Privacy Policy spin88 — Your Personal Data Protection

This Privacy Policy ("Policy") describes the privacy practices of Spin88 regarding the collection, use, disclosure, and protection of your personal information when you use our platform, website, mobile application, and related services (collectively referred to as the "Services"). By using Spin88 Services, you acknowledge that you have read and understood this Privacy Policy.

Spin88 collects your personal information through various means when you interact with our platform. We only collect information that is genuinely necessary to provide you with a quality and secure service.

1.1 Information You Provide Directly

• Registration Information: Full name, date of birth, gender, email address, mobile number, and the password you create.
• Identity Verification (KYC): Copies of national ID, passport, driving licence, or other valid identity documents; verification selfie and proof of address such as a utility bill or bank statement.
• Financial Information: Bank account details, e-wallet account numbers, deposit and withdrawal transaction history.
• Communications: Messages you send to our customer support team, complaints, feedback, and surveys you participate in.

1.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, screen resolution, and device type used.
• Usage Data: Pages you visit, time spent, games played, bets placed, and navigation patterns within the platform.
• Location Data: General geographic location based on your IP address for legal compliance and fraud detection purposes.
• Cookies & Tracking Technologies: Session cookies, persistent cookies, and tracking pixels that help us understand how you use our platform.

Every piece of data we collect has a clear and lawful purpose. Below is a full breakdown of how spin88 uses your personal information:

In accordance with Malaysia's Personal Data Protection Act 2010 (PDPA), spin88 processes your personal data on one or more of the following bases:

• Consent: You have given explicit consent for data processing for specific purposes, such as receiving marketing communications. You may withdraw this consent at any time.
• Contract: Processing is necessary to fulfil the service contract between you and spin88, including account management and transaction processing.
• Legal Obligation: spin88 is required by law to process certain data, such as KYC records for anti-money laundering (AML) purposes.
• Legitimate Interest: Processing is necessary for the legitimate interests of spin88 or a third party, such as fraud prevention and network security, provided those interests do not override your fundamental rights.

Spin88 does not sell, rent, or trade your personal data. However, in certain limited and lawful circumstances, we may share your information with the following parties:

4.1 Third-Party Service Providers

We share necessary data with service providers we use to operate our platform, including payment processors, identity verification providers, cloud service providers, and customer support providers. All such providers are bound by strict confidentiality agreements and are only permitted to use your data for purposes we specify.

4.2 Legal Compliance & Authorities

Spin88 will disclose your personal data to government authorities, regulators, or law enforcement when required by applicable law, court order, or valid legal process. We will inform you of any such request where we are permitted to do so.

4.3 Business Transfers

Should spin88 be involved in a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.

Spin88 implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction.

5.1 Technical Measures

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption of sensitive personal data in databases using AES-256 algorithm.
• Two-factor authentication (2FA) available for all player accounts.
• 24/7 security monitoring and active intrusion detection system (IDS).
• Regular security audits by accredited independent cybersecurity firms.
• Regular data backups with redundant storage across multiple locations.

5.2 Organisational Measures

• Access to personal data is restricted to staff who require it to perform their duties only (need-to-know principle).
• All staff handling personal data are bound by strict confidentiality agreements.
• Mandatory privacy and security awareness training for all staff.
• Documented and regularly tested security incident response procedures.

Spin88 uses cookies and similar tracking technologies to enhance your experience, understand how our platform is used, and deliver more relevant content to you.

6.1 Types of Cookies We Use

• Necessary Cookies: Required for core platform functions such as login authentication and session security. These cookies cannot be disabled.
• Performance Cookies: Collecting anonymous information about how visitors use our website to help us improve platform performance.
• Functional Cookies: Remembering your preferences such as language, currency, and display settings to provide a more personalized experience.
• Analytics Cookies: Used to understand platform usage patterns for internal service improvement purposes.

You can control and delete cookies through your browser settings. However, disabling certain cookies may affect the functionality of some parts of the Spin88 platform.

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and sound data protection principles, you have the following rights regarding personal data held by Spin88:

• Right of Access: You have the right to request a copy of the personal data we hold about you and to know how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data in certain circumstances, subject to our legal obligations to retain certain records.
• Right to Restrict Processing: You may request that we restrict the processing of your data in certain circumstances while a dispute is being resolved.
• Right to Data Portability: You have the right to receive your personal data in a machine-readable format for transfer to another service provider.
• Right to Object: You may object to the processing of your data for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the validity of prior processing.

The spin88 platform is exclusively for individuals aged 18 and above. We do not knowingly collect or process any personal data from individuals under 18. Should we discover that we have collected personal data from a minor without verified parental or guardian consent, we will take immediate steps to delete that information from our systems.

If you are a parent or guardian and believe your child has provided personal data to spin88, please contact us immediately so we can take appropriate action.

In the course of its operations, Spin88 may transfer your personal data to servers or service providers located outside Malaysia. When such transfers occur, Spin88 ensures that adequate safeguards are in place to protect your data, including:

• Use of approved standard contractual clauses requiring an equivalent level of protection.
• Transfers only to countries or regions with recognised data protection laws.
• Data protection impact assessments (DPIA) conducted prior to any new transfer.

Spin88 retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy or as required by applicable Malaysian law. Below are our data retention guidelines:

• Active Account Data: Retained for the duration your account remains active plus any period required by law.
• KYC & AML Records: Retained for at least 6 years after the business relationship ends, in line with anti-money laundering legal requirements.
• Transaction History: Retained for at least 7 years for audit and tax compliance purposes.
• Support Communication Log: Retained for 2 years after a ticket is closed for reference and service improvement.
• Marketing Data: Retained until you withdraw consent or request unsubscription.

Once the retention period expires, your data will be securely deleted or anonymised so that it can no longer be personally linked to you.

Spin88 reserves the right to amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological advancements. Any material amendments will be communicated to you via in-platform notification or email to your registered address at least 14 days before the changes take effect.

We encourage you to review this page regularly to stay informed of spin88's latest privacy practices. The most recent revision date is always displayed at the top of this page. Continued use of the spin88 platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

If you have any questions, concerns, or complaints regarding how spin88 handles your personal data, or to exercise any of your privacy rights, please contact our Data Protection Officer (DPO):

• Email: [email protected]
• General Support Email: [email protected]
• Response Time: Within 30 business days for personal data rights-related requests.

You also have the right to lodge a complaint with the Department of Personal Data Protection Malaysia if you believe your privacy rights have been violated and we have failed to address your concerns satisfactorily.