Privacy Policy

Last updated: 12 May 2026
Operator: INNOVATION AND TECHNOLOGY SERVICES LIMITED (Company number 04611805)
Registered Office: 1 Tilney Street, Aintree, Liverpool, Merseyside, L9 8DT

Policy Statement. Pacifica SpinHub (pacificaspinhub.com) is a free-to-play, browser-based portal that offers social gaming simulations and editorial content. The site is operated by INNOVATION AND TECHNOLOGY SERVICES LIMITED, a company registered in England and Wales. This Privacy Policy describes the categories of information we may collect when you visit the Service, how we use that information, who we share it with, how long we keep it, and the rights you have over it. We aim to comply with the UK GDPR and Data Protection Act 2018, and to apply equivalent standards to visitors from other jurisdictions wherever reasonable.

1. Information We Collect and Store

1.1 Personal Information You Disclose. The Service does not require account creation, registration, or any login mechanism. The only situation in which you actively share personal data with us is when you choose to contact our team — for example by sending an email to info@pacificaspinhub.com or by submitting our contact form. Information shared in this way may include your name, email address, and the content of your message. Please do not include sensitive information such as financial credentials or government identifiers in messages to us.

1.2 Information Automatically Collected. When you load a page on Pacifica SpinHub, our servers and the third-party services we use may automatically record limited technical information: IP address, approximate location derived from IP, device type, operating system, browser version, language preference, the page that referred you, the pages you viewed, and timestamps of interaction events within our games. Wherever possible this data is aggregated or pseudonymised.

1.3 Cookies, Analytics and Similar Technologies. Cookies and similar technologies are described in detail in our Cookie Policy. In short, we use them for security, language preferences, analytics, consent management, and (where you have agreed) advertising measurement. Sensitive categories of data are never used for advertising targeting or remarketing.

1.4 Anti-Abuse and Automated Traffic Controls. To protect the Service from spam, automated scraping, and denial-of-service attempts, we and our infrastructure providers may apply rate limits, CAPTCHA challenges, and similar fraud-prevention measures. These tools may collect minimal technical signals (such as IP reputation or browser fingerprint hashes) strictly for security purposes.

2. Use and Purpose of Your Information
We use the information described above for the following purposes:
- to deliver the Service and keep it available, secure, and performant;
- to reply to enquiries, support requests, and feedback you submit;
- to send administrative messages relating to changes in our policies or Service;
- to detect, prevent, and investigate fraud, abuse, or technical attacks;
- to analyse aggregated traffic patterns so we can improve the blog and games;
- where you have consented, to measure the effectiveness of advertising or partner campaigns;
- to comply with legal, regulatory, and audit obligations;
- to manage the overall quality of the Service.
We do not process personal data for account management, authentication, profiling, or payments because none of those features exist on the Service.

3. Disclosure of Collected Information
We disclose information only to the categories of recipients listed below, and only where it is necessary for one of the purposes set out above:
- Infrastructure providers — hosting, content delivery, security, and DNS partners.
- Analytics vendors — for aggregated traffic measurement.
- Advertising partners — only where you have consented, and only to measure campaign reach.
- Legal authorities — when we are required by law or formal legal process.
- Professional advisers — such as auditors and lawyers acting under confidentiality.
- Successors — in the event of a merger, acquisition, or reorganisation of INNOVATION AND TECHNOLOGY SERVICES LIMITED.
We do not sell personal information, and we do not rent it to data brokers. Service providers acting on our behalf are required to protect your data and to notify us of any security incident.

4. Use of Cookies and Tracking Tools
Strictly necessary cookies and similar tools support core functions of the Service and cannot be disabled without breaking the site. All other cookies (analytics, marketing measurement, optional preferences) are activated only with your consent through the on-page banner. Full detail is provided in our Cookie Policy.

5. Retention Period for Information
We retain personal data only as long as we have a clear operational or legal reason to do so. Specifically:
- contact-form and email correspondence is kept for as long as is reasonably necessary to handle your enquiry and any follow-up, typically up to 24 months;
- aggregated analytics data may be retained for up to 26 months for trend analysis;
- security and abuse-prevention logs are kept for the period necessary to detect, investigate, and respond to incidents;
- consent records are retained for the period required to demonstrate compliance with applicable law.
When data is no longer needed, we will securely delete it, anonymise it, or otherwise render it non-identifying.

6. Information Security Measures
We apply organisational and technical safeguards proportionate to the sensitivity of the data we handle. These include TLS encryption in transit, hardened hosting, role-based access controls, regular software updates, and incident-monitoring procedures. No method of electronic transmission or storage is completely secure, so while we strive to protect your data, we cannot guarantee absolute security. Where required by law, we will notify affected individuals and the relevant regulator of any qualifying data breach.

7. Collection of Data from Minors
The Service is intended exclusively for adults. We do not knowingly collect personal data from anyone under the age of 18 (or under the local legal age of majority, whichever is higher). If we become aware that we have collected personal data from a minor, we will delete or anonymise it without undue delay. If you believe that a minor has accessed the Service or provided us with personal data, please contact us at info@pacificaspinhub.com.

8. Your Data Rights and Choices

8.1 Privacy Rights. Subject to applicable law, you may have the right to access the personal data we hold about you, to request correction or deletion, to restrict or object to processing, to withdraw consent (where processing is based on consent), to receive a copy of your data in a portable format, and to lodge a complaint with a supervisory authority. In the UK, the relevant authority is the Information Commissioner's Office (ICO).

8.2 How to Exercise Rights. To make a rights request, email info@pacificaspinhub.com from the address you used to contact us. Please include enough detail for us to identify the relevant correspondence and explain what you would like us to do. We may need to ask for additional information to confirm your identity before fulfilling the request.

8.3 Response Timeline. We will respond to valid rights requests within the timeframe required by applicable law (typically one month under the UK GDPR), and we will explain any extension or refusal in writing.

9. Do-Not-Track Settings and Controls
At present there is no universal standard for "Do Not Track" browser signals, and the Service does not respond to such signals automatically. You can, however, control most non-essential processing through the cookie consent banner and through your browser's privacy settings.

10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top of the page indicates when the current version was published. Continued use of the Service after changes have been published constitutes acceptance of the revised policy. Material changes will be flagged on the homepage or in the consent banner.

11. Access, Update or Delete Data
You may ask us to access, correct, or delete the personal data we hold about you by contacting us at the address below. These rights are not absolute and may be limited where we have a legal obligation to retain information, where the request is manifestly unfounded, or where granting the request would adversely affect the rights of others.

12. Contact Details and Data Enquiries
For all enquiries about this Privacy Policy or the way your personal data is handled, please contact us:

• Company: INNOVATION AND TECHNOLOGY SERVICES LIMITED (Company number 04611805)
• Address: 1 Tilney Street, Aintree, Liverpool, Merseyside, L9 8DT
• E-mail: info@pacificaspinhub.com