Privacy Policy

PRIVACY POLICY

This policy was last updated on: April 2, 2026

Your privacy is important to us, and we make every effort to protect your personal data. This Privacy Policy covers the use of all products, services, content, features, and technologies offered by us through our website spinyolo.com and related platforms (collectively referred to as the "Services"). Here we explain how we handle your data, what privacy rights you have, and what legal remedies are available to you – noting that our company is located outside the European Union. We encourage you to read this Privacy Policy carefully before using our Services.

Table of Contents

1. Who we are
2. What data we collect
3. Why we process your information
4. Your rights
5. Communication and marketing
6. Who we share your data with
7. Transfers of data to third countries
8. Data storage and retention
9. How we protect your data
10. Links to third-party websites
11. Contact
12. Changes to the Privacy Policy

1. Who we are

The controller of your personal data is:
SAM GLOBAL DEVELOPMENT TRADING CO., LTD.
Registered address: No. 10, Lum Street, Tropeang Thling 3 Village, Sangkat Chorm Chao 1, Khan Porsenchey, Phnom Penh City, Cambodia
Registration number: 1,500.00.22.34
Email: support@spinyolo.com

Important information regarding location outside the EU:

Our company is based in Cambodia. Although we offer Services to individuals originating from the European Union and the United States, we do not provide services to individuals physically located within the EU or the United States. By using our Services, you declare that you are aware of this, confirm that you are not located in the EU or the United States, and accept these conditions. Use of the Services without meeting this requirement is prohibited, and the user bears full responsibility for any violation.

The controller has not appointed a Data Protection Officer (DPO) due to the lack of establishment in the EU and the absence of services provided within the EU. However, in the interest of protecting user data, we follow standards similar to Regulation (EU) 2016/679 (GDPR). For data-related matters, please contact us directly using the details above.

2. What data we collect

2.1. Data provided directly by you

Registration and account information:
When you register, we may collect:

• Email address
• Full name
• Username

Payment data:
Required to process transactions – handled by external payment providers (e.g., credit cards, bank transfers). We do not store full card numbers.

Communication with us:
When you contact us (form, email, chat), we collect message content, email address, and name.

Surveys and feedback:
If you voluntarily complete surveys or leave reviews, we collect your responses.

2.2. Data collected automatically

When using our Services, we automatically collect:

• Device information: operating system, browser type, IP address, language, ISP
• Activity data: pages visited, links clicked, time spent, search terms, content sequence
• Cookies and similar technologies (see Cookie Policy)

2.3. Data obtained from third parties

We may receive your data from:

• Payment partners (partial card data, name)
• Law enforcement or authorities if required by law

2.4. Age restrictions

Our Services are not intended for minors (under 18). We do not knowingly collect their data.

3. Why we process your information

We process your data based on:

• Contract – to provide Services
• Legitimate interest – to improve Services, ensure security, analytics
• Consent – for newsletters and personalized marketing
• Legal obligation – when required by Cambodian law

3.1. Processing purposes

3.1.1. Service provision and account management
Authentication, profile management, payments, support
Basis: contract

3.1.2. Service improvement
Personalization, analytics, search optimization
Basis: legitimate interest

3.1.3. Security and fraud prevention
Monitoring activity, detecting bots, preventing attacks
Basis: legitimate interest

3.1.4. Marketing and advertising
Newsletters (with consent), personalized ads, remarketing
Basis: consent or legitimate interest

4. Your rights

You have the following rights under GDPR; however, due to the company's location in Cambodia, exercising them may be limited:

• Access to data
• Rectification
• Erasure ("right to be forgotten")
• Restriction of processing
• Data portability
• Objection
• Withdrawal of consent

Contact us via email to exercise your rights. We will respond within a reasonable time.

5. Communication and marketing

5.1. Essential notifications
We will send important service-related information (cannot be disabled).

5.2. Marketing
With your consent, we send newsletters and offers. You can unsubscribe anytime.

5.3. Transactional communication
We may contact you regarding inquiries or service-related matters.

6. Who we share your data with

We may share data with:

• Technical service providers (hosting, payments, analytics, chat tools)
• Authorities if required by law

We do not sell your personal data.

7. Transfers to third countries

Your data is processed in Cambodia (and possibly other countries via providers).

Cambodia is not recognized by the EU as providing adequate protection. We do not use Standard Contractual Clauses (SCC).

Transfers are based on:

• Your explicit consent
• Contract necessity

Consequences:
Your data may be accessed by Cambodian authorities without EU-level protections, and legal enforcement may be limited.

8. Data retention

Data is deleted or anonymized afterward.

9. How we protect your data

We use:

• Encryption
• Restricted access
• Backups
• Firewalls and intrusion detection

However, we cannot guarantee GDPR-level protection.

10. Third-party links

We are not responsible for third-party privacy policies. Please review them separately.

11. Contact

For all data-related matters:
SAM GLOBAL DEVELOPMENT TRADING CO., LTD.
Email: support@spinyolo.com

No EU office or hotline is available.

12. Changes to this Privacy Policy

We may update this Policy. Significant changes will be communicated via the website or email. Continued use means acceptance.