Privacy Policy

THE CGS GROUP, LLC PRIVACY POLICY

FOR USERS OF THE Spintime™ SERVICE

(Last updated February 9, 2026)

Our business name is the "Spintime™ Service." We are the owner of the web site www.spintime.app. (The "Website.") All information provided in this Privacy Policy pertains only to account holders and applicants for such accounts with www.spintime.app (in this Privacy Policy, sometimes, "Website" or the Spintime™ Service). The Spintime™ Service enables You to transmit necessary identity authentication and location confirmation, as required to enable administration of the Spintime™ Service and its compliance with applicable law. By enrolling as a registered user of the Spintime™ Service, You may be able to conveniently access the web sites of "third party" merchants. Each time you do so, your identity as a registered user of the Spintime™ Service is authenticated. This Privacy Policy explains Our collection, processing, protection and use of Your Personal Identifying Information. By Personal Identifying Information We mean information that identifies You, relates to You, describes or could reasonably be linked, directly or indirectly, with You and used to contact You. Personal Identifying Information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with You: identifying information such as a name, alias, postal address, Internet protocol address, email address, account name, social security account number, driver's license number, passport number, and other similar identifying information, any feature which enables Us to ascertain Your location when You are connected to the Spintime™ Service, and anything else defined as Personal Identifying Information under a statute of the state where you access the Spintime™ Service. By Sensitive Personal Identifying Information, We mean Your social security account number, driver's license number, state identification card number, passport number; provided however that Personal Identifying Information does not include information that is publicly available.

GENERAL AND CONTACT INFORMATION

As required by law, We take Your privacy and that of every user of the Spintime™ Service seriously. We make reasonable efforts to protect it from unauthorized disclosure. We have created this Privacy Policy in order to inform You about our collection, protection and use practices related to your Personal Identifying Information and Sensitive Personal Identifying Information that We collect and process in the ordinary course of operating the Spintime™ Service. We will never without your prior knowledge and approval, knowingly sell your Personal Identifying Information to a data broker or other "third party" or use it for profiling any Personal Identifying Information not in depersonalized form.

This Privacy Policy is subject to change at any time. Any changes will be posted on the Website. This Privacy Policy is integral with and a part of Our Terms of Use and Service Agreement and subject to all of its terms, including the definitions that are set out in that Agreement. As is the case with Our Terms of Use and Service Agreement, We have and reserve the prerogative to make amendments, modifications or revisions to the Website, the Spintime™ Service and this Privacy Policy. The posting of any amendments, modifications or revisions, online at the Spintime™ Service Website, shall constitute effective notice under these Policies. Your continued use of the Spintime™ Service, thereafter, shall constitute Your acceptance of such changes. By using Our identification and location services and as provided in Our Terms of Use and Service Agreement, You consent to Our Privacy Policy.

WHAT PERSONALLY IDENTIFIABLE INFORMATION DO WE COLLECT; HOW IS IT USED?

In order to use the Spintime™ Service, YOU will be asked for certain Personal Identifying Information such as name, email address, home or business address, telephone number and other information. For example, when You request information about or register as a user of the Spintime™ Service, contact information which You provide to us can be used to communicate with You, to verify your identity as required by law and to make governmental reports as required by law. We will not collect Personal Identifying Information from You while You use the Spintime™ Service, unless You voluntarily provide it to Us or otherwise authorize Us to collect such information; but providing to Us the Personal Identifying Information that we request is at all times a condition of Your continued use of the Spintime™ Service. Whenever Your cash winnings from Our free game of chance promotion are six hundred dollars ($600.00) or more during a calendar year, We will request your signature and social security account number on an IRS Form W-9 to enable Our required reporting to applicable tax authorities.

For example, if You purchase services or merchandise, you will be required to provide information necessary to complete the purchase transaction. The Spintime™ Service transmits necessary identity authentication and location information, as required by this Website. By enrolling as a registered user of the Spintime™ Service, You are agreeing to have Your location (including Your cell phone location or as applicable mobile device location) and other Personal Identifying Information logged and used for account authentication. Each time this occurs some or all of the following information may authenticate: your identity, location, service approval, activity, and financial transaction approval. This information is stored securely and used to be sure that you are currently within the proper parameters for compliance associated with the Spintime™ Service, as required both by law, and the Terms of Use and Service Agreement.

Your data will be used by the Spintime™ Service, by any "third-party" selling merchant, by our contracted money transmitting business, and by Our contracted data processor (all) in order to execute the functions of the Spintime™ Service. Data provided by Yourself and the other "third parties" characterized above as well as any data collected as part of the functions of the Spintime™ Service may be shared with "third party" transaction participants, including (not limited to) Our contracted data processor.

All identity, location, financial, device, or other known data is transmitted via Secure Socket Layer (SSL) technology into password protected servers. This information is used only to enable the Spintime™ Service to conduct the services that We provide to You and other registered users of the Website. Specific Personal Identifying Information connected with financial transactions between Yourself and any "third party" other than those characterized in this paragraph is not shared with any other person unless disclosed in this Privacy Policy or with Your consent. This data may be used by Our contracted data processor for updating and enhancing your legally-required "know your customer" identification profile.

You may provide other information about Yourself in addition to the mandatory Personal Identifying Information ("Voluntary Information") for example. Voluntary Information provided to the Spintime™ Service will be viewable by all other users of the Spintime™ Service and will not be protected from public disclosure.

We may use or disclose Your Personal Identifying Information for any and all of the following uses and purposes:

1. to operate and manage the Spintime™ Service, and
2. to provide services or information that You have requested, and
3. to respond to other inquiries or requests from You, and
4. to provide You with information about specials or new services that the Spintime™ Service will be introducing, and
5. to enable our internal business functions and purposes, such as data analysis and audits, and
6. to enhance our information and to aid us in providing to You and other users of the Spintime™ Service, targeted promotions, and
7. in the establishment or exercise of legal rights or defenses against legal claims, and
8. to comply with applicable laws, and
9. to comply with a valid legal process, such as a subpoena, a national security letter or a court order, and
10. to investigate suspected fraud or a violation of our Terms of Use and Service Agreement.

If You open an account with the Spintime™ Service, We retain Your Personal Identifying Information for as long as Your account is open, plus thirty six months, in order to have it available for audit purposes and as required by law. If You have applied to open an account with the Spintime™ Service but Your application was denied, or if We have permanently blocked or closed Your account for breach of Our Terms of Use and Service Agreement, We retain Your Personal Identifying Information for five years following the date when Your account was permanently blocked or closed. During these periods We will retain Personal Identifying Information, including information from closed accounts, to comply with law, to prevent fraud, to collect any money owed, to resolve disputes, to troubleshoot problems, to assist or cooperate with any governmental or other investigation, to enforce the "award rules" of our prize promotions, to prepare marketing and demographic studies and statistical reports, and to take any other necessary or appropriate actions permitted by law. Please be aware that it may be technologically impossible to remove from our servers every record or information that You provide to us. The need for backup means that a copy of Your personal information may exist in non-erasable form.

Except in connection with a sale, assignment, merger, change of control or financing of CGS Group, LLC, We will not without Your consent sell or transfer Your Personal Identifying Information to any "third party" with whom we do not maintain a contractual commitment to protect the confidentiality of Your Personal Identifying Information and does not assist or participate in the operation of the Spintime™ Service. In any event, we will not sell or transfer Your Personal Identifying Information to a data broker or to any third-party not affiliated with or associated as a contractor which assists the Spintime™ Service, without consent, except in connection with the sale, assignment or merger of the Spintime™ Service. None of CGS Group, LLC, the Spintime™ Service and Our contracted data processors use spyware.

We may use Voluntary Information for marketing to You of promotions, features and offers available from the Spintime™ Service and requests for no-purchase (i.e., free) participation in Our game promotions. From time to time, We may send to You by text message and/or email, surveys, questionnaires and other requests for user feedback. Any responses that We may receive from You and other users of the Spintime™ Service will be used only for evaluation of the Spintime™ Service. No Personally Identifiable Information from respondents to such surveys, marketing materials, requests for free participation in Our free game of chance promotions or solicitations will be shared with any person who is not an employee of CGS Group, LLC, or a contractor which assists Us and is subject to a contractual covenant to protect Your data the same as We do, or except is stated in any of the Terms of Use and Service Agreement, this Privacy Policy or the Award Rules of Our free game of chance promotions. HOWEVER, YOU CAN OPT OUT of receiving these communications. To opt out of text solicitations, visit www.spintime.app, Settings, and select to be removed from SMS Content. You can also opt out of the Spintime™ Service receiving Your location coordinates. To opt out of providing Your location coordinates, use Your device to disable this feature. (Please note that opting out of Our receipt of location coordinates may adversely affect Your use of the Spintime™ Service.)

WHAT INFORMATION DO WE COLLECT THAT IS NOT PERSONAL IDENTIFYING INFORMATION?

We collect and track certain information that is not Personal Identifying Information. This includes as non-limiting examples, Internet protocol address, browser type, access times, domain names, usage habits and other information which does not specifically identify any person. We may use, share and disclose non-personally-identifiable information for any number of reasons, including, but not limited to, interaction with contracted data processors, "third-party" merchants, money transferring businesses, independent testing laboratories and other business "partners," and otherwise improving the Spintime™ Service.

USER LOCATION VERIFICATION FOR MOBILE AND TWO-DEVICE AUTHENTICATION

The Spintime™ Service uses information about Your location, to enable compliance with Our Eligible Jurisdictions and Excluded Jurisdictions policies as from time to time specified in Our Terms of Use and Service Agreement and to provide customized data to Your account profile. Our electronic system and that of Our contracted data processor detects Your device's approximate location whenever it is turned on (subject to communications common carrier coverage limitations) and connected to the Spintime™ Service. We use location information for:

1. If Your device is geo-located within an Excluded Jurisdiction, the login session may be terminated.
2. If Your mobile device is geo-located within a permitted jurisdiction, an access code may be sent, via text message, to the mobile device, requesting You to validate Your device access.

Location coordinates are only collected after You have agreed to the Spintime™ Service Terms of Use and Service Agreement, including this Privacy Policy and the Award Rules of our free game of chance promotion.

Depending upon the type of Your device, We may also be able to obtain a wide array of data points to its approximate location. These data services, known as Location-Based Services, are made available by the Spintime™ Service usually via applications that may be pre-loaded on Your device, or manually or automatically downloaded from various application stores, or via connected, interactive websites.

We may provide location-based services or provide trusted and contracted "third parties" with access to Your device's approximate location, in order to provide services to You. When the location of Your device is requested, You will be given the option to allow the Spintime™ Service or to deny it. We and our contracted data processor comply with CTIA's Best Practices Guidelines for Location-Based Services.

DO WE USE COOKIES, LOGS, IDENTIFIERS OR PIXEL TAGS?

"Cookies" are small text files that a web site can write to Your computer. Like many other web sites, the Spintime™ Service may use cookies to identify You, to customize web page content and allow You to log in once to our web site, and then search or post, without having to log in again. If You reach our web site by clicking on a link or advertisement on another web site, then we also log that information. This helps Us to maximize our Internet exposure and to understand Your interests and those of Our other enrolled users. Cookies cannot be used to read data contained on Your hard drive or device. Cookies cannot retrieve information from any other cookies created by other web sites. Cookies are also used by merchants who sell services or merchandise through the Spintime™ Service to identify You as a Customer of the Spintime™ Service.

To maintain privacy, You can disable Your browser's ability to accept cookies. However, if You do so, You may find that Your browser reacts strangely when visiting the Spintime™ Service and other web sites. Most browsers enable You to disable or delete cookies. For example, in Internet Explorer (version 9), You can block cookies using the cookie handling override settings, available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced." In Firefox (version 16) You can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and un-ticking "Accept cookies from sites." In Chrome (version 23), You can block all cookies by accessing the "Customize and control" menu, and clicking "Settings," "Show advanced settings" and "Content settings," and then selecting "Block sites from setting any data" under the "Cookies" heading.

You can also delete cookies already stored on Your computer. For example, In Internet Explorer (version 9), You must manually delete cookie files (instructions for doing so are at http://support.microsoft.com/kb/278835). In Firefox (version 16), You can delete cookies by clicking "Tools", "Options", "Privacy" and then "Show Cookies", and then clicking "Remove All Cookies." In Chrome (version 23), You can delete all cookies by accessing the "Customize and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Delete cookies and other site and plug-in data" before clicking "Clear browsing data". Again, doing this may have a negative impact on the usability of many web sites, including the Spintime™ Service.

Merchants who link with the Spintime™ Service may use cookies on their own web site or an external web site. We have no access to, or control over these cookies. Accordingly, We will not be responsible for their use or misuse. This Privacy Policy only covers the use of cookies by the Spintime™ Service. It does not cover the use of cookies by any "third-party" or web site other than www.spintime.app.

Like many other web sites, www.spintime.app makes use of log files. The information inside the log files includes Internet protocol ("IP") addresses, type of browser, Internet service provider ("ISP"), date/time stamp, referring/exit pages and number of clicks (all) that we use to analyze trends, administer the Spintime™ Service, track Your movement around our web site, and gather demographic information. IP addresses and other such information are not linked to any information that is personally identifiable. We use device identifier technologies. These may include device-level cookies and other technologies used to identify a device on future visits. These identifier technologies may be in the form of a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Identifiers can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website. Device identifiers may be either "persistent" or "session" identifiers. A persistent identifier consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until deleted or (if the user does not delete the file) its set expiration date. A session identifier, on the other hand, will expire at the end of the session, when the web browser is closed. The Spintime™ Service uses session identifiers and persistent identifiers. You will also encounter identifiers derived from contracted data processors, contracted independent testing laboratories, contracted "third party" merchants and contracted analytics identifiers. When You use the Spintime™ Service, You may also be sent "third-party" identifiers that can be utilized by service providers, so that they may obtain from Your device, the ability to track it across multiple services, to build a profile of Your activity; and to target services which may be used to determine Your location, habits, and other personal data.

In addition, tracking analytics are used to analyze the use of our Service. Analytics uses and reports only deidentified user data. ("Deidentified" means information that cannot reasonably be used to infer information about, or otherwise be linked to You or any other user of the Spintime™ Service. We and our contracted data processors take reasonable measures to ensure that the information cannot be associated with You or Your household. We commit to maintain and use the information in deidentified form and not to attempt to reidentify the information, except for testing the effectiveness of our methods of deidentification, and to contractually obligate any recipients of the deidentified information to do the same.)

The system of the Spintime™ Service and its contracted data processor generates deidentified statistical and other deidentified information about You, by means of computer identifiers, which are stored on Your device. The information generated, relating to the Spintime™ Service, is used to create reports about Your use of the Spintime™ Service. The system will store this information. Device identifiers do not contain any information that personally identifies You. However, Personal Identifying Information that is stored about You may be linked to the information stored in, and obtained from, cookies.

Merchants, and non-affiliated "third parties" that link with the Spintime™ Service may also use so-called "pixel tags," "web beacons," "clear GLIFs" or similar technology (collectively, "Pixel Tags"), in connection with some web site pages and HTML-formatted e-mail messages. These are used to compile aggregate statistics about web site usage and response rates, among other things. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to web site visitors, and may be associated with Cookies on the visitors' hard drives. Pixel Tags allow the Spintime™ Service to count the number of users who have visited certain pages of the Spintime™ Service, to deliver branded services, to provide online advertising, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, pixel tags can tell the sender whether, and when, the e-mail has been opened.

IS MY INFORMATION PRIVATE WITH AFFILIATES AND CONTRACTORS ASSOCIATED WITH THE Spintime™ SERVICE?

The Spintime™ Service may contain links to various "third-party" web sites and any external web sites of our contracted data processors, contracted independent testing laboratories, contracted "third party" merchants and contracted analytics compilers. Each of these web sites may have a privacy policy that differs from that of the Privacy Policy of Spintime™ Service. The Privacy Policy of the Spintime™ Service does not cover the privacy policies of other web sites. We encourage You to check the privacy policies of each web site that You may visit or interact with. The only information that may be shared between the Privacy Policy of Spintime™ Service and a web site of any of our contracted data processors, contracted independent testing laboratories, contracted "third party" merchants and contracted analytics compilers is that which we tell You about, either through this Privacy Policy or Terms of Use and Service Agreement of CGS Group, LLC.

WHAT ABOUT DATA SECURITY?

We and Our contracted Data Processor will use reasonable efforts to keep Your Personal Identifying Information accurate, protected from unauthorized disclosure and safe for the business purposes identified in this Privacy Policy. You are responsible for informing us about changes to Your Personal Identifying Information. We will update personal information when necessary to keep it accurate, or otherwise provide to You a means (such as account access) to make such updates. We have instituted appropriate security measures that protect against the loss, misuse, unauthorized disclosure or alteration of Personal Identifying Information that we have collected from You. We require that our contracted data processors, contracted independent testing laboratories, contracted "third party" merchants and contracted analytics compilers provide contractual assurance regarding the security of the Personal Identifying Information that You and our other users provide to Us and them. However, in the event of a breach of their security measures, You agree that We will not be liable for any loss of data or other damage to You or to Your business or organization.

We limit access to Your Personal Identifying Information to employees of CGS Group, LLC for whom we reasonably believe have a need to know, in order to operate the Spintime™ Service and to trusted contractors who process Your data and agree with Us, for the "third-party" benefit as well of Our enrolled users and others whose data we collect, to implement and maintain data security measures as effective as Our own. We have physical, electronic, procedural and contractual safeguards that comply with all applicable laws, to protect against the loss, misuse, unauthorized disclosure or alteration of Personal Identifying Information that we have collected from You. We have security measures and tools, such as firewalls, in place, to help protect against the loss, misuse, unauthorized disclosure and alteration of the Personal Identifying Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with Us is no longer secure (for example, if You feel that the security of an account that You have with us has been compromised), please notify us of the problem as soon as possible by sending an email to [email protected] or calling us at (659) 247-2477.

MAY I SEE THE PERSONAL IDENTIFYING INFORMATION WHICH THE Spintime™ SERVICE COLLECTS ABOUT ME? WHAT OTHER RIGHTS DO I HAVE IN RESPECT OF THAT PERSONAL IDENTIFYING INFORMATION?

You have the right to review Your Personal Identifying Information that We control, but no more frequently than twice in any twelve-month period. You have the right to correct any of Your Personal Identifying Information that We control. You have the right to require us to delete all or part of Your Personal Identifying Information that We control; provided however that You do not have the right to require Us to delete Personal Identifying Information which United States federal law requires Us to maintain. You have the right to require Us to limit Our use of Your social security account number to that use which is necessary to perform the services from time to time provided by the Spintime™ Service.

We will provide Your Personal Identifying Information in an understandable format and will accommodate Your exercise of the foregoing rights (all) only in response to a Verifiable User Request from You or Your agent on Your behalf. By a "Verifiable User Request" We mean a written request that is made by Yourself or by a natural person or a juridical person registered with the secretary of state in the state of Your residence, authorized by Yourself to act on Your behalf, or by a person who has power of attorney or is acting as a conservator for You, and that in all cases the We can verify, using commercially reasonable methods, that You are the person about whom the We have collected Personal Identifying Information upon whose behalf the request is submitted to Us. We shall not be obligated to provide information to You or to accommodate Your other exercise of Your rights stated here to delete Personal Identifying Information, or to correct inaccurate Personal Identifying Information, or to limit Our use of Your Personal Identifying Information if We cannot verify that You, Your attorney in fact or other duly authorized agent making the request is You or as applicable Your representative authorized by the consumer to act on Your behalf.

We are not responsible for removing or correcting Your Personal Identifying Information from the records of any "third-party" merchant who has previously been provided Your Personal Identifying Information when a web site of the "third-party" merchant was accessed by a link on the Spintime™ Service. If We are either not able or not required to provide access to some aspect of Your Personal Identifying Information or some aspect of Your exercise of Your rights regarding it, if not prohibited by law We will provide reasons for such denying, such as: that by doing so would likely reveal personal information that we control about someone other than Yourself, or that it is confidential commercial information or attorney-client privileged communications, or that the information relates to a breach of an agreement or a contravention of law, or that its disclosure could reasonably be expected to threaten the life or security of another individual, or that the disclosure is prohibited by United States federal law.

To exercise these rights, You can send an email with all pertinent information, including Your name and user identification, to [email protected]. You may also exercise these rights by sending by United States Postal Service a written request to Spintime.app Support, Post Office Box 353, Kings Mountain, NC 28086.

WHERE IS THE WEB SITE LOCATED?

The Spintime™ Service web site is maintained within the United States of America.