1. Who We Are

TopSpin Games is a trading name of Sigma Gaming Limited, a company registered in England and Wales (Company No. 09222120). Our registered address is 5 Brayford Square, London, England, E1 0SG.

Sigma Gaming Limited holds a UK Gambling Commission Remote Gambling Software Licence (Account No. 40865). We operate in two capacities covered by this policy:

As a game studio and B2B provider: We develop and supply casino games and software to licensed casino operators worldwide through our studio at topspin.games.

As a casino affiliate: Through our India-facing affiliate content at topspin.games/in/ we publish independent casino reviews, game guides and informational content. We do not operate a casino, accept player deposits or process gambling transactions.

For data protection purposes, Sigma Gaming Limited is the data controller in both capacities. If you have any questions about how we handle your data, contact us at [spinme@topspin.games] or by post at the registered address above.

2. What Data We Collect and Why

2.1 Website Visitors (Affiliate Content)

When you browse topspin.games we collect:

Technical data collected automatically: IP address, browser type and version, device type, operating system, pages visited, time and date of visit, referring URL and session duration. This is collected via cookies and analytics tools. The lawful basis is legitimate interests -we use this data to understand how our content performs and to improve the user experience.

Contact enquiries: If you use our contact form we collect your name, email address and the content of your message. The lawful basis is contract performance or legitimate interests depending on the nature of the enquiry.

Newsletter or update subscriptions: If you subscribe to updates we collect your email address. The lawful basis is consent. You can withdraw consent at any time by unsubscribing.

We do not collect any financial data, payment details or gambling account information from visitors to our affiliate content. We are not a casino and do not process player deposits or withdrawals.

2.2 B2B Partners and Operator Clients

When you engage with us as an operator, integration partner or business client we collect:

Business contact data: Name, job title, company name, business email address, phone number and business address. The lawful basis is contract performance or pre-contractual steps.

Integration and technical data: API credentials, technical configuration details and usage data related to our game integrations. The lawful basis is contract performance.

Financial and commercial data: Billing information, bank details for revenue share arrangements and commercial agreement terms. The lawful basis is contract performance and legal obligation.

We retain business contact data for the duration of the commercial relationship and for six years thereafter to comply with UK tax and legal requirements.

2.3 Job Applicants

If you apply for a role at TopSpin Games we collect your CV, cover letter, contact details and any other information you provide. The lawful basis is legitimate interests. We retain unsuccessful application data for twelve months and will delete it on request.

3. Cookies and Tracking

We use cookies and similar technologies on topspin.games. Under the UK Privacy and Electronic Communications Regulations (PECR) we are required to obtain your consent before placing non-essential cookies.

• Strictly necessary cookies: Required for the website to function. These cannot be disabled. No consent required.
• Analytics cookies: We use Google Analytics to understand how visitors use our site. These cookies collect anonymised data about pages visited and session behaviour. These are only placed with your consent.
• Marketing and affiliate tracking cookies: We use affiliate tracking technologies to measure referrals to third-party casino platforms. These cookies record clicks to affiliated casinos for the purpose of attributing commissions. These are only placed with your consent.

You can manage your cookie preferences at any time through our cookie banner or your browser settings. Withdrawing consent does not affect any processing carried out before withdrawal.

4. How We Share Your Data?

We do not sell, rent or trade your personal data.

We may share data with the following categories of recipients:

• Analytics providers: Google Analytics processes anonymised visitor data on our behalf under a data processing agreement. Data may be transferred to the United States under standard contractual clauses.
• Email and communication tools: If you contact us or subscribe to updates, your data may be processed by our email service provider under a data processing agreement.
• Affiliate network platforms: Click and referral data is processed by affiliate tracking platforms to manage commission arrangements with casino operators.
• UKGC and regulatory authorities: We may be required to share data with the UK Gambling Commission or other regulators in connection with our software licence obligations.
• Legal compliance: We will disclose data to law enforcement or regulatory bodies where required by law, court order or to protect the rights and safety of individuals.
• Business transfers: In the event of a merger, acquisition or sale of all or part of our business, personal data may be transferred to the acquiring entity. You will be notified in advance of any such transfer.

All third-party processors who handle your data on our behalf are subject to data processing agreements and are required to process data only in accordance with our instructions.

5. International Data Transfers

Some of our service providers are based outside the UK. Where data is transferred outside the UK we ensure appropriate safeguards are in place, including UK International Data Transfer Agreements, standard contractual clauses or adequacy decisions recognised by the UK Government under the Data Use and Access Act 2025. You can request details of the specific safeguards in place by contacting us.

6. How Long We Keep Your Data?

We retain data only for as long as necessary for the purpose for which it was collected or as required by law.

Data type	Retention period
Website analytics	26 months
Contact form enquiries	2 years from last contact
Newsletter subscriptions	Until unsubscribe or withdrawal of consent
B2B contracts and commercial data	6 years from end of contract
Job applications (unsuccessful)	12 months
UKGC compliance records	As required by licence conditions

7. Your Rights Under UK GDPR

As a UK resident you have the following rights regarding your personal data:

• Right of access: You can request a copy of the personal data we hold about you.
• Right to rectification: You can ask us to correct inaccurate or incomplete data.
• Right to erasure: You can ask us to delete your data where there is no legitimate reason for us to continue processing it.
• Right to restrict processing: You can ask us to pause processing of your data in certain circumstances.
• Right to data portability: You can request your data in a structured, machine-readable format where processing is based on consent or contract.
• Right to object: You can object to processing based on legitimate interests. We will stop unless we can demonstrate compelling legitimate grounds.
• Rights related to automated decision making: We do not make automated decisions that produce legal or similarly significant effects about individuals.
• Right to withdraw consent: Where processing is based on consent you can withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

To exercise any of these rights contact us at [privacy@topspin.games]. We will respond within one calendar month. There is no charge for exercising your rights. We may need to verify your identity before processing your request.

If you are not satisfied with how we handle your data you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113

8. 18+

Our affiliate content at topspin.games/in/ is directed exclusively at adults aged 18 and over. Our B2B studio services are provided exclusively to regulated casino operators who are themselves required to implement age verification. We do not knowingly collect data from anyone under the age of 18. If you believe we have inadvertently collected data from a minor please contact us immediately and we will delete it.

9. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or alteration. These include encryption of data in transit, access controls and regular security reviews. No system is entirely secure. In the event of a data breach that is likely to result in risk to your rights and freedoms we will notify the ICO within 72 hours and affected individuals without undue delay where required.

10. Affiliate Disclosure

topspin.games/in/ publishes casino reviews and game guides. Some links to casino platforms are affiliate links. If you click through and register or deposit at a recommended casino we may receive a commission from the operator. This does not affect the price you pay or the terms you receive. Our editorial content is independent and based on genuine research and testing. We do not accept payment to alter our reviews or rankings.

Our affiliate tracking uses cookies. Details are set out in section 3 above. We do not share individual player data with casino operators. Commission tracking is based on anonymised click and referral data only.

11. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices, legal obligations or regulatory requirements. The updated version will be posted on this page with a revised effective date. Where changes are material we will notify you by email if we hold your contact details.

12. Contact Us

For any questions, requests or complaints regarding this policy:

Email: [spinme@topspin.games]

Post: Data Privacy, Sigma Gaming Limited, 5 Brayford Square, London, England, E1 0SG

For complaints you can also contact the ICO directly at ico.org.uk.