spin996 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by spin996 ("the Company", "we", "us", "our") and applies to all personal data processed by spin996 in connection with the operation of the spin996 platform at spin996.co, including all associated sub-domains, mobile interfaces, customer support channels, and related services (collectively, "the Platform").

spin996 recognises that Malaysian players entrust us with sensitive personal and financial information when they create an account, make transactions, or interact with the Platform. We take that trust seriously. This Policy is designed to be clear, accurate, and complete — not a document engineered to obscure how your data is actually used.

By using the spin996 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. This Policy should be read in conjunction with our Terms & Conditions.

2. Data Controller

spin996 acts as the data controller for all personal data processed in connection with the Platform. As data controller, spin996 determines the purposes and means by which your personal data is processed. Where spin996 engages third-party service providers to process personal data on its behalf, those providers act as data processors and are contractually bound to process data only in accordance with spin996's instructions and applicable data protection law.

For all data protection enquiries, requests, or complaints, please contact spin996 via the details provided in Section 14 of this Policy.

3. Personal Data We Collect

spin996 collects the following categories of personal data from Members and prospective Members:

• Identity Data: Full legal name, date of birth, nationality, and copies of government-issued identity documents (e.g., MyKad, passport) provided during the KYC (Know Your Customer) verification process.
• Contact Data: Email address, mobile telephone number, and residential address.
• Financial Data: Payment method details (e.g., Touch 'n Go eWallet account identifiers, bank account numbers for FPX transactions, USDT wallet addresses), deposit and withdrawal transaction records, and account balance history.
• Account Data: Username, encrypted password, account registration date, login history, session timestamps, and IP addresses associated with account access.
• Gaming Activity Data: Game play history, wager amounts, win/loss records, bonus utilisation, and sportsbook betting activity across all spin996 products.
• Device & Technical Data: Device type, operating system, browser type and version, screen resolution, and device identifiers collected automatically when you access the Platform.
• Communications Data: Records of communications between you and spin996 customer support, including live chat transcripts and email correspondence.
• Responsible Gaming Data: Records of responsible gaming tools activated on your account, including deposit limit settings, cooling-off periods, and self-exclusion requests.

4. How We Collect Your Data

spin996 collects personal data through the following methods:

• Direct Collection: Information you provide when registering your spin996 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and device data collected automatically by the Platform's servers when you access the website, including through cookies, web beacons, server logs, and similar tracking technologies as described in Section 9.
• Third-Party Sources: Identity verification data received from KYC service providers and fraud prevention agencies engaged by spin996; payment data received from payment processing partners in connection with transaction verification.
• Publicly Available Sources: In limited circumstances, spin996 may verify Member information against publicly available records for compliance, fraud prevention, or AML (Anti-Money Laundering) purposes.

5. Purposes of Processing & Legal Basis

spin996 processes your personal data for the following purposes and on the following legal bases:

• Account Administration (Contractual Necessity): Creating and managing your spin996 account, processing deposits and withdrawals, verifying your identity, and providing access to the Platform's gaming services.
• Regulatory Compliance (Legal Obligation): Complying with applicable anti-money laundering (AML) regulations, KYC requirements, and any applicable financial crime prevention obligations imposed by the international gaming authority licensing framework under which spin996 operates.
• Fraud Prevention & Security (Legitimate Interest): Detecting and preventing fraudulent transactions, unauthorised account access, bonus abuse, collusion, and other prohibited activities that would harm spin996 or its Members.
• Customer Support (Contractual Necessity / Legitimate Interest): Responding to Member enquiries, complaints, and technical support requests; maintaining records of such interactions to improve service quality.
• Responsible Gaming (Legal Obligation / Legitimate Interest): Monitoring gaming behaviour for indicators of problem gambling; enforcing self-exclusion, cooling-off, and deposit limit controls set by Members; complying with responsible gaming obligations under applicable licensing conditions.
• Marketing Communications (Consent): Sending promotional communications, bonus offers, and product updates to Members who have opted in to receive such communications. You may withdraw this consent at any time by contacting spin996 support or using the unsubscribe mechanism in any marketing email.
• Platform Improvement (Legitimate Interest): Analysing aggregate, anonymised usage data to improve the Platform's functionality, game catalogue, payment experience, and customer support processes.

6. Data Sharing & Disclosure

spin996 does not sell your personal data to third parties. We may share your personal data with third parties only in the following circumstances:

• Service Providers: Third-party companies engaged by spin996 to provide services on our behalf, including payment processing, identity verification, fraud prevention, IT hosting and infrastructure, customer support technology, and analytics. These providers process data solely under spin996's instructions and are subject to contractual data protection obligations.
• Game Studio Partners: Licensed game studios providing games on the Platform may receive anonymised session and outcome data for RTP auditing and game integrity purposes. No directly identifying Member data is shared with game studios for this purpose.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, legal process, or regulatory direction — including anti-money laundering reporting obligations — spin996 may disclose Member data to competent governmental, regulatory, or law enforcement authorities.
• Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of all or part of spin996's business, Member data may be transferred to the successor entity, subject to equivalent data protection commitments.

spin996 requires all third-party recipients of personal data to maintain appropriate technical and organisational security measures and to use such data only for the purposes for which it was disclosed.

7. International Data Transfers

The spin996 Platform serves Members across Malaysia and other jurisdictions, and our operations, service providers, and data storage infrastructure may be located in countries outside Malaysia. Where personal data is transferred outside Malaysia, spin996 takes appropriate steps to ensure that such transfers are subject to adequate legal safeguards, including the use of standard contractual clauses or equivalent measures that provide a level of data protection consistent with applicable standards.

By using the spin996 Platform, you acknowledge and consent to the transfer of your personal data to other jurisdictions as described in this Section, subject to the safeguards described above.

8. Data Retention

spin996 retains personal data for as long as necessary to fulfil the purposes for which it was collected, including the following retention periods:

• Active Account Data: Retained for the duration of your spin996 account's active status plus a minimum period of five (5) years following account closure, in accordance with AML record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of seven (7) years from the date of each transaction, in accordance with applicable financial record-keeping requirements.
• KYC Verification Documents: Retained for the duration of account operation plus five (5) years following account closure.
• Customer Support Records: Retained for three (3) years from the date of the interaction, unless the subject matter requires longer retention for legal or compliance reasons.
• Marketing Consent Records: Retained for three (3) years from the date of consent or its withdrawal, whichever is later.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with spin996's data deletion procedures.

9. Cookies & Tracking Technologies

The spin996 Platform uses cookies and similar tracking technologies to enable core Platform functionality, maintain session security, and analyse Platform usage. The following categories of cookies are used:

• Essential Cookies: Strictly necessary for the Platform to function. These include session authentication cookies that keep you logged in to your spin996 account during an active session. Essential cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences and settings, such as language preferences and the "Keep me signed in" option on the spin996 login page.
• Analytics Cookies: Collect anonymised, aggregated data about how Members navigate and use the Platform. This data is used exclusively for internal Platform improvement purposes. spin996 does not use analytics data to build personal advertising profiles.
• Security Cookies: Assist in detecting and preventing fraudulent activity, bot access, and unusual login patterns on the Platform.

You may control cookie settings through your browser preferences. Please note that disabling essential cookies will impair your ability to access the spin996 Platform, including completing the sign-in process.

10. Your Data Protection Rights

Subject to applicable law and spin996's legal obligations, Members have the following rights in respect of their personal data:

• Right of Access: You may request a copy of the personal data spin996 holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data held on your spin996 account.
• Right to Erasure: You may request deletion of your personal data in certain circumstances, subject to spin996's legal obligations to retain records (see Section 8).
• Right to Restriction of Processing: You may request that spin996 restrict the processing of your personal data in certain defined circumstances.
• Right to Data Portability: Where processing is carried out by automated means on the basis of your consent or a contract, you may request that your personal data be provided to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of spin996's legitimate interests, including direct marketing processing.
• 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 prior to withdrawal.

To exercise any of the above rights, please contact spin996 using the details in Section 14. spin996 will respond to verified requests within thirty (30) days. spin996 may request identity verification before processing any data subject request.

11. Security Measures

spin996 implements a comprehensive set of technical and organisational security measures to protect Member personal data against unauthorised access, disclosure, alteration, and destruction:

• AES-256 Encryption at Rest: All stored personal data, financial records, and account credentials are encrypted using AES-256 standard encryption.
• TLS 1.3 in Transit: All data transmitted between your browser or device and the spin996 Platform is encrypted using TLS 1.3 protocol, protecting your data from interception during transmission.
• Two-Factor Authentication: App-based 2FA is available for all spin996 accounts, providing an additional layer of protection against unauthorised account access beyond password credentials alone.
• Access Controls: Access to Member personal data within spin996's systems is restricted on a need-to-know basis, with role-based access controls enforced for all internal staff and third-party service providers.
• Penetration Testing & Security Audits: The spin996 Platform undergoes periodic security assessments by qualified independent security professionals.
• Incident Response: spin996 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to Members, spin996 will notify affected Members and applicable regulatory authorities as required by law.

12. Children's Privacy

The spin996 Platform is strictly intended for adults aged 21 years and above. spin996 does not knowingly collect personal data from individuals under the age of 21. If spin996 becomes aware that personal data has been collected from a person under the minimum age, such data will be deleted promptly and the associated account will be permanently closed.

Parents or guardians who believe a minor may have accessed the spin996 Platform or provided personal data to spin996 without authorisation are encouraged to contact spin996 immediately via the support contact details in Section 14.

13. Policy Amendments

spin996 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable data protection law, our data processing practices, or the services offered on the Platform. Material amendments will be communicated to Members via the registered email address associated with their account and/or by prominent notice on the Platform, with a minimum notice period of seven (7) calendar days prior to the amended Policy taking effect.

The "Last updated" date at the top of this Policy reflects the most recent revision. Your continued use of the spin996 Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using the Platform and may request account closure in accordance with our Terms & Conditions.

14. Contact & Complaints

For any queries, requests, or complaints relating to this Privacy Policy or spin996's handling of your personal data, please contact our Data Protection team:

• Email: support@spin996.co (plain text only — not a clickable link)
• Live Chat: Available 24/7 via the spin996 Platform
• Subject Line: Please use "Data Protection Request" or "Privacy Enquiry" to ensure prompt routing to the relevant team

spin996 aims to acknowledge all privacy-related correspondence within five (5) business days and to provide a substantive response within thirty (30) days. If you are not satisfied with spin996's response to a data protection complaint, you may have the right to escalate your complaint to the applicable data protection supervisory authority in your jurisdiction.