Spin123 Privacy Policy – Personal Data Protection for Malaysia Users

Spin123 understands that privacy is more than a buzzword to drop into an official document. For most Malaysian users joining an online betting platform, privacy is a genuine concern that shapes your trust in and comfort with the platform. That is why we have written this Privacy Policy in clear, honest language.

This Privacy Policy applies to all services provided by spin123 through the spin123.best website, including Sports Betting, online casino, Virtual Sports, e-sports, and all other features available on the platform. It also applies to all communications we conduct with you via email, live chat, and other support channels.

We collect and process your personal data on the basis of legitimate necessity to operate spin123's services — including processing your account, verifying your identity, handling deposits and withdrawals via Touch 'n Go eWallet, GrabPay, DuitNow, and other Malaysian payment methods, and maintaining platform security for all members.

Spin123 collects various types of information from members depending on the stage of your interaction with the platform. Below is a complete list of the data categories we collect:

Spin123 only collects data that is strictly necessary for the stated purposes. We do not collect sensitive information such as your medical details, religious beliefs, or political views.

Spin123 collects your personal information through several different methods:

• Account Registration: When you register a spin123 account, you provide basic information such as your name, Malaysia phone number, and email address directly.
• Financial Transactions: Every time you make a deposit using Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, or FPX Maybank2u and CIMB Clicks, the transaction details are automatically recorded for accounting and security purposes.
• Platform Usage: Whether you're betting on EPL football or the Malaysia Super League, playing slots or Live Casino, or using any spin123 feature, your activity data is automatically recorded to maintain platform integrity.
• KYC Verification: In certain cases as required by spin123's operating procedures, we may request identity verification documents such as a copy of your identification card. This is standard industry practice to prevent fraud and money laundering.
• Support Communications: When you contact the spin123 support team via live chat or email, the information you provide during those interactions is retained for reference purposes and to help us improve our service.
• Cookies & Tracking Technologies: The spin123 platform uses cookies and similar technologies to enhance your experience and ensure the platform functions correctly. Further details are explained in Section 8.

Spin123 uses the personal data it collects for legitimate and specific purposes only. We do not use your data for any other purpose without obtaining your consent first.

The primary purposes for which spin123 uses your data are:

• Account Management: To create, verify, and manage your spin123 account, including login, two-factor authentication, and account settings.
• Transaction Processing: Processing deposits in MYR and withdrawals to your Malaysian e-wallet or bank account accurately and securely.
• Service Provision: Enables you to access and use all features of the spin123 platform, including Sports Betting, casino, Virtual Sports, and e-sports.
• Fraud Prevention: Detecting and preventing fraudulent activity, money laundering, account misuse, and other security threats that could affect you or other members.
• Legal Compliance: To fulfil applicable legal obligations in Malaysia, including compliance with the Anti-Money Laundering Act, PDPA, and related reporting requirements.
• Customer Support: Enables the spin123 support team to efficiently resolve inquiries, complaints, and disputes based on your account and transaction history.
• Personalise Your Experience: With your consent, we use activity data to suggest spin123 games or promotions that may be relevant based on your interests and habits.
• Platform Improvements: Analysing usage data in aggregate and anonymised form to understand how members use spin123 and to make meaningful improvements.

Spin123 does not sell, rent, or trade your personal data to third parties for their own marketing purposes – this is an absolute, unwavering commitment. That said, in the course of operating the platform, there are certain situations where data sharing is necessary:

• Payment Providers: Payment service providers such as Touch 'n Go, GrabPay, DuitNow, and FPX receive the transaction information required to process your deposits and withdrawals. They receive only the minimum data necessary and are subject to their own privacy policies.
• Game Providers: Companies such as Pragmatic Play, Evolution Gaming, and PG Soft receive the game session data needed to run games within the spin123 platform. No financial information or full identity details are shared.
• Technology Providers: Companies providing spin123's technical infrastructure (server hosting, cybersecurity services) may process your data as part of the services they deliver to us. All such companies are bound by strict confidentiality agreements.
• Legal Requirements: Spin123 may be required to disclose certain information to Malaysian authorities or regulatory bodies where mandated by a court order, warrant, or other lawful legal requirement.

In all of the above cases, we share only the minimum information necessary and always require the receiving party to protect that data to a standard equivalent to spin123's own.

Spin123 takes security infrastructure seriously to safeguard your personal and financial data. The following technical and organisational measures are continuously maintained:

• 256-bit SSL Encryption: All communications between your device and spin123's servers are encrypted using the latest TLS protocol. This ensures that data such as passwords, e-wallet account numbers, and betting records cannot be intercepted by unauthorised parties.
• Two-Factor Authentication (2FA): Spin123 offers two-factor authentication via OTP sent to your Malaysian mobile number, providing an additional layer of protection when you log in.
• Internal Access Controls: Only spin123 staff who require access to specific data to carry out their duties are permitted to access that data. A role-based access control system ensures that no staff member has broader access than their role requires.
• 24/7 Security Monitoring: An automated threat detection system monitors spin123's platform traffic and activity around the clock to identify intrusion attempts, unusual activity, or potential data breaches.
• Regular Penetration Testing: Spin123 conducts regular security testing by independent cybersecurity experts to identify and remediate vulnerabilities before they can be exploited.
• Funds Segregation: Member funds held in spin123 accounts are kept in accounts fully segregated from the company's operational funds, providing an additional layer of protection for your balance.

While we take all reasonable precautions, no security system can be guaranteed 100% safe against every threat. You also play an important role in keeping your spin123 account secure by using a strong password, not sharing your login credentials, and reporting any suspicious activity to us promptly.

Spin123 retains your personal data for as long as necessary to fulfil the purpose for which it was collected, or for as long as required under applicable Malaysian law — whichever is longer.

• Active Account Data: While your spin123 account is active, core data such as profile information, transaction records, and betting history is retained to allow you to access your account history and for support purposes.
• Financial Records: Financial transaction records, including deposits and withdrawals in MYR, are retained for a minimum of 7 years in compliance with Malaysia's accounting and anti-money laundering requirements.
• KYC Verification Data: Identity verification documents submitted for the KYC process are retained for 5 years from the date of submission or from the date of account closure, in accordance with applicable legal requirements.
• Technical Log Data: Access logs and technical data are typically retained for 12 months, after which they are automatically deleted or anonymised.
• After Account Closure: When your spin123 account is closed at your request, we will delete or anonymize your personal data within 30 days of the closure date, except for data that must be retained to fulfill legal obligations or resolve outstanding disputes.

Spin123 uses cookies and similar tracking technologies to enhance platform functionality and improve your experience. Cookies are small files stored on your device when you visit the spin123 website.

Types of cookies used by spin123:

• Session Cookies: Required to keep you logged in throughout your session on spin123. This cookie is automatically deleted when you close your web browser.
• Preference Cookies: Saves your preferences such as display language and other personal settings so you do not have to reconfigure them each time you visit spin123.
• Analytics Cookies: Collects information on how you use the spin123 platform — pages visited, time spent, and features used — to help us understand and improve the user experience. This data is collected in aggregate and does not identify you individually.
• Security Cookies: Used to detect and prevent fraudulent activity, and to ensure the security of your login session on spin123.

You can manage cookies through your web browser settings. However, disabling certain cookies may affect the functionality of the spin123 platform, particularly session cookies required for login and transactions.

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and recognised data protection principles, you as a spin123 member have the following rights regarding your personal data:

To exercise any of the rights above, contact the spin123 support team via live chat or email at support@spin123.best. State the right you wish to exercise along with the relevant details. We will process your request within 14 business days and inform you of the action taken.

The spin123 platform is exclusively for individuals aged 18 and above. Spin123 does not knowingly collect, store, or process any personal information from individuals under the age of 18.

If we become aware or receive information that personal data of a minor has been collected without valid parental or guardian consent, we will take the following steps immediately:

• Suspending the account immediately while an investigation is conducted.
• Permanently delete all personal data belonging to the underage individual from spin123's systems.
• Returning any funds held in the account in accordance with established procedures.

We encourage parents and guardians to use parental control software on all devices shared with children and teenagers under 18 to prevent unauthorized access to platforms such as spin123.

Spin123 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the technologies we use. Every amendment will include a clear effective date.

When significant changes are made to this Privacy Policy, spin123 will notify you through:

• A prominent notice within the spin123 platform when you log in
• An email notification sent to the address registered to your account
• Updating the "Last Updated" date at the top of this document

Continued use of the spin123 platform after any amendments to the Privacy Policy take effect will be considered acceptance of the revised terms. If you do not agree with the changes made, you have the right to close your account and request the deletion of your personal data by contacting the spin123 support team.

If you have any questions, concerns, or wish to exercise your privacy rights in relation to spin123's Privacy Policy, please contact us through the following channels:

• Live Chat: Available 24/7 within the spin123 platform – the fastest way to get an immediate response from our Bahasa Malaysia-speaking support team.
• Privacy Email: support@spin123.best – for requests related to data access, correction, deletion, or any other privacy concerns. Please include "Privacy Inquiry" in the subject line of your email.

The spin123 support team handling privacy inquiries will respond within 5 business days. We are committed to addressing every privacy concern seriously, transparently, and within a reasonable timeframe.