spinngo Privacy Policy

1. Who We Are (Data Controller)

1.1 spinngo is the data controller in respect of personal data collected through the spinngo platform. As data controller, spinngo determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is lawful, fair, and transparent.

1.2 For all data protection enquiries or to exercise your rights under this Policy, please contact our Data Protection team at [email protected], marking your correspondence "Data Protection / Privacy".

2. Personal Data We Collect

spinngo collects the following categories of personal data:

2.1 spinngo does not collect sensitive personal data (such as racial origin, religious beliefs, or biometric data) unless required for identity verification under our regulatory obligations.

3. How We Collect Personal Data

spinngo collects personal data through the following means:

• Direct provision: Information you supply when registering, completing KYC verification, making a deposit or withdrawal, contacting support, or responding to a survey;
• Automated collection: Technical data collected automatically via cookies, server logs, and similar tracking technologies when you visit or use the spinngo platform;
• Third parties: Identity and fraud-screening data received from KYC verification partners and payment processors in connection with account verification and transaction processing.

4. Purposes for Which We Use Your Data

spinngo uses personal data for the following purposes:

• To create, manage, and maintain your spinngo account;
• To verify your identity and age (21+) as required by our licensing obligations;
• To process deposits, withdrawals, and related financial transactions in MYR;
• To provide and improve the games, sportsbook, and other platform features;
• To administer promotions, bonuses, and loyalty programmes;
• To detect and prevent fraud, money laundering, problem gambling, and other prohibited conduct;
• To comply with anti-money laundering ("AML"), responsible gaming, and other regulatory requirements;
• To respond to support queries and resolve complaints;
• To send transactional communications (e.g. deposit confirmations, withdrawal notifications, security alerts);
• To send promotional communications where you have opted in to receive them (you may opt out at any time);
• To analyse platform usage and improve the spinngo user experience.

5. Legal Bases for Processing

spinngo processes your personal data on the following legal bases:

• Contract performance: Processing necessary to provide the services you have contracted for when registering a spinngo account;
• Legal obligation: Processing required by applicable AML, responsible gaming, KYC, and data retention laws;
• Legitimate interests: Processing for fraud prevention, platform security, and improving our services, where such interests are not overridden by your rights;
• Consent: Processing for direct marketing communications, where you have explicitly opted in. You may withdraw consent at any time.

6. Data Sharing & Third-Party Disclosure

6.1 spinngo does not sell, rent, or trade your personal data to third parties for their independent marketing purposes.

6.2 spinngo may share your personal data with the following categories of recipients, solely to the extent necessary for the stated purposes:

• Payment processors: Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank, Visa/Mastercard networks — for transaction processing;
• KYC and identity verification providers: To verify your identity and comply with age restriction and AML obligations;
• Game software providers: Limited technical and session data necessary to deliver certified games within the spinngo platform;
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory direction;
• IT and hosting service providers: Engaged to operate and maintain the spinngo platform infrastructure under binding data processing agreements.

6.3 All third-party service providers engaged by spinngo are required to process personal data only on spinngo's instructions and in accordance with applicable data protection standards.

7. International Data Transfers

7.1 Some of spinngo's service providers and game providers are located outside Malaysia. Where personal data is transferred to recipients in countries that do not provide an equivalent level of data protection, spinngo implements appropriate safeguards including standard contractual clauses, data processing agreements, or equivalent transfer mechanisms recognised under applicable law.

7.2 You may request details of the specific safeguards applicable to any particular international transfer by contacting [email protected].

8. Cookies & Tracking Technologies

8.1 The spinngo platform uses cookies and similar technologies to maintain session state, personalise your experience, detect fraud, and collect aggregate usage analytics. The following categories of cookies may be set:

• Strictly necessary: Required for the platform to function, including session authentication and security tokens;
• Functional: Remember your preferences such as language settings and responsible gaming limits;
• Analytics: Aggregate, anonymised data used to understand platform usage patterns and improve features;
• Security/fraud prevention: Device fingerprinting and behavioural signals used to detect suspicious access attempts.

8.2 You may manage non-essential cookies through your browser settings. Disabling strictly necessary cookies will impair your ability to use the spinngo platform.

9. Data Retention

9.1 spinngo retains personal data for as long as your account remains active and for a minimum of five (5) years following account closure, in compliance with AML and regulatory record-keeping obligations.

9.2 KYC documents and transaction records are retained for the period required by applicable law, which may extend beyond the general five-year minimum.

9.3 Following the expiry of applicable retention periods, personal data is securely deleted or anonymised such that it can no longer be associated with any identifiable individual.

10. Your Rights

Subject to applicable data protection law, you may hold the following rights in respect of your personal data held by spinngo:

• Access: The right to request a copy of the personal data spinngo holds about you;
• Rectification: The right to request correction of inaccurate or incomplete personal data;
• Erasure: The right to request deletion of your personal data, subject to overriding legal or regulatory retention obligations;
• Restriction: The right to request that processing of your data be restricted in certain circumstances;
• Portability: The right to receive personal data you have provided in a structured, machine-readable format;
• Objection: The right to object to processing based on legitimate interests or for direct marketing purposes;
• Withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, submit a written request to [email protected] marked "Data Rights Request". spinngo will respond within thirty (30) days. We may require identity verification before fulfilling any request.

11. Children's Privacy

11.1 The spinngo platform is strictly intended for adults aged 21 years and over. spinngo does not knowingly collect personal data from persons under 21. If spinngo becomes aware that a person under 21 has provided personal data, that data will be deleted and the account closed immediately.

11.2 If you believe a minor has registered on the spinngo platform, please notify us immediately at [email protected].

12. Data Security

12.1 spinngo implements industry-standard technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, and destruction. These measures include 256-bit SSL encryption for all data in transit, hashed password storage, access controls restricting data access to authorised personnel, and regular security assessments.

12.2 In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, spinngo will notify you without undue delay and take all reasonable steps to mitigate the impact of the breach.

12.3 While spinngo takes all reasonable precautions, no internet transmission is entirely secure. You are responsible for maintaining the confidentiality of your spinngo login credentials and for logging out of shared or public devices.

13. Changes to This Policy

13.1 spinngo may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable law. Material changes will be communicated to registered players via email or a prominent notice on the spinngo platform no less than seven (7) days before they take effect.

13.2 Your continued use of the spinngo platform after the effective date of any revision constitutes your acceptance of the updated Policy.

14. Contact & Complaints

For all privacy-related enquiries, requests to exercise your data rights, or complaints regarding spinngo's handling of your personal data, please contact us at:

Email (plain text — not a link): [email protected] — subject line: "Data Protection / Privacy"

We aim to acknowledge all privacy enquiries within two (2) business days and resolve them within thirty (30) days. If you are not satisfied with spinngo's response, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.