Privacy Policy

1. Introduction

Spinngo operates an online gaming and sports betting platform designed to serve Malaysian players. In the course of providing these services, Spinngo necessarily collects and processes certain personal data. We take this responsibility seriously. This Policy is intended to give you a clear and transparent account of how your data is handled — from the moment you begin registration through to account closure and beyond, where legal retention obligations apply.

This Policy applies to all data processing activities carried out by Spinngo in connection with the platform, including account management, payment processing, identity verification, marketing communications (where opted-in), responsible gambling monitoring, and customer support. It should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which form part of the overall agreement governing your use of Spinngo.

If you have any questions about how your data is handled, please contact us using the details in Section 16 of this Policy.

2. Definitions

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

• "Account" — the registered user profile created on the Spinngo platform.
• "Controller" — Spinngo, as the entity that determines the purposes and means of processing personal data.
• "Data Subject" — the natural person (you, the Player) to whom personal data relates.
• "KYC Data" — identity verification documents and information collected as part of Know Your Customer compliance procedures.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, device identifiers, IP address, transaction history, and identity documents.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, transfer, or deletion.
• "Processor" — a third party that processes personal data on behalf of Spinngo under a formal data processing agreement.
• "Special Category Data" — personal data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, which is subject to heightened protections.

3. Personal Data We Collect

The categories of personal data Spinngo collects are set out in the table below, along with the primary purpose of collection in each case.

4. How Personal Data is Collected

Spinngo collects personal data through the following channels:

• Direct submission: Information you provide when creating an Account, completing KYC verification, contacting support, entering promotions, or updating your profile.
• Automated technical collection: Data gathered automatically when you access the platform, including IP address, device identifiers, browser information, and session activity logs.
• Payment processors: Transaction metadata (not full payment credentials) received from our certified Malaysian payment partners — DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, and Hong Leong — in connection with deposit and withdrawal processing.
• Identity verification providers: Results and flags from third-party KYC and AML screening tools used to verify identity documents and assess risk.
• Cookies and similar technologies: As described in Section 11 of this Policy.

5. Purposes of Data Processing

Spinngo processes personal data for the following defined purposes:

1. Account registration and management — creating, maintaining, and securing your Spinngo Account.
2. Identity verification (KYC) and age verification — confirming that all Players are aged 21 or above and that accounts are not held by ineligible persons.
3. Payment processing — facilitating deposits and withdrawals in MYR via accepted Malaysian payment methods.
4. Anti-money laundering (AML) and fraud prevention — detecting and preventing fraudulent activity, money laundering, and other financial crimes as required by applicable law.
5. Service delivery and personalisation — providing access to games, betting markets, promotions, and VIP programme features relevant to your Account status.
6. Customer support — responding to queries, complaints, and requests submitted via live chat or email.
7. Responsible gambling monitoring — identifying behavioural patterns that may indicate problem gambling and applying appropriate safeguards, including enforcing self-exclusion and deposit limits.
8. Legal and regulatory compliance — meeting obligations imposed by licensing conditions, applicable law, and regulatory authorities.
9. Security and platform integrity — detecting and preventing unauthorised access, bot activity, account takeover, and other security threats.
10. Direct marketing — sending promotional communications via email or in-platform notification where you have provided explicit consent and have not subsequently withdrawn it.

6. Lawful Basis for Processing

Every processing activity at Spinngo is supported by one of the following lawful bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions — including account management, payment processing, and game service delivery.
• Legal obligation: Processing required to comply with AML regulations, KYC requirements, licensing conditions, and other applicable laws.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gambling monitoring, and improving the quality of our services, where those interests are not overridden by your fundamental rights.
• Consent: Direct marketing communications sent only where you have provided clear, informed, and freely given consent. You may withdraw consent at any time by updating your Account preferences or contacting our support team.

7. Data Sharing with Third Parties

Spinngo does not sell, rent, or otherwise transfer personal data to third parties for their own marketing purposes. We share personal data only in the following defined circumstances and strictly on a need-to-know basis:

• Payment processors: Malaysian-licensed payment partners (DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong) receive transaction data necessary to process deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML screening services receive identity document data solely for the purpose of completing verification checks. These providers operate under formal data processing agreements with Spinngo.
• Licensed game studio partners: Generic game platform providers may receive pseudonymised Account identifiers and game session data to facilitate game delivery and resolve technical disputes. No directly identifying personal data is shared with game studios beyond what is technically required.
• Regulatory and law enforcement authorities: Spinngo may be required by law, court order, or regulatory demand to disclose personal data to competent authorities. In such cases, Spinngo will comply with legal obligations while seeking to protect Player privacy to the extent permitted.
• Professional advisers: Lawyers, auditors, and compliance consultants may have access to personal data where strictly necessary for the purpose of providing professional advice, subject to binding confidentiality obligations.

8. International Data Transfers

Some of Spinngo's service providers and technology partners may be located in countries outside Malaysia. Where personal data is transferred internationally, Spinngo ensures that appropriate safeguards are in place — including standard contractual clauses, adequacy determinations, or other legally recognised transfer mechanisms — to ensure that your personal data receives an equivalent level of protection regardless of where it is processed.

If you would like further information about the specific safeguards applied to any particular international transfer, please contact our support team.

9. Data Retention

Spinngo retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and licensing obligations. The general retention principles applied are as follows:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by standard AML and regulatory record-keeping obligations.
• Transaction and gaming records: Retained for a minimum of five (5) years, consistent with financial record-keeping requirements and potential dispute resolution needs.
• Customer support communications: Retained for a minimum of two (2) years for quality assurance, dispute resolution, and regulatory compliance purposes.
• Marketing preference data: Retained until you withdraw consent, request deletion, or close your Account — whichever occurs first.
• Technical and security logs: Typically retained for twelve (12) months, unless required for longer retention in connection with a specific security incident or investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents identification of the Data Subject.

10. Security Measures

Spinngo employs a layered security architecture to protect personal data against unauthorised access, disclosure, alteration, or destruction. Our technical and organisational security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• AES-256 encryption for sensitive data stored at rest.
• Role-based access controls ensuring that personnel can access only the data necessary for their specific function.
• Two-factor authentication (2FA) for all internal systems used to access personal data.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Detailed access logs and anomaly detection systems that flag unusual patterns of data access or export.
• Incident response procedures in place to ensure prompt detection, containment, and reporting of any personal data breach.

While Spinngo takes all reasonable precautions to protect your data, no online system can guarantee absolute security. You are responsible for maintaining the security of your Account credentials. Please notify us immediately if you suspect any unauthorised access to your Account.

11. Cookies & Similar Tracking Technologies

11.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites function correctly and to provide analytical information about how users interact with web content. Spinngo uses cookies and similar technologies (including pixel tags and local storage) on its platform.

11.2 Types of Cookies Used

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting the usability of the platform.
• Functional cookies: Used to remember your preferences, such as language settings, game display preferences, and logged-in status. Improve your experience without being used for tracking.
• Analytics cookies: Collect anonymised data about how users navigate the platform, which pages are visited most frequently, and where users encounter errors. Used solely to improve platform performance.
• Security cookies: Help detect and prevent fraudulent activity, including bot detection and session integrity checks.

11.3 Managing Cookies

You can control cookie settings through your browser preferences. Note that disabling certain cookies — particularly strictly necessary cookies — may impair the functionality of the Spinngo platform. Spinngo does not use third-party advertising or behavioural targeting cookies.

12. Your Data Subject Rights

You hold a number of rights in respect of your personal data. These rights are explained below. To exercise any of them, please contact our support team using the details in Section 16. We will respond to all valid requests within thirty (30) days, subject to extension in complex cases.

Please note that certain rights are subject to limitations where Spinngo has a legal obligation to retain data — for example, KYC and transaction records required by AML regulations. In such cases, we will clearly explain the basis for any restriction on your rights.

13. Minors & Age Verification

Spinngo is strictly a platform for adults. We do not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the account registration and KYC process. If Spinngo becomes aware that personal data has been collected from a minor, the Account will be immediately closed, all associated data will be deleted to the extent legally permissible, and the matter may be escalated to relevant authorities.

Parents and guardians who believe a minor may have accessed Spinngo are encouraged to contact our support team immediately at [email protected].

14. Third-Party Services and External Links

The Spinngo platform does not contain links to external third-party websites. However, third-party services integrated into the platform — such as payment gateways and identity verification tools — operate under their own independent privacy policies. Spinngo is not responsible for the data practices of third-party service providers beyond the obligations imposed under our data processing agreements with them.

Where you interact with a third-party service accessed through the Spinngo platform, we recommend reviewing that provider's privacy documentation directly to understand how your data is handled at their end.

15. Amendments to This Privacy Policy

Spinngo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform functionality. Where material changes are made, we will notify registered Players via email or in-platform notification prior to the changes taking effect. The revised Policy will be posted on this page with an updated effective date.

We encourage you to review this Policy periodically. Your continued use of the Spinngo platform following notification of any changes constitutes acceptance of the revised Policy.

16. Contact Us & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Spinngo handles your personal data, please contact our Data Protection team through the following channels:

• Live Chat: Available 24/7 directly within the Spinngo platform.
• Email: [email protected]

We are committed to resolving all data-related queries and concerns promptly and fairly. If you are not satisfied with our response to a data-related complaint, you may have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction.