Spree Privacy Policy

1 About This Policy

This Privacy Policy applies to all services offered by Spree through the website spree.vu and the Spree mobile application. It covers every interaction you have with our platform — from creating your account and making a PKR deposit through to placing a bet, claiming a bonus, or contacting our support team.

We are the data controller for the personal information you provide to us. That means we decide how and why your data is used. Where we engage third-party processors — such as payment providers — they act strictly on our instructions and under written data processing agreements.

This policy should be read alongside our Terms and Conditions, which govern the overall use of the Spree platform. If anything in this policy is unclear, you're welcome to contact our support team for a plain-language explanation before proceeding.

2 Data We Collect

We collect personal data in three main ways: information you give us directly, information generated by your use of the platform, and information we receive from third parties such as payment processors.

Information you provide directly:

• Full name and date of birth
• Email address and mobile number
• CNIC or other government-issued identity document (for verification)
• Residential address
• Payment method details (account numbers for JazzCash, Easypaisa, Raast, or bank account details — not card numbers, which are handled by our payment partners)
• Communications you send to us via support chat or email

Information generated automatically:

• IP address and approximate location derived from it
• Device type, operating system, and browser type
• Session duration and pages visited within the platform
• Betting and gaming activity — markets accessed, bets placed, results, stakes, and winnings
• Deposit and withdrawal transaction records
• Login times and account activity logs

Information from third parties:

• Identity verification results from our KYC (Know Your Customer) provider
• Payment confirmation and status data from JazzCash, Easypaisa, Raast, and banking partners
• Fraud and risk signals from our fraud prevention partners

3 How We Use Your Data

The data we collect is used for specific, legitimate purposes. The table below sets out the main uses and the reason we process that data for each purpose.

We do not use your data for automated decision-making that produces significant legal effects on you without human review. If any such processing is ever introduced, we will update this policy and notify you.

4 Legal Basis for Processing

Every time Spree processes your personal data, we do so on one of the following legal grounds:

• Contract performance: Processing your account details, deposits, withdrawals, and betting activity is necessary to deliver the service you've signed up for.
• Legal obligation: Identity verification and transaction record-keeping are required to comply with anti-money laundering and financial crime prevention obligations.
• Legitimate interests: Platform security, fraud prevention, and responsible gaming monitoring are carried out in the legitimate interest of keeping the platform safe for all users.
• Consent: Marketing communications are sent only where you have actively opted in. You can withdraw consent at any time by updating your account notification preferences or contacting support.

5 Sharing Your Data

Spree does not sell, rent, or trade your personal data to any third party for their own marketing purposes. We share data only where it is necessary to operate the platform or comply with legal requirements. The categories of recipients are as follows:

• Payment processors: JazzCash, Easypaisa, Raast, bank partners, and card processors receive the transaction details required to process your PKR deposits and withdrawals. They are independently regulated and operate under their own privacy frameworks.
• Identity verification providers: Our KYC partner receives the identity documents you submit for verification purposes. Data is processed solely for verification and is not used for any other purpose by the provider.
• Fraud prevention services: Risk signals, IP addresses, and behavioural data may be shared with fraud detection partners to protect accounts and the integrity of the platform.
• Responsible gaming providers: Where self-exclusion is requested, relevant account information may be shared with responsible gaming systems to enforce exclusion effectively.
• Legal and regulatory authorities: We may disclose account and transaction data to relevant authorities when required to do so by law, court order, or financial crime investigation requirements.
• Technology infrastructure providers: Hosting, cloud storage, and platform delivery partners may process data as part of operating the technical infrastructure. All such providers are bound by strict data processing agreements.

6 Cookies and Tracking

Spree uses cookies and similar tracking technologies on the platform website and mobile application. Cookies are small text files stored on your device that help us deliver a better, more personalised experience.

We use the following categories of cookies:

• Essential cookies: Required for the platform to function. These keep you logged in, maintain your session across pages, and remember your security preferences. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language, odds format, and preferred betting markets so you don't have to reconfigure them on every visit.
• Analytics cookies: Help us understand how the platform is being used — which pages are visited most, where users drop off, and how features are performing. This data is aggregated and does not identify individual users.
• Security cookies: Used to detect suspicious login patterns, CSRF protection, and session integrity checks.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Spree platform — for example, you may be required to log in again on every visit if session cookies are blocked.

7 Data Retention

We retain your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal and financial compliance obligations. The general retention periods we apply are as follows:

• Active accounts: All account and transaction data is retained for as long as your account remains active on the platform.
• Closed accounts: Following account closure, core account and transaction records are retained for a minimum of five years to satisfy anti-money laundering and financial record-keeping requirements.
• Identity verification documents: Retained for the duration of the account relationship and for five years after closure.
• Support communications: Chat logs and email correspondence are retained for three years from the date of the interaction.
• Marketing data: Where you have opted in to marketing, your contact preferences are retained until you withdraw consent. Once consent is withdrawn, your details are removed from active marketing lists within 30 days.

When data is no longer required, it is securely deleted or anonymised so that it can no longer be linked to you as an individual.

8 Security

Spree takes the security of your personal data seriously. We have implemented a range of technical and organisational measures to protect your information against unauthorised access, loss, destruction, or disclosure.

• Encryption in transit: All data transmitted between your device and Spree servers is encrypted using TLS (Transport Layer Security).
• Encryption at rest: Sensitive data stored on Spree infrastructure is encrypted at the database level.
• Access controls: Only authorised staff with a legitimate operational need can access personal data, and all such access is logged and audited.
• Payment security: Payment credentials are processed exclusively by our certified payment partners. Spree never stores full card numbers, mobile wallet PINs, or bank account passwords.
• Regular security reviews: Our platform undergoes periodic security assessments to identify and address vulnerabilities.

Despite these measures, no internet-based platform can guarantee absolute security. We encourage you to use a strong, unique password for your Spree account and to enable any available account security features. If you suspect your account has been compromised, contact our support team immediately.

9 Your Rights

You have a number of rights in relation to the personal data we hold about you. These are set out below. To exercise any of these rights, contact our support team with your request — we aim to respond within 30 days.

We will not charge a fee for handling rights requests in most cases. We may ask you to verify your identity before processing a request to ensure we are releasing data to the correct person.

10 Children and Minors

The Spree platform is strictly for adults aged 18 and above. We do not knowingly collect personal data from anyone under 18 years of age. If you are a parent or guardian and believe that a minor in your household has created a Spree account or submitted personal data to the platform, please contact our support team immediately.

Upon receiving a verified report of underage access, we will close the account and securely delete any associated personal data without delay. We also encourage parents and guardians to use device-level parental controls and content filtering tools to prevent minors from accessing online gaming and betting platforms.

11 Changes to This Policy

Spree may update this Privacy Policy from time to time to reflect changes in the platform, our data practices, or applicable legal requirements. When we make changes, the "Last Updated" date at the top of this page will be revised.

For significant changes that materially affect how your data is used, we will send a notification to your registered email address at least 14 days before the changes take effect. Your continued use of the platform after the effective date of any update constitutes acceptance of the revised policy.

We recommend reviewing this page periodically. If you disagree with any update, you may close your account by contacting our support team before the effective date.

12 Contact Us

If you have any questions about this Privacy Policy, want to exercise your data rights, or wish to raise a concern about how your personal information is being handled, please reach out to our team:

• Live chat: Available 24/7 via the platform. VIP Silver accounts and above receive priority response.
• Email: [email protected] — we aim to respond to privacy-related queries within 5 business days.
• FAQ: Visit our FAQ page for answers to common questions about accounts and data.

For data rights requests specifically, please state clearly in your message which right you wish to exercise and include the email address registered to your account. We will acknowledge receipt within 48 hours and complete the request within 30 days.