Privacy Policy

1. About This Policy

This Privacy Policy is issued by spinggo ("spinggo", "we", "us", "our") and applies to all personal data collected through the spinggo website at spinggo.co, the spinggo mobile application, and any related services, features, or communications.

spinggo is committed to protecting the privacy and personal data of all players and visitors. This policy has been prepared in accordance with applicable data protection legislation and the requirements of the gaming authority under which spinggo operates.

This Privacy Policy should be read together with spinggo's Terms and Conditions and Responsible Gaming Policy. By accessing or using the spinggo platform, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

spinggo collects personal data that you provide directly, data generated through your use of the platform, and data received from third-party service providers. The categories of personal data we collect include:

spinggo does not collect or store complete payment card numbers. Payment processing is handled by PCI-DSS compliant third-party payment processors, and spinggo receives only tokenised or masked payment references.

3. How We Use Your Personal Data

spinggo uses personal data for the following purposes:

• Account Management: To create, maintain, and secure your spinggo account, including authentication and account recovery;
• Service Delivery: To provide access to games, process deposits and withdrawals, and fulfil your requests on the spinggo platform;
• Identity Verification (KYC): To verify your identity and age as required under gaming regulations and anti-money laundering obligations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, bonus abuse, and other prohibited activities;
• Regulatory Compliance: To comply with applicable gaming, anti-money laundering, and data protection regulations;
• Customer Support: To respond to enquiries, resolve disputes, and provide technical assistance;
• Marketing Communications: To send promotional offers, bonuses, and platform updates to players who have opted in to receive such communications;
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the spinggo platform experience;
• Responsible Gaming: To monitor player activity for indicators of problem gambling and to apply and enforce responsible gaming tools where applicable.

4. Legal Basis for Processing

spinggo processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between spinggo and the player, including account operation and payment processing;
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, and gaming licence conditions;
• Legitimate Interests: Processing carried out in spinggo's legitimate business interests, including fraud prevention, platform security, and platform analytics, where such interests are not overridden by the rights of the data subject;
• Consent: Processing based on your explicit consent, including the sending of marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5. Sharing Your Personal Data

spinggo does not sell personal data to third parties. spinggo may share personal data with the following categories of recipients where necessary:

• Payment Processors: Including Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank, and FPX service providers, for the purpose of processing deposits and withdrawals;
• Game Providers: Licensed game studio partners who supply live casino, slot, and table game content to the spinggo platform, to the extent required for game operation and dispute resolution;
• Identity Verification Services: Third-party KYC and AML compliance providers who assist spinggo in verifying player identity and monitoring for suspicious activity;
• Regulatory Authorities: Gaming regulators, financial intelligence units, and law enforcement agencies where disclosure is required by law or regulation;
• Technology Service Providers: Cloud hosting, cybersecurity, analytics, and customer support platform vendors, under strict data processing agreements;
• Responsible Gaming Partners: Organisations operating self-exclusion registers or problem gambling support services, where a player has requested self-exclusion or where spinggo has a regulatory obligation to report.

All third-party recipients are required to handle personal data in a manner consistent with this Privacy Policy and applicable data protection laws. spinggo does not authorise third-party recipients to use player data for their own marketing purposes.

6. International Data Transfers

spinggo operates internationally and may transfer personal data to countries outside of Malaysia in connection with the services described in this policy. Where such transfers occur, spinggo ensures that appropriate safeguards are in place, including contractual data protection clauses, to provide a level of protection equivalent to that required under applicable Malaysian data protection legislation.

By using the spinggo platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Malaysia where the above safeguards are in place.

7. Data Retention

spinggo retains personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. The key retention considerations are:

• Account data is retained for the duration of the active account relationship and for a minimum of five (5) years following account closure, in accordance with anti-money laundering regulatory requirements;
• Transaction records are retained for a minimum of seven (7) years for financial and regulatory compliance purposes;
• Customer support and communication records are retained for a period of three (3) years from the date of the last interaction;
• Marketing consent records are retained for the duration of the consent and for three (3) years following withdrawal of consent as evidence of prior authorisation.

At the end of the applicable retention period, personal data is securely deleted or anonymised in accordance with spinggo's data disposal procedures.

8. Cookies and Tracking Technologies

The spinggo platform uses cookies and similar tracking technologies to enhance functionality, analyse platform usage, and support security operations. The categories of cookies used by spinggo are:

• Strictly Necessary Cookies: Required for basic platform functions including login session management and security. These cannot be disabled;
• Performance Cookies: Collect anonymised data on how players use the spinggo platform to help improve performance and user experience;
• Functional Cookies: Remember your preferences and settings to provide a personalised experience on return visits;
• Analytics Cookies: Used to understand aggregate usage patterns on the spinggo platform. Data collected via analytics cookies does not identify individual players.

You may manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the spinggo platform.

9. Your Data Rights

As a spinggo player, you have the following rights in relation to your personal data:

• Access: You may request a copy of the personal data spinggo holds about you;
• Rectification: You may request correction of inaccurate or incomplete personal data;
• Erasure: You may request deletion of your personal data where there is no compelling legal or regulatory reason for continued retention;
• Restriction: You may request that spinggo restricts the processing of your data in certain circumstances;
• Portability: You may request a structured, machine-readable copy of personal data you have provided to spinggo for transfer to another service provider;
• Objection: You may object to processing based on legitimate interests or for direct marketing purposes.

To exercise any of the above rights, please contact spinggo customer support. spinggo will respond to all data rights requests within 30 days. Where a request is complex or numerous, the response period may be extended by a further 60 days with notification to the requestor. spinggo will not charge a fee for handling data rights requests unless they are manifestly unfounded or excessive.

10. Security Measures

spinggo implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the spinggo platform;
• Encrypted storage of sensitive data at rest using industry-standard algorithms;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Multi-factor authentication options available for all spinggo player accounts;
• Incident response procedures for the detection, investigation, and notification of personal data breaches in accordance with applicable regulatory requirements.

Whilst spinggo takes all reasonable precautions to protect your data, no electronic transmission over the internet can be guaranteed to be completely secure. Players are encouraged to use strong, unique passwords for their spinggo account and to enable multi-factor authentication.

11. Children and Minors

The spinggo platform is strictly for adults aged 21 years and above. spinggo does not knowingly collect or process personal data from individuals under the age of 21. If spinggo becomes aware that personal data has been collected from a minor, the relevant account will be closed immediately and the data deleted without delay.

If you believe that a minor has registered for a spinggo account, please contact spinggo support immediately so that appropriate action can be taken.

12. Changes to This Privacy Policy

spinggo reserves the right to update this Privacy Policy at any time. Where changes are material, spinggo will publish the updated policy on this page with a revised "Last Updated" date. For significant changes, spinggo may also provide notice to registered players via email or in-platform notification.

Your continued use of the spinggo platform following any update to this Privacy Policy constitutes your acceptance of the revised terms. It is your responsibility to review this page periodically. If you do not agree with any amendment, you should cease using the platform and contact support to close your account.

13. Contact and Data Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by spinggo, please contact the spinggo data privacy team via customer support. Live chat support is available 24 hours a day, 7 days a week.

Written data privacy enquiries may be directed to spinggo at the following email address. Please include your registered username, a description of your enquiry, and any relevant account reference numbers.

spinggo data privacy contact: [email protected] (plain text — not a clickable link)

spinggo aims to acknowledge all privacy-related enquiries within 5 business days and to provide a substantive response within 30 calendar days. Where a request requires additional time to process, spinggo will notify you of the expected timeline.