Effective Date: October 15, 2025

SPINA, Inc. ("SPINA," "we," "our," or "us") values your privacy and wants you to understand how we collect, use, and protect your information.

This Privacy Policy explains how we handle personal data when you use our website, mobile experiences, and skill-based gaming platform (collectively, the "Platform").

By using SPINA, you agree to this Privacy Policy and our Terms of Service. If you don't agree, please stop using the Platform.

1. Information We Collect

We collect the following categories of information to provide and improve SPINA:

a. Information You Provide

• Account Information: Name, username, email, phone number, and password.

• Identity Verification (KYC): Government-issued ID, selfie, and date of birth for age and identity checks.

• Payment Information: Deposit and withdrawal details, transaction history, and wallet balances (processed through third-party partners).

• Support & Communication: Any messages or emails you send us.

b. Information We Collect Automatically

• Device Data: IP address, device model, operating system, browser type, and settings.

• Usage Data: Match history, gameplay data, session length, and actions within the app.

• Location Data: GPS coordinates or device-based location to verify state eligibility.

• Cookies & Analytics: We use cookies and analytics tools to understand usage trends and improve performance.

c. Information from Other Sources

We may receive information from third-party services (like payment processors, analytics providers, or verification partners) to help operate SPINA securely and legally.

2. How We Use Information

We use your data to:

• Create and manage your account.

• Verify your identity, eligibility, and location.

• Enable matches, process entry fees, and award winnings.

• Detect and prevent fraud, cheating, or prohibited play.

• Improve gameplay, user experience, and performance.

• Communicate updates, promotions, and account notices.

• Comply with legal, tax, and regulatory requirements.

We only use data as necessary to operate and secure the Platform — never to sell user information or for unrelated advertising.

3. Sharing Information

We share limited data with trusted service providers who help us operate SPINA. This includes:

• Payment processors (to handle deposits, withdrawals, and fees).

• Identity verification vendors (to perform KYC and age checks).

• Cloud and analytics providers (for hosting and performance monitoring).

Each partner is contractually required to protect your data and use it only for SPINA's purposes.

We may also disclose information if required by law, legal process, or to protect our rights or users' safety.

SPINA does not sell or rent personal data to third parties.

4. Cookies and Tracking

We use cookies and similar technologies to:

• Keep you logged in and secure your session.

• Remember your preferences and settings.

• Analyze app performance and gameplay metrics.

You can disable cookies in your browser, but some features may not work properly.

5. Data Retention

We keep data only as long as necessary for legitimate business and legal purposes:

• Account and transaction data: retained while your account is active and up to 5 years after closure.

• Verification data (ID/selfie): retained only as long as needed to confirm identity and meet compliance obligations.

• Gameplay logs: retained for fraud prevention, dispute resolution, and analytics.

When data is no longer needed, it is securely deleted or anonymized.

6. Biometric and Location Data

Biometric Information

If you complete identity verification using a selfie or facial scan, we may collect biometric identifiers such as facial geometry. We use these only to verify your identity and prevent fraud. We do not sell or share biometric information, and we delete it once verification is complete or as required by law.

Location Information

We collect device-based GPS data to confirm that players are in eligible states. You must allow location access to participate in real-money matches. We do not track continuous movement or location outside SPINA activity.

7. Data Security

We use reasonable and appropriate safeguards to protect your information, including encryption in transit and at rest, access controls, and regular security testing.

No system is 100% secure, but we take data protection seriously and continually improve our practices.

8. Your Rights and Choices

Depending on your state, you may have the right to:

• Request access to or deletion of your personal data.

• Correct inaccurate information.

• Opt out of the sale or sharing of personal data (we don't sell data).

• Receive notice of how your data is used.

To exercise these rights, contact hi@spina.app. We may verify your identity before processing requests.

9. Children's Privacy

SPINA cash play is for players 18 years and older. We do not knowingly collect sensitive data from minors. If you believe a minor has created an account, contact hi@spina.app and we will remove associated data.

10. Updates to This Policy

We may update this Privacy Policy periodically to reflect new features, vendors, or legal requirements. When we do, we'll post the new version and update the "Effective Date" above.

If changes are significant, we'll notify you in-app or by email.

11. Contact Us

If you have questions or privacy requests, contact us at: hi@spina.app

Mailing Address: 903 Peachtree St NE Atlanta, GA 30309 UNIT 1024