Privacy Policy

Last updated: [DATE]

This policy explains what personal data Spin Crush collects, why, how long it is kept and what you can do about it. It covers this website and the Spin Crush Android application.

1. Who we are

[REGISTERED COMPANY NAME], [REGISTERED ADDRESS], is the data fiduciary responsible for the personal data described in this policy. You can reach us at support@spincrush-in.com.

2. What we collect

List only what you genuinely collect. Remove anything that does not apply.

2.1 Information you give us

  • Account details such as [name, email address, mobile number] when you register.
  • Anything you send us by email or through a contact form.
  • [Payment details, if applicable — state who processes them and that you do not store card numbers, if that is the case.]

2.2 Information collected automatically

  • Device and app information: device model, operating system version, app version, language and time zone.
  • Usage data: which screens and features you use, and when.
  • Log data: IP address, and the date and time of requests.
  • [Advertising or analytics identifiers, if you use them — name the services.]

2.3 What we do not collect

[State what you deliberately do not collect — for example contacts, SMS, call logs or precise location. Only claim this if the app genuinely does not request those permissions.]

3. Why we use it

  • To provide, operate and maintain the app and this website.
  • To respond to support requests.
  • To detect, investigate and prevent fraud, abuse and security incidents.
  • To understand how features are used so we can improve them.
  • To meet legal and regulatory obligations.

4. Legal basis and consent

Where the Digital Personal Data Protection Act, 2023 applies, we process personal data on the basis of your consent or for legitimate uses permitted by the Act. You may withdraw consent at any time, as described in section 8. Withdrawing consent does not affect processing that already took place.

5. Sharing

We do not sell personal data. We share it only with:

  • Service providers who process data on our behalf — [hosting, analytics, payment processing, customer support tooling] — under contract and only for those purposes.
  • Authorities, where we are legally required to disclose it.
  • An acquirer, if the business is sold or merged, with notice to you.

6. Cookies and similar technologies

[State which cookies this site sets and why — for example session cookies, analytics cookies, and any advertising cookies. If the site uses Google Analytics or similar, name it and link to its privacy policy. If you set non-essential cookies for visitors in regions requiring consent, describe your consent banner here.]

7. Retention

We keep personal data only as long as needed for the purposes above, or as long as the law requires. [State actual retention periods per data category where you can — for example "support emails are deleted after 24 months".] When data is no longer needed it is deleted or anonymised.

8. Your rights

Subject to applicable law, you can:

  • Ask what personal data we hold about you and get a copy.
  • Ask us to correct data that is inaccurate or incomplete.
  • Ask us to erase your data.
  • Withdraw consent you previously gave.
  • Nominate another person to exercise these rights on your behalf if you are unable to.
  • Raise a grievance with us, and escalate to the Data Protection Board of India if you are not satisfied with our response.

To exercise any of these, email support@spincrush-in.com. We will respond within [NUMBER] days.

9. Grievance officer

[NAME]
[EMAIL ADDRESS]
[POSTAL ADDRESS]

Naming a grievance officer is a legal requirement in India. Fill this in with a real person and a monitored address.

10. Security

We use reasonable technical and organisational measures to protect personal data — [encryption in transit, access controls, and so on]. No system is completely secure, and we cannot guarantee absolute security. If a breach affects your data, we will notify you and the relevant authority as the law requires.

11. Children

Spin Crush is intended for users aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

12. Third-party links

This site and the app may link to services we do not control. Their privacy practices are their own — read their policies before providing information to them.

13. Changes to this policy

We may update this policy. The date at the top shows when it last changed, and material changes will be flagged in the app or on this site before they take effect.

14. Contact

Questions about this policy: support@spincrush-in.com, or see the contact page. Our terms & conditions cover the rules for using the app itself.