SpinCity44 Privacy Policy – Our Commitment to Protecting Your Personal Data

This SpinCity44 Privacy Policy describes the data handling practices observed by SpinCity44 for all services accessed through our official website at spincity44.app. This document has been prepared in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and recognised international data protection standards.

SpinCity44 acts as both data processor and data controller for all personal information collected from members during registration, platform use, deposits and withdrawals via Malaysian payment methods such as DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, and FPX, as well as all other interactions with the SpinCity44 platform.

By registering an account with SpinCity44 or continuing to use our services, you consent to the collection and processing of your personal data as described in this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the SpinCity44 platform and contact us to close your account.

2.1 Personal Data You Provide to SpinCity44

2.2 Technical & Usage Data Collected Automatically

• IP address, device type, operating system, and web browser used.
• Activity logs within the SpinCity44 platform, including games played, bets placed, and session duration.
• General geolocation data (region, not precise coordinates) for Malaysian location verification.
• Cookie and tracking technology information as described in Section 7.
• Game performance data and betting statistics for SpinCity44 service improvement purposes.

SpinCity44 collects your personal data through the following channels:

• Directly From You: When you register a SpinCity44 account, complete the identity verification (KYC) process, make a deposit via DuitNow or a Malaysian e-wallet, contact customer support, or submit any form on the platform.
• Automatically: When you use the SpinCity44 platform, our systems automatically record technical and usage data via cookies, pixels, and other tracking technologies as described in Section 7 of this document.
• From Authorised Third Parties: SpinCity44 may receive your personal data from Malaysian payment service providers you use for deposits (such as transaction verification details from DuitNow or Maybank2u), as well as from identity verification service providers we work with.
• From Public Sources: In certain cases related to legal compliance or fraud prevention, SpinCity44 may reference publicly available information sources as permitted under Malaysian law.

SpinCity44 does not collect sensitive personal data such as health information, religious beliefs, or political views unless specifically required by applicable law.

SpinCity44 uses collected personal data solely for legitimate purposes, which are transparently outlined below:

• Service Provision: Processing account registration, verifying your identity, handling deposits via DuitNow and Malaysian e-wallets, and managing your winnings withdrawals in Malaysian Ringgit (MYR).
• Security & Verification: Verifying your identity at login, detecting unusual activity or fraud attempts, and protecting your SpinCity44 account from unauthorised access.
• Legal Compliance: Complying with the requirements of the Personal Data Protection Act 2010 (PDPA), anti-money laundering (AML) obligations, and any other applicable legal requirements in Malaysia.
• Customer Support: Helping you resolve technical issues, addressing queries about your account or transactions, and ensuring a seamless gaming experience at SpinCity44.
• Product Improvement: Analysing SpinCity44 platform usage patterns to improve game features, platform performance, and the overall experience for Malaysian users.
• Service Communications: Sending important notifications about your account, security, terms changes, and SpinCity44 promotional information (where you have consented to receive such communications).
• Responsible Gaming: Monitoring gameplay patterns to identify and support members who may need responsible gambling assistance.

SpinCity44 does not sell, rent, or disclose your personal data to any third party for marketing or commercial purposes. However, in the following limited circumstances, SpinCity44 may share your personal data with authorised third parties:

• Malaysian Payment Providers: Transaction data is shared with payment processors such as DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, and FPX banks (Maybank2u, CIMB Clicks) solely for the purpose of processing your financial transactions.
• Game Providers: Game session information is shared with licensed game providers whose platforms are integrated into SpinCity44, limited strictly to data required for game operation.
• Identity Verification Providers: KYC verification data is shared with licensed and certified third-party identity verification service providers to ensure anti-fraud compliance.
• Legal Requirements: SpinCity44 may disclose your personal data to Malaysian authorities if required by law, court order, or a legitimate official investigation.
• Professional Advisors: In certain situations, required personal data may be shared with SpinCity44's lawyers, accountants, or auditors, subject to strict professional confidentiality obligations.

All third parties receiving personal data from SpinCity44 are required to protect that data to a security standard equal to or higher than SpinCity44's own, and to use it solely for authorised purposes.

SpinCity44 continually invests in industry-leading security technologies and procedures to protect our members' personal data. Key security measures implemented by SpinCity44 include:

• 256-bit SSL Encryption: All communications between your device and SpinCity44's servers are encrypted using 256-bit TLS/SSL protocol, ensuring data cannot be intercepted in transit.
• Two-Factor Authentication (2FA): SpinCity44 provides and actively encourages the use of two-factor authentication on all accounts as an added layer of security.
• Strict Access Controls: Access to SpinCity44 members' personal data is restricted to staff with a legitimate operational need, and all access is logged and audited on a regular basis.
• Continuous Monitoring: SpinCity44's security monitoring system operates 24/7 to detect and respond to any threats or unusual activity promptly.
• Regular Security Audits: SpinCity44 conducts regular penetration testing and vulnerability assessments carried out by certified independent security experts.
• Incident Response Plan: SpinCity44 has a comprehensive security incident response plan to ensure a swift and effective response in the event of any security incident.

SpinCity44 uses cookies and similar tracking technologies to enhance your user experience, analyze platform traffic, and secure your login sessions. The following are the types of cookies used by SpinCity44:

You can manage cookie settings through your web browser preferences. Please note that disabling essential cookies will affect the functionality of the SpinCity44 platform, including your ability to log in and play.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you as a data subject have the following rights regarding your personal data held by SpinCity44:

To exercise any of the above rights, please contact the SpinCity44 privacy team by email at privacy@spincity44.app or via 24/7 live chat. SpinCity44 will process your request within 30 working days of receipt.

SpinCity44 retains members' personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy, or as required by applicable Malaysian law. General data retention guidelines are as follows:

• Active Account Data: For the duration of your active SpinCity44 membership.
• Data After Account Closure: Identity information and financial records are retained for a minimum of 7 years following account closure, in accordance with Malaysia's AML and tax legal requirements.
• Game Activity Logs: Retained for 2 years for dispute resolution and audit purposes.
• Customer Support Records: Retained for 3 years as evidence of complaint resolution.
• Marketing Data: Deleted within 30 days after you withdraw consent for marketing communications.

Once the designated retention period has elapsed, SpinCity44 will securely delete or anonymise your personal data using methods that ensure it cannot be recovered or reused.

SpinCity44's services are intended solely for individuals aged 21 and above, and SpinCity44 does not knowingly collect personal data from minors or individuals below the stipulated age limit. Should SpinCity44 discover that personal data of an underage individual has been collected without appropriate age verification, we will take immediate action to delete such data and close the account in question.

If you believe your child or a minor has registered an account with SpinCity44, please contact us immediately at support@spincity44.app so that we can take appropriate action promptly.

The SpinCity44 platform may contain links to integrated third-party services, including licensed game providers and Malaysian payment providers such as DuitNow, Touch 'n Go eWallet, and GrabPay. This SpinCity44 Privacy Policy applies solely to the SpinCity44 platform itself.

SpinCity44 is not responsible for the privacy practices or content of third-party services integrated into our platform. We encourage you to read the privacy policy of each third-party service you use. Any data shared with Malaysian payment processors is strictly for the purpose of processing transactions that you have initiated.

If you have any questions, concerns, or requests regarding SpinCity44's Privacy Policy or the handling of your personal data, please reach out to us through the following channels:

• Privacy Email: privacy@spincity44.app
• General Support Email: support@spincity44.app
• Live Chat: Available 24/7 directly through the SpinCity44 platform
• Mailing Address: Data Privacy Division, SpinCity44, Kuala Lumpur, Malaysia

SpinCity44 is committed to responding to all privacy-related enquiries within 14 working days from the date of receipt. For more complex data subject rights requests, we may require up to 30 working days and will notify you should additional time be needed.

SpinCity44 reserves the right to update this Privacy Policy from time to time to reflect changes in data practices or legal requirements. The latest version will always be available on the SpinCity44 website, and you will be notified of material changes via email or in-platform notification.