Privacy Policy — How Spin77 Protects Your Personal Data

1 Introduction

This Privacy Policy is published by Spin77 ("the Company", "we", "us", "our"), the operator of the online casino and sports betting platform accessible at https://spin77.click. This Policy governs the collection, processing, storage, and disclosure of personal data provided by users ("you", "the Player") in connection with your registration, use of our platform, and any communications with our support team.

Spin77 is committed to handling your personal information responsibly and in accordance with applicable data protection principles. This Policy applies to all users of the Spin77 platform, including players accessing from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and all other locations where the platform is made available.

By registering an account with Spin77, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, you should not register an account or use the Spin77 platform.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, alteration, or deletion.
• "Data Controller" means Spin77, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of Spin77 under a data processing agreement.
• "KYC Data" means identity and document verification information collected as part of the Know Your Customer process, including government-issued identification documents such as Malaysian IC (MyKad) or passport.
• "Transaction Data" means records of deposits, withdrawals, wagers, and all financial activity conducted through your Spin77 account, including payment method details.
• "Technical Data" means automatically collected information about your device and usage, including IP address, browser type, operating system, and session activity logs.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement to the processing of your Personal Data.

3 Personal Data We Collect

Spin77 collects Personal Data through several channels: directly from you during account registration and verification; automatically through your use of the platform; and from third-party payment providers and verification services where applicable. The categories of data we collect include:

4 Purpose of Processing

Spin77 processes your Personal Data only for clearly defined, legitimate purposes. The principal purposes for which we collect and use your information are as follows:

• Account Administration: To create, manage, and maintain your Spin77 account, including processing registrations, authenticating logins, and managing account settings.
• Identity Verification (KYC): To verify your identity and age (21+ requirement) in compliance with anti-money-laundering (AML) and responsible gambling obligations.
• Payment Processing: To facilitate deposits and withdrawals via your chosen payment method (Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, DuitNow, FPX, USDT TRC20) and to maintain accurate financial records.
• Platform Provision: To provide you with access to casino games, sports betting markets (EPL, Liga Super Malaysia, UFC, and others), live dealer tables, and all associated Platform features.
• Regulatory Compliance: To fulfil our legal obligations, including AML reporting, fraud prevention, responsible gambling monitoring, and cooperation with law enforcement agencies where legally required.
• Customer Support: To respond to your queries, complaints, and support requests submitted via live chat or email.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, multi-accounting, collusion, bonus abuse, and other prohibited conduct on the Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have given explicit consent or where permitted under applicable law.
• Platform Improvement: To analyse aggregated usage patterns and improve the functionality, performance, and user experience of the Spin77 Platform.

5 Legal Basis for Processing

Spin77 processes your Personal Data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions, including account management, payment processing, and Platform access.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML requirements, tax record-keeping, and regulatory reporting.
• Legitimate Interests: Processing carried out for our legitimate business interests, including fraud detection, Platform security, and service improvement — provided such interests are not overridden by your fundamental rights.
• Consent: Processing based on your freely given, informed consent — primarily for direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

Spin77 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We share your data only in the limited circumstances described below, and always subject to appropriate contractual safeguards:

• Payment Service Providers: We share Transaction Data with our payment partners (including processors supporting Touch 'n Go eWallet, Boost, GrabPay, Maybank FPX, CIMB, DuitNow, and USDT TRC20 networks) to facilitate deposits and withdrawals.
• Identity Verification Partners: KYC Data is shared with approved third-party identity verification service providers to fulfil our age verification and AML obligations.
• Game Providers: Where required by game mechanics or responsible gambling systems, certain gaming data may be shared with licensed game suppliers under data processing agreements.
• Regulatory Authorities: We may disclose Personal Data to regulatory bodies, law enforcement agencies, or courts where legally required or in response to a valid legal request.
• Fraud Prevention Services: Data may be shared with industry fraud prevention networks and databases to detect and prevent financial crime and prohibited conduct.
• Professional Advisers: Legal, financial, and compliance advisers engaged by Spin77 may access relevant Personal Data under strict confidentiality obligations.
• Business Successors: In the event of a merger, acquisition, or sale of assets, your Personal Data may be transferred to the successor entity, which will be bound by this Privacy Policy or an equivalent.

7 Data Retention

Spin77 retains your 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 following general retention periods apply:

• Account Data & KYC Documents: Retained for a minimum of 5 years from the date of account closure, in compliance with applicable anti-money-laundering regulations.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction for financial audit and regulatory compliance purposes.
• Gaming History: Retained for a minimum of 3 years for dispute resolution, responsible gambling monitoring, and regulatory compliance purposes.
• Support Communications: Retained for 2 years following the resolution of the relevant support interaction.
• Marketing Consent Records: Retained for the duration of your account and for 2 years following account closure or consent withdrawal.
• Technical Data & Server Logs: Retained for up to 12 months for security monitoring and fraud prevention purposes.

8 Data Security

Spin77 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:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the Spin77 Platform is encrypted using 256-bit SSL encryption.
• Access Controls: Internal access to Personal Data is restricted on a need-to-know basis. Staff with access to sensitive data are subject to confidentiality obligations and regular security training.
• Secure Data Storage: Personal Data and KYC documents are stored on encrypted servers with restricted physical and digital access controls.
• Multi-Factor Authentication (MFA): Available for player accounts and enforced for all internal staff access to systems containing Personal Data.
• Regular Security Audits: The Spin77 Platform undergoes regular penetration testing and security vulnerability assessments.
• Incident Response: Spin77 maintains a data breach response protocol. In the event of a security incident affecting your Personal Data, we will notify you and relevant regulatory authorities as required by applicable law.

While we implement robust security measures, no online transmission or storage system is entirely invulnerable. You are responsible for maintaining the security of your account credentials. If you suspect your account has been compromised, contact our support team immediately.

9 Cookies & Tracking Technologies

Spin77 uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session continuity, and collect Technical Data for security and analytics purposes. The categories of cookies we use include:

• Strictly Necessary Cookies: Required for the Platform to function. These cannot be disabled as they are essential for maintaining your login session, storing preferences, and ensuring platform security.
• Functional Cookies: Enable enhanced features such as remembering your language preferences, game history display settings, and personalised content layout.
• Analytics Cookies: Used to collect aggregated, anonymised information about how visitors interact with the Platform, enabling us to identify areas for improvement.
• Security Cookies: Support fraud detection and abuse prevention systems by identifying unusual access patterns or suspicious device behaviour.

You may configure your browser settings to refuse or delete cookies. Note that disabling strictly necessary cookies may impair your ability to use certain features of the Spin77 Platform, including maintaining your logged-in session.

10 Your Data Protection Rights

Subject to applicable law and any overriding legal obligations on Spin77's part, you hold the following rights in respect of your Personal Data:

• Right of Access: You may request a copy of the Personal Data Spin77 holds about you, together with information on how it is being used.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data held in your account.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal data retention obligations.
• Right to Restriction of Processing: You may request that we limit the processing of your Personal Data in certain circumstances, for example while a dispute is being investigated.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you may request a copy of your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing. If you object to marketing, we will cease processing your data for that purpose immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

11 Minors & Age Verification

The Spin77 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is a mandatory component of our KYC process, and accounts found to belong to individuals under 21 will be immediately suspended and closed.

If you are a parent or guardian and believe a minor has accessed the Spin77 Platform or provided their personal information without your consent, please contact us immediately at [email protected]. We will take prompt action to verify the situation, close any relevant account, and delete associated Personal Data.

12 International Data Transfers

In certain circumstances, your Personal Data may be transferred to and processed in countries outside Malaysia. This may occur when we engage third-party service providers (such as cloud hosting providers, identity verification platforms, or game suppliers) that operate infrastructure outside Malaysia.

Where such transfers occur, Spin77 ensures that appropriate safeguards are in place to protect your Personal Data to a standard at least equivalent to that required under applicable data protection law. These safeguards may include contractual data transfer agreements, standard contractual clauses, or the use of service providers in jurisdictions recognised as providing adequate data protection.

13 Third-Party Services

The Spin77 Platform may contain links to or integrations with third-party services, including payment gateways, game providers, and customer support tools. Spin77 is not responsible for the privacy practices of these third parties. We recommend reviewing the privacy policies of any third-party service you interact with in connection with your use of the Platform.

Third-party payment providers you interact with directly — including the operators of Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, DuitNow, and similar platforms — process payment data under their own privacy policies and are independently responsible for their data handling practices.

14 Policy Amendments

Spin77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or operational requirements. The "Last Updated" date at the top of this page will be revised accordingly.

Where amendments are material — for example, changes that significantly affect how we use your data or the rights available to you — we will provide notice to registered users via the email address associated with your account or through a prominent notification on the Platform. Your continued use of the Spin77 Platform following such notice constitutes acceptance of the revised Privacy Policy.

15 Contact Us & Data Enquiries

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or need to report a potential data security concern, please contact us through the following channels. All privacy-related enquiries are handled with priority by our compliance team.

For matters specifically relating to responsible gambling, self-exclusion tools, or deposit limit settings, please visit our dedicated Responsible Gambling page.