Privacy Policy Spinner77 — How We Protect the Personal Data of Malaysian Players

1.1 Data You Provide Directly

When you register and use the Spinner77 platform, you provide us with certain information directly. This includes:

• Identity Information: Full name, identity card number (MyKad), date of birth, and gender — required for the identity verification (KYC) process
• Contact Information: Malaysian phone number, email address, and residential address
• Account Information: Username, encrypted password and security questions
• Verification Documents: Copy of identity card or passport, proof of address — only requested when necessary to meet KYC requirements
• Payment Information: Details of the payment method you use (Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX, Maybank2u, CIMB Clicks) — processed through a secure payment gateway

1.2 Automatically Collected Data

When you use the Spinner77 platform, our systems automatically collect certain technical information required for platform operations. This includes:

• IP address and general location data (state/city) for Malaysian geography verification
• The type of device, operating system, and web browser version you are using
• Session data including login time, pages visited and session duration
• Gaming activity records — games played, bets placed, wins and losses
• Financial transaction records including all deposits and withdrawals
• Cookie information and similar tracking technology data (see Section 5)

Spinner77 uses collected data for specific, legitimate purposes. We do not use your data for any purpose not stated here without first obtaining your consent:

2.1 Platform Operations

• Verifying your identity during registration and when logging in to spinner77
• Processing deposits and withdrawals via your chosen Malaysian payment method
• Managing your account, including balance, transaction history and game records
• Providing effective customer support whenever you need assistance
• Sending important account notifications such as deposit confirmations, withdrawal updates and security alerts

2.2 Security & Fraud Prevention

• Detecting and preventing unauthorised access to your account
• Identifying and investigating potentially suspicious or fraudulent activity
• Complying with Malaysia's Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements
• Ensuring every account is held by an individual who meets the required age and location criteria

2.3 Service Improvement

• Analysing usage patterns in aggregate (not at an individual level) to improve the spinner77 platform
• Understanding the types of games and features most popular among Malaysian players
• Resolving technical issues and improving platform performance

2.4 Marketing Communications (With Consent)

Spinner77 will only send you marketing communications — such as promotional information, bonuses, and special events — if you have given your consent to receive them during registration or through your account settings. You may withdraw this consent at any time via the notification settings in your Spinner77 account.

Spinner77 does not sell, rent, or share player personal data for third-party marketing purposes. However, there are limited circumstances in which data may be shared with specific parties:

3.1 Trusted Service Providers

Spinner77 works with selected third-party service providers to operate the platform. These include payment gateway providers (such as FPX, Touch 'n Go, and others), identity verification service providers, and server infrastructure providers, all of whom are bound by strict data protection agreements and may only use your data as directed by Spinner77. They are not permitted to use your data for any other purpose.

3.2 Legal Requirements

Spinner77 will disclose personal data to Malaysian authorities — including the Royal Malaysia Police, Bank Negara Malaysia or relevant regulatory bodies — when required by law, court order or in connection with investigations into criminal activity such as money laundering. In such cases, we will disclose only the minimum data necessary and will notify you if legally permitted to do so.

3.3 Business Transfers

Should spinner77 be involved in a merger, acquisition or asset sale, players' personal data may form part of the transferred assets. In such cases, players will be notified in advance and the applicable new privacy policy will be clearly communicated.

4.1 Technical Security Measures

Spinner77 implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers
• Encryption of data at rest for sensitive information stored in our databases
• Two-factor authentication (2FA) available for all Spinner77 player accounts
• Role-based access controls ensure that only staff who genuinely need it can access specific data
• Regular security audits conducted by accredited independent third parties
• An intrusion detection system (IDS) that continuously monitors network traffic
• 24/7 monitoring by the Spinner77 cybersecurity team

4.2 Data Retention Period

Spinner77 retains your personal data for as long as necessary to fulfil the purposes stated in this privacy policy, or as required by Malaysian law. Generally speaking:

• Active account data is retained for as long as your account remains active with Spinner77
• Financial transaction records are retained for 7 years for Malaysian financial law compliance purposes
• KYC documents are retained for 5 years after account closure
• Security log data is retained for 2 years
• Aggregated analytics data (with no personal information) may be retained longer for platform improvement purposes

4.3 Security Incident Response

In the event of a security incident involving player data, Spinner77 has a clear incident response procedure in place. We will assess the scope and impact of the incident within 72 hours, implement immediate containment measures, and notify affected players and relevant authorities as required by applicable law. Transparency is our priority in such situations.

The Spinner77 platform uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions correctly. The following are the types of cookies we use:

You can manage cookie settings through your web browser. However, disabling essential cookies will affect the functionality of the Spinner77 platform. For guidance on managing cookies in your browser, please refer to your browser's help documentation.

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and Spinner77's privacy policy, you have the following rights regarding your personal data:

Spinner77 will respond to all data rights requests within 30 days of receipt. In more complex cases, this period may be extended to 60 days with reasonable notice to you. Spinner77 does not charge a fee to exercise these rights under normal circumstances.

7.1 Payment Information Processing

When you make a deposit using Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX, Maybank2u or CIMB Clicks, your transaction is processed through a licensed and approved payment gateway in Malaysia. Spinner77 does not store credit/debit card numbers directly in our systems — sensitive card information is handled by a PCI-DSS compliant payment gateway.

7.2 Transaction Records

Spinner77 maintains a complete record of all financial transactions on your account — including all deposits, withdrawals, bets and winnings — for a period of 7 years. This is a legal requirement in Malaysia relating to financial records and AML compliance. These records are accessible to you via the transaction history in your Spinner77 account.

7.3 Reporting to Authorities

Under Malaysian legal requirements, spinner77 may be obligated to report certain transactions to the relevant authorities. This includes transactions exceeding specified thresholds or those deemed suspicious from an anti-money laundering perspective. Such reporting is a legal obligation and not a choice made by spinner77.

7.4 Your Financial Account Security

To protect your financial account, Spinner77 applies multiple layers of financial security: email or SMS verification for every withdrawal, daily withdrawal limits that you can set yourself, instant notifications for every transaction, and automated monitoring to detect unusual transaction patterns. If we detect any suspicious activity on your account, we will proactively reach out to you before taking any action.

The Spinner77 platform is restricted to individuals aged 21 and above. We do not knowingly collect or process personal data from individuals under the age of 21. Spinner77 employs several mechanisms to verify player age, including MyKad verification during the KYC process and age checks at registration.

If you believe your child or any underage individual has registered on Spinner77 or that their data has been inadvertently collected by us, please contact us immediately at support@spinner77.biz with full details. Spinner77 will take prompt action to investigate, close the relevant account, and delete the associated data if it is confirmed to belong to a minor. This is an absolute priority for us and we take it very seriously.

Spinner77 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements or technological developments. When we make significant changes, we will:

• Updating the "Last Updated" date at the top of this page
• Notifying all registered players by email at least 14 days before any changes take effect
• Displaying a clear notice on the Spinner77 platform regarding upcoming changes
• For significantly material changes that affect your fundamental rights, we will seek your renewed consent before proceeding

Continued use of the Spinner77 platform after the effective date of any changes will be considered acceptance of the updated privacy policy. If you do not agree with the changes, you have the right to close your account and request deletion of your data in accordance with the procedure set out in Section 6.

We recommend reviewing this Privacy Policy page periodically to stay informed about how spinner77 manages your personal data. All previous versions of the spinner77 Privacy Policy are available upon request by emailing our team, should you need them for reference purposes.

If you have any questions, concerns or requests relating to this Privacy Policy or how Spinner77 handles your personal data, please reach out to us through the following channels:

Spinner77 is committed to responding to all privacy-related enquiries within 3 business days. For more formal data rights requests such as access, rectification or deletion, processing may take up to 30 days. We will keep you informed of your request status throughout the process.