Privacy Policy —
spinking44 Platform

spinking44 ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all users who access the spinking44 online casino and sports betting platform at spinking44.cam and any related digital services (collectively, the "Platform").

This Privacy Policy ("Policy") describes the types of personal data we collect from you ("User", "Player", "you"), the purposes for which that data is processed, the parties with whom it may be shared, the security measures we employ to protect it, and the rights you hold in relation to your personal data.

This Policy applies to all users of the Platform, including registered account holders, visitors browsing without an account, and individuals who contact our support team. It applies regardless of the device or method used to access the Platform — whether you are playing from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, or anywhere else.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference into this document.

For the purposes of this Privacy Policy, the following terms are defined as follows:

• "Personal Data" — Any information that identifies or can reasonably identify a natural person, directly or indirectly. Examples include full name, identification number, email address, phone number, IP address, and account activity data.
• "Data Controller" — spinking44, as the entity that determines the purposes and means by which your personal data is processed.
• "Data Processor" — A third-party entity that processes personal data on behalf of spinking44, subject to written data processing agreements and security obligations.
• "Processing" — Any operation performed on personal data, including collection, storage, retrieval, use, disclosure, transmission, alteration, erasure, or destruction.
• "KYC Data" — Identity and age verification documentation submitted by a Player as part of the Know Your Customer process, including but not limited to government-issued identification, proof of address, and source of funds information.
• "Cookies" — Small text files placed on your device by the Platform to facilitate functionality, session management, analytics, and personalisation. See Section 11 for full details.
• "Consent" — A freely given, specific, informed, and unambiguous indication by the User of their agreement to the processing of their personal data for a stated purpose.

spinking44 collects personal data that is necessary to provide you with our services and to meet our legal and regulatory obligations. The categories of personal data we collect include:

spinking44 collects personal data through the following channels and methods:

4.1 Direct Collection

Data you provide directly when you: register an account on the Platform; complete identity verification (KYC); make a deposit or withdrawal request; contact our support team via live chat or email; complete any form or survey on the Platform; or submit a formal complaint or request.

4.2 Automated Collection

Data collected automatically as you use the Platform, including your IP address, device identifiers, browser type, operating system, session timestamps, and interaction data. This collection occurs via cookies, web beacons, server logs, and similar tracking technologies described in Section 11.

4.3 Third-Party Sources

In limited circumstances, spinking44 may receive personal data about you from third parties, including: identity verification service providers used to complete KYC checks; payment processors and financial institutions processing your transactions; fraud detection and risk management service providers; and publicly available sources used for compliance screening purposes, such as sanctions and politically exposed persons (PEP) databases.

spinking44 processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your player account, including authentication, session management, and account preference settings.
• Service Delivery: To provide access to casino games, sports betting markets, live dealer tables, sports betting, and all other Platform features and content.
• Payment Processing: To process deposits via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency methods; and to process withdrawal requests to your registered payment accounts.
• Identity and Age Verification: To verify your identity and confirm you are aged 21 or above, as required by our licensing obligations and responsible gambling commitments.
• Regulatory Compliance: To meet anti-money laundering (AML), counter-terrorism financing (CTF), and other legal obligations, including transaction monitoring and suspicious activity reporting where required.
• Customer Support: To respond to your queries, investigate and resolve complaints, and maintain records of support interactions.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other malicious behaviour on the Platform.
• Platform Improvement: To analyse usage patterns and technical performance data to identify improvements, fix bugs, and develop new features that better serve Malaysian players.
• Responsible Gambling Monitoring: To identify potential problem gambling behaviours and, where appropriate, reach out proactively with support resources or implement player protection tools as described in our Responsible Gambling Policy.
• Marketing Communications: Where you have provided explicit consent, to send you information about promotions, new game launches, and other Platform updates. You may withdraw consent at any time via your account settings or by contacting support.

spinking44 processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform our contract with you — including account creation, payment processing, game delivery, and support services. Without this processing, we cannot provide the Platform services.
• Legal Obligation: Processing required to comply with applicable laws, including KYC and AML obligations, age verification requirements, tax reporting obligations, and responses to lawful regulatory or law enforcement requests.
• Legitimate Interests: Processing based on our legitimate business interests, where those interests do not override your fundamental rights. This includes fraud prevention, platform security, usage analytics, and internal quality assurance — balanced against your right to privacy.
• Consent: Processing based on your freely given, specific, and informed consent — primarily in relation to marketing communications and optional platform personalisation features. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

spinking44 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the following limited and necessary circumstances:

7.1 Service Providers

We engage trusted third-party vendors to assist in operating the Platform. These include payment processors (handling transactions via Touch 'n Go eWallet, FPX, DuitNow, and other Malaysian payment channels), identity verification providers, cloud infrastructure and hosting providers, cybersecurity and fraud detection firms, and customer support software vendors. All service providers are bound by written data processing agreements and are permitted to use your data only to perform services on our behalf.

7.2 Game Providers

Game content on spinking44 is supplied by certified third-party game providers. Limited technical data (such as session tokens and game play logs) may be shared with game providers to facilitate gameplay integrity and resolve technical disputes. These providers do not receive your full identity data.

7.3 Regulatory and Law Enforcement Authorities

spinking44 may disclose personal data to regulatory bodies, licensing authorities, law enforcement agencies, or courts where required to do so by law, court order, or in connection with regulatory investigation or compliance obligations. We will, where lawfully permitted, notify you of such disclosure.

7.4 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of spinking44's business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified in advance of any such transfer, and the acquiring party will be required to honour the terms of this Privacy Policy.

spinking44 operates as an international platform. As a result, your personal data may be transferred to and processed in countries outside of Malaysia. Where such transfers occur, spinking44 takes appropriate steps to ensure your data receives an equivalent level of protection to that applicable in Malaysia.

Safeguards for international transfers include: entering into data transfer agreements incorporating internationally recognised standard contractual clauses; ensuring recipient countries have adequate data protection frameworks recognised by relevant authorities; and applying supplementary technical and organisational measures where required.

spinking44 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required or permitted by applicable law. Our standard retention periods are as follows:

• Account Data and KYC Records: Retained for a minimum of five (5) years from account closure, in accordance with anti-money laundering regulatory requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Support and Communications Data: Retained for three (3) years from the date of the interaction, to support dispute resolution and quality assurance.
• Technical and Usage Data (anonymised): Retained indefinitely in aggregated, anonymised form for platform analytics and improvement purposes. Non-anonymised technical data is retained for up to twelve (12) months.
• Marketing Consent Records: Retained for the duration of marketing consent, plus two (2) years following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where deletion is not immediately possible due to technical constraints, the data is isolated and protected from further processing until deletion can be completed.

spinking44 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security programme includes:

• Encryption: All data transmitted between your device and the Platform is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest (including financial and KYC data) is encrypted using advanced encryption standards.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis. Employees with data access rights undergo regular security training and are subject to confidentiality obligations.
• Multi-Factor Authentication: Administrative systems require multi-factor authentication. Players are encouraged to enable two-factor authentication on their accounts for additional protection.
• Regular Security Testing: The Platform undergoes regular penetration testing, vulnerability assessments, and third-party security audits.
• Incident Response: spinking44 maintains a documented data breach response plan. In the event of a breach affecting your personal data, we will notify you and relevant authorities within the legally required timeframes and provide guidance on protective action.

While we employ comprehensive security measures, no system can guarantee absolute security. You are also responsible for maintaining the security of your account credentials. Please notify us immediately at [email protected] if you suspect any unauthorised access to your account.

spinking44 uses cookies and similar tracking technologies to enable Platform functionality, maintain user sessions, and understand how the Platform is used. The following types of cookies are employed:

• Strictly Necessary Cookies: Essential for Platform operation. These enable core functions such as logging in, maintaining your session, and processing transactions. They cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Collect anonymised information about how visitors interact with the Platform — including page visit counts, session duration, and error occurrences. This data is used to improve Platform performance and user experience.
• Functional Cookies: Remember your preferences and settings (such as language, currency display, and game layout preferences) to provide a more personalised experience on return visits.
• Security Cookies: Used to support our fraud detection and account security systems by identifying unusual session patterns or multiple login attempts.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the Platform. Disabling performance or functional cookies will not prevent access but may reduce the quality of your experience.

Subject to applicable data protection law and the limitations outlined below, you hold the following rights in relation to your personal data held by spinking44:

• Right of Access: You have the right to request a copy of the personal data spinking44 holds about you, along with information about how it is used and with whom it has been shared.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. For account details, many fields can be updated directly in your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where consent is withdrawn and no other legal basis applies. Note that regulatory retention obligations (Section 9) may limit our ability to fully honour erasure requests.
• Right to Restrict Processing: You may request that we temporarily stop processing your data in certain circumstances — for example, while the accuracy of your data is being contested.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests. You also have an absolute right to object to processing 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. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, contact our data protection team via the live chat on the Platform or by emailing [email protected] with the subject line "Data Rights Request — [Your Account Username]". We will acknowledge all requests within 5 business days and aim to resolve them within 30 days. Complex requests may take up to 90 days, in which case we will notify you of the extended timeline.

spinking44 is strictly for individuals aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21. Age verification is a mandatory component of our KYC process, and all Players are required to provide valid government-issued identification confirming they meet this age threshold before their account is fully activated.

If spinking44 discovers or has reasonable grounds to believe that personal data has been collected from a person under the age of 21, we will: (a) immediately suspend the relevant account; (b) delete or return any deposited funds; (c) permanently delete all personal data associated with the account; and (d) take appropriate steps to prevent future access.

Parents and guardians who have reason to believe a minor has registered on the Platform are urged to contact our support team immediately at [email protected]. We will investigate and act promptly.

spinking44 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, regulatory requirements, or Platform functionality. All updates will be published on this page, and the "last updated" date at the top of the Policy will be revised accordingly.

Where changes are material — meaning they substantially affect your rights or the manner in which we process your data — we will provide reasonable advance notice via a prominent notice on the Platform and, where practicable, by email to your registered address. Non-material changes (such as typographical corrections or clarifications that do not alter your rights) may be made without advance notice.

Continued use of the Platform after the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you disagree with any change, you should cease using the Platform and contact support to exercise your data rights as described in Section 12.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the spinking44 Data Protection team through the following channels. All privacy-related correspondence is handled by trained team members with data protection responsibility.

• 24/7 Live Chat: Available directly on the Platform. For privacy enquiries, use the subject "Data Protection" when initiating the chat. Average response time under 2 minutes.
• Email (plain text — not a clickable link): [email protected] — please use the subject line "Privacy Enquiry — [Your Account Username]" for fastest routing.

We acknowledge all privacy-related email requests within 5 business days and endeavour to resolve standard requests within 30 days. We are reachable from players in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, Bangsar, and all other regions across Malaysia.

spinking44 takes data protection matters seriously and is committed to resolving any concerns promptly and transparently. We encourage you to contact us in the first instance before escalating to any external authority.