From the desk of The Spin Insider
Privacy Policy
This page explains what personal data The Spin Insider collects, why we collect it, who we share it with, and how to exercise your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1 · Who we are
The Spin Insider is published by Apollo Solution Inc., a company registered in the British Virgin Islands. For UK data protection purposes our representative is reachable at [email protected].
2 · What we collect
We process the following categories of personal data:
- Email address — only if you subscribe to our nightly pick newsletter, and only with your double opt-in confirmation
- Click data — when you tap a Visit Site button, we record the operator brand, the timestamp, and an opaque short hash that identifies your subscriber record (never your email address itself)
- Approximate location — derived from your IP address by our analytics provider, stored at country/city granularity only
- Device and browser metadata — type, version, viewport size, referrer URL — used for site analytics and bug-fixing
We do not collect any payment, financial, or identity-document data. We do not request or store your name, address, date of birth, or telephone number.
3 · How we use it
We use the data above to:
- Send you a single email per day at 8pm (UK time) with our nightly operator pick — only if you opted in
- Measure which operators our readers find most relevant, so we can refine our editorial rankings
- Improve the page itself: spot bugs, optimise loading speed, fix broken links
- Pay our affiliate partners and account for revenue (the operator's payment to us, if any)
4 · Legal basis
We rely on the following lawful bases under UK GDPR Article 6:
- Consent (Art.6(1)(a)) — for the email newsletter, processed only after you double-opt-in
- Legitimate interests (Art.6(1)(f)) — for click-tracking, anonymised analytics, and bug-fixing, balanced against your reasonable expectations
You have the right to object to processing on the legitimate-interests basis at any time — see Your rights below.
5 · Cookies and similar technologies
The Spin Insider uses three categories of cookies:
- Strictly necessary — remembers your cookie preferences. Always set, no consent required.
- Analytics — PostHog, set only after your explicit consent. Used to measure page views, click-through rates, and bounce. Anonymous by default.
- Affiliate attribution — when you click a Visit Site button, our redirect host (r.rtrly.com) sets a short-lived attribution cookie on the operator's domain. This is how operators credit our editorial recommendation if you sign up.
You can decline analytics cookies via the banner at the bottom of any page, change your mind at any time, and delete all cookies via your browser settings.
6 · Who we share data with
The Spin Insider does not sell, rent, or trade personal data. We share narrowly with:
- Brevo (our email service provider, Paris) — to deliver newsletter emails. Brevo processes data on our behalf under a Data Processing Addendum compliant with UK GDPR.
- Cloudflare (our hosting and CDN provider, USA with EEA data centres) — serves the page itself. Cloudflare does not access the contents of your interactions.
- PostHog (our analytics provider, EU-hosted) — only after consent. Anonymised event data only.
- Operators — only the opaque attribution token is passed when you click their Visit Site button. They never receive your email address from us.
We may also disclose data where required by UK law or to protect our or others' rights.
7 · Data retention
- Newsletter subscribers — retained until you unsubscribe, plus 30 days for processing the unsubscribe request
- Click-tracking events — 24 months, then aggregated and anonymised
- Analytics data — 12 months in identifiable form, then aggregated
8 · Your rights
Under UK GDPR you have the right to:
- Access your personal data
- Rectification of inaccurate data
- Erasure ("right to be forgotten")
- Restriction of processing
- Data portability
- Object to processing under legitimate interests
- Withdraw consent at any time (including a single click via the unsubscribe link in any email)
To exercise any of these rights, email [email protected]. We respond within 30 days.
9 · Complaints
If you believe we have mishandled your data, you can complain to the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
10 · Changes to this policy
We will update this page if our practices change. The "Last updated" date at the top reflects the most recent revision. Substantive changes will be flagged via the cookie banner and in the next nightly newsletter.