Privacy Policy — spingo88 Platform

spingo88 ("Company", "we", "us", "our") operates the online gaming platform accessible at https://spingo88.cam ("Platform"). We are committed to protecting the personal data of all individuals who interact with the Platform, including registered account holders and visitors.

This Privacy Policy ("Policy") has been prepared in accordance with applicable data protection legislation, including the Personal Data Protection Act 2010 (Malaysia) ("PDPA") and other relevant international data privacy frameworks. It describes:

• The categories of personal data we collect and the methods by which we collect it;
• The purposes for which your personal data is processed and the legal basis for each purpose;
• The circumstances under which your personal data may be shared with third parties;
• How long we retain your personal data;
• The security measures we apply to safeguard your data;
• Your rights in relation to your personal data and how to exercise them.

For the purposes of this Privacy Policy, the following terms have the meanings assigned below:

• "Controller" means the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, the Controller is spingo88.
• "Data Subject" means any identified or identifiable natural person whose personal data is processed by spingo88 — this includes you, as a registered user or visitor to the Platform.
• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial data, device identifiers, and behavioural data, whether collected individually or in combination.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, transfer, erasure, or destruction.
• "Processor" means a third party that processes personal data on behalf of spingo88 in accordance with our instructions and this Policy.
• "Sensitive Personal Data" means personal data pertaining to health, financial account information, identification documents, and other categories requiring heightened protection under applicable law.
• "Third Party" means any person or entity other than the Data Subject and spingo88 that has been authorised to receive or process personal data in accordance with this Policy.

spingo88 collects personal data through the following channels: account registration, KYC verification, payment transactions, Platform usage, customer support interactions, and marketing communications. The categories of personal data we collect include:

spingo88 processes your personal data for the following purposes:

1. Account Administration: To create and manage your Account, verify your identity, process KYC documentation, and maintain accurate account records.
2. Service Delivery: To provide access to the Platform's games, sports betting markets, live dealer tables, and all associated features; to process deposits and withdrawals via approved Malaysian payment methods including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect.
3. Customer Support: To respond to enquiries, resolve disputes, and provide technical assistance through our 24/7 live chat and email support channels.
4. Regulatory Compliance: To fulfil obligations under applicable anti-money laundering (AML), counter-financing of terrorism (CFT), and responsible gambling regulations, including age verification, transaction monitoring, and mandatory reporting.
5. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised access, and other security threats to the Platform and its users.
6. Responsible Gambling: To monitor gaming behaviour for indicators of problem gambling, administer self-exclusion arrangements, enforce deposit and session limits, and facilitate cooling-off periods requested by users.
7. Marketing Communications: To send promotional offers, bonus notifications, and platform updates to users who have opted in to receive such communications. You may opt out at any time.
8. Platform Improvement: To analyse usage patterns, conduct performance testing, and improve the functionality, security, and user experience of the Platform.
9. Legal and Dispute Resolution: To enforce our Terms and Conditions, defend legal claims, and comply with lawful requests from regulatory or law enforcement authorities.

Where applicable data protection law requires us to identify a legal basis for each processing activity, we rely on the following:

• Contractual Necessity: Processing required to perform our contract with you, including account management, service delivery, and payment processing.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including AML/CFT requirements, age verification mandates, and responsible gambling regulations.
• Legitimate Interests: Processing conducted for purposes of fraud prevention, platform security, improving our services, and enforcing our terms — where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit, freely given, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

spingo88 does not sell your personal data to any third party. We may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment Service Providers: Malaysian payment processors and financial institutions necessary to execute deposit and withdrawal transactions, including providers supporting Touch 'n Go eWallet, DuitNow, FPX, Maybank2u, CIMB, and other approved methods. These providers receive only the data strictly necessary to process your transaction.
• Identity Verification Services: Third-party KYC and identity verification providers engaged to perform document authentication and age verification in accordance with our regulatory obligations.
• Game Technology Providers: Licensed gaming software providers who power specific games or sports betting markets on the Platform. These providers may receive limited usage data necessary to deliver the relevant game or service.
• Regulatory and Law Enforcement Authorities: Government agencies, regulatory bodies, and law enforcement authorities, where disclosure is required by applicable law, court order, or regulatory directive.
• Professional Advisers: Lawyers, auditors, accountants, and other professional advisers, subject to applicable professional confidentiality obligations, where disclosure is necessary for the provision of their services to spingo88.
• Fraud Prevention Networks: Shared fraud prevention databases and networks where we are permitted or required to share data relating to suspected fraudulent activity.

All third-party data processors are required to process your personal data in accordance with our instructions, this Policy, and applicable data protection law. We do not permit third parties to use your personal data for their own independent purposes without your explicit consent.

spingo88 uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device that allow us to recognise your browser and remember certain information about your visit.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cookies cannot be disabled without significantly impairing Platform functionality.
• Functional Cookies: Enable the Platform to remember your preferences, such as language settings, game display preferences, and Account settings, to provide a personalised experience.
• Analytics Cookies: Collect aggregated, anonymised data about how users interact with the Platform, enabling us to identify usability issues and improve performance. Analytics data is not used to identify individual users.
• Marketing and Targeting Cookies: Used to deliver relevant promotional content and measure the effectiveness of marketing campaigns, subject to your prior consent.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Where consent is required for non-essential cookies, we will request it through an in-Platform consent mechanism.

spingo88 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulatory obligation.

General retention periods applied by spingo88 are as follows:

• Account Data: Retained for the duration of your Account and for a period of five (5) years following account closure, in accordance with AML/CFT record-keeping obligations.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification, or longer where required by applicable law.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer Support Records: Retained for three (3) years from the date of the most recent support interaction.
• Marketing Data: Retained until you withdraw consent or request erasure, subject to suppression list requirements.
• Technical and Usage Data: Retained for up to twelve (12) months in identifiable form, after which it is aggregated and anonymised.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that renders it incapable of identifying any individual.

spingo88 implements technical and organisational measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption at rest for all stored personal data and financial information;
• Access controls restricting Platform system access to authorised personnel on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Firewalls, intrusion detection systems, and continuous network monitoring;
• Staff training on data protection obligations and security awareness.

While we apply robust security measures, no data transmission over the internet or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your Account credentials and for reporting any suspected unauthorised access to spingo88 immediately.

Subject to applicable data protection law, you have the following rights in relation to the personal data spingo88 holds about you:

1. Right of Access: You have the right to request a copy of the personal data we hold about you, together with information about how it is processed. We will respond to verified access requests within 30 days.
2. Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. You may update some information directly within your Account settings; other corrections may be requested by contacting our support team.
3. Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may request deletion of your personal data. This right is subject to exceptions, including where retention is required for legal, regulatory, or legitimate business purposes.
4. Right to Restrict Processing: You may request that we restrict our processing of your personal data in certain circumstances, for example while the accuracy of data is contested or while an objection is under consideration.
5. Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, and machine-readable format.
6. Right to Object: You have the right to object to processing based on our legitimate interests, including profiling. You also have an unconditional right to opt out of direct marketing communications at any time.
7. Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing undertaken prior to withdrawal.

To exercise any of the above rights, please contact our Data Protection team at [email protected] with the subject line "Data Subject Request". We will verify your identity before processing any request and will respond within 30 days of receipt.

spingo88 may transfer your personal data to countries outside of Malaysia in the course of operating the Platform, including transfers to service providers, game technology partners, and cloud infrastructure providers located in other jurisdictions.

Where personal data is transferred internationally, spingo88 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under applicable Malaysian data protection law. Such safeguards may include:

• Transfers to countries with an adequate level of data protection as determined by applicable regulatory authorities;
• Data processing agreements incorporating standard contractual clauses or equivalent transfer mechanisms;
• Binding corporate rules applicable to transfers within the spingo88 corporate group.

You may request further information about international transfer safeguards by contacting us using the details in Section 14 of this Policy.

The Platform is strictly restricted to individuals aged 21 years and above. spingo88 does not knowingly collect or process personal data from any individual under the age of 21. Age is verified during the registration process and as part of KYC procedures.

If we become aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated Account.

If you believe that a minor has registered on the Platform or that we have inadvertently collected data from a minor, please contact us immediately at [email protected] so that we can take prompt corrective action.

spingo88 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, we will notify registered users by email or by prominently displaying a notice on the Platform at least seven (7) days before the updated Policy takes effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed of how we protect your personal data. Continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by spingo88, please contact our team through the following channels:

• Data Protection Enquiries: [email protected] — please include "Privacy / Data Protection" in the subject line
• Live Chat: Available 24/7 via the Platform — our support team will escalate data protection queries to the appropriate team
• Response Time: We aim to acknowledge all data protection requests within 3 business days and provide a full response within 30 days

For data subject rights requests (access, erasure, portability, etc.), please submit your request by email with sufficient detail to enable us to identify your Account and the nature of your request. We will verify your identity before processing the request.