Privacy Policy



Two7 Two9

Privacy Policy of SpinTheGame

Effective date: August 23, 2018

Two7 Two9 (“us”, “we”, or “our”) operates the website and the SpinTheGame mobile application (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service but also for the Service to be able to get in touch with you for the collection and delivery of your free wins, gifts, and samples.

By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). The data you share also allows us to provide you with gifts, discounts and promotional material that you will find relevant based on your selected category criteria and interests.  Personally, identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data
  • Basic Demographic Data
Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

Two7 Two9 uses the collected data for various purposes:

  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To allow us to select you specific gifts, discounts and other promotional items based on your selected preferences and are relevant to you.
  • To allow us to deliver to you directly the free gifts, wins and samples
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues

Transfer Of Data

Two7 Two9 will take all steps reasonably necessary to ensure that your data is treated securely, in all confidentiality and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data
Legal Requirements

Two7 Two9 may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Two7 Two9
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Service Providers to monitor and analyze the use of our Service. Our personal data will be used in all confidentiality and will never be shared or sold to third parties.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

SpinTheGame: Rules & Regulations

The following terms stipulate the rules and regulations for participation your participation on SpinTheGame mobile application and platforms.

  1. SpinTheGame is a free to download and free to play mobile game application.
  2. Upon account creation you will be prompted to select the categories that interest you. This service is not available for anyone under the age of 18 years old.
  3. Your account will be credited with 3 Spins as a welcome gift when you create an account.
  4. Once your Spins are depleted, one new Spin will be credited to your account every day at midnight. The counter on the wheel will indicate when your next Spin will be credited to your account.
  5. You can use your Spins to spin the wheel for the chance to win product samples, store discounts and other freebies from our partner brands.
  6. Not every Spin is guaranteed to generate a win.  You may win points which you can collect on SpinTheGame and use these points to grow in levels within the game.
  7. You can collect points by answering questions, giving your feedback on products or updating your profile information.
  8. Points collected on SpinTheGame can only be used to redeem and unlock an extra Spin on the SpinTheGame application.  They cannot be cashed, transferred or reimbursed and hold no value outside of the game.
  9. Your points balance is visible on your profile slide.  Once you collect 1,000 points you can redeem them on SpinTheGame to unlock an additional Spin.
  10. Any product, sample, discount or freebie won by the player cannot be transferred or resold. Please refer to our FAQ and T&C.
  11. The Wheel will return wins based on the preferences you have selected and the information you choose to share in your profile section.
  12. SpinTheGame will not ask for your credit card information or any other form of payment and we never will.
  13. You will be prompted once a month to collect the freebies that you may have won from our partner brands by redeeming your basket.
  14. Once your basket has been redeemed, any freebies you have won will be prepared and delivered to the location you specify.
  15. Distribution of the free wins happen during the first week of each month. Please refer to T&C.
  16. Upon selecting to accept a free win, you will be prompted to answer questions that will seek your opinion or preferences between certain products and services offered through our partner brands.
  17. SpinTheGame is not a gambling, lottery or betting platform.   Any free products or services won through the application are solely intended for the winner and are not valid for resale or transfer.
  18. Apple Inc. nor any of its affiliates are a sponsor of SpinTheGame.  Apple Inc. holds no responsibility nor accountability.
  19. SpinTheGame is owned and managed by Two7 Two9 SARL.  For any queries please contact us at and we will get back to you within 24Hours.
  20. Apple Inc. is not a sponsor of or a participant of SpinTheGame or Two7 Two9 SARL.

Transfer of Data/consent and approval.

If you are located outside Lebanon and choose to provide information to us, please note that we transfer the data, including Personal Data, to Lebanon and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us: