SpinLah Privacy Policy – Malaysian Player Data Protection

SpinLah ("we", "platform") respects the privacy of every individual who uses our services. This Privacy Policy describes our practices regarding the collection, use, disclosure, and protection of your personal data when you access or use the SpinLah platform at spinlah.net.

This Privacy Policy applies to all registered spinlah members, visitors to our website, and anyone who interacts with our platform through any channel, including the website, mobile app, and email communications.

SpinLah acts as the data controller of your personal data under Malaysia's Personal Data Protection Act 2010 (PDPA). This means we are responsible for ensuring your personal data is processed in a lawful, fair, and transparent manner at all times.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at support@spinlah.net. We are committed to responding to all privacy-related enquiries within 5 business days.

SpinLah only collects the personal data necessary to deliver our services safely and efficiently. Below are the categories of data we collect:

We do not collect sensitive data such as health information, political views, or religious beliefs unless specifically required to meet legal or responsible gambling obligations.

The personal data we collect is used solely for legitimate purposes directly related to spinlah's services. The following are the primary purposes for which your data is used:

• Identity verification and KYC – To verify that you are who you claim to be and that you meet spinlah's eligibility requirements, including the minimum age of 18.
• Transaction processing – Processing deposits via Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow, and FPX, as well as managing withdrawals to your Malaysian bank account.
• Account management – Creating and managing your SpinLah account, processing logins, and keeping your account secure.
• Customer support – Answering your questions, resolving technical issues, and providing the support you need via live chat or email.
• Marketing communications – Sending you promotions, bonus offers, and platform updates, subject to the communication preferences you have set.
• Fraud prevention – To identify and prevent fraudulent activity, money laundering, or misuse of the platform.
• Responsible gambling – Monitoring gameplay patterns to identify signs of problem gambling and offering appropriate support.
• Platform improvements – Analysing usage data to improve user experience, platform performance, and SpinLah's game offerings.

Spinlah will not use your data for any other purpose without first obtaining your consent.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), SpinLah processes your personal data on one or more of the following legal bases:

• Consent – You have given explicit consent for your data to be processed for a specific purpose, such as receiving marketing communications from SpinLah.
• Contractual fulfilment – Processing is necessary to fulfil the contract between you and spinlah, such as processing deposits and withdrawals.
• Legal obligation – spinlah is required to process certain data to comply with Malaysian law, including Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements.
• Legitimate interest – Processing is necessary for the legitimate interests of spinlah or a third party, such as fraud prevention and platform security, provided those interests do not override your fundamental rights.

For every data processing purpose, SpinLah ensures a solid and valid legal basis is in place. If you would like to know the specific legal basis applied to any processing activity, please contact us at support@spinlah.net.

Spinlah does not sell, rent, or trade your personal data to any third party for their own marketing purposes. However, we may share your data with the following parties under limited and controlled circumstances:

• Payment service providers – Includes Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX partner banks for the purpose of processing your financial transactions.
• Technology service providers – Companies that support the technical operations of the spinlah platform, such as cloud hosting, email delivery services, and analytics tools, all of which are bound by strict confidentiality agreements.
• KYC and identity verification providers – Third parties who assist us in verifying member identities as part of our legal compliance process.
• Authorities and regulatory bodies – Where required by Malaysian law or a valid court order, SpinLah will disclose the necessary data to law enforcement agencies or regulatory bodies.
• Dispute resolution – In the event of a legal dispute, relevant data may be disclosed to the parties involved or the applicable arbitration tribunal.

SpinLah applies robust technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL Encryption – All data transmitted between your web browser and SpinLah's servers is protected with industry-standard 256-bit SSL/TLS encryption.
• Two-factor authentication (2FA) – Members are encouraged to enable two-factor authentication for an added layer of security when logging in.
• Internal access controls – Only SpinLah staff who require access to your data for their authorised work purposes are permitted to do so, and all access is logged and monitored.
• Encrypted password storage – Your account password is stored in hashed form and cannot be reversed to its original state, keeping your password secure even in the event of a data breach.
• Continuous security monitoring – SpinLah's systems are monitored 24/7 to detect any suspicious activity or unauthorised access attempts.
• Regular security audits – spinlah conducts regular security audits and penetration testing to identify and address any vulnerabilities in our systems.

While SpinLah takes all reasonable steps to protect your data, no data transmission over the internet can be guaranteed to be 100% secure. You are also responsible for safeguarding your login credentials and the devices you use to access SpinLah.

SpinLah retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or to comply with applicable legal requirements:

• Active account data – For as long as your SpinLah account remains active, your personal data will be retained so we can continue providing services to you.
• After account closure – Financial transaction data and KYC records are retained for a minimum of 7 years after account closure to meet Malaysia's AML and tax reporting legal requirements.
• Communication logs – Customer support records and communications are retained for 3 years for reference and dispute resolution purposes.
• Analytics data – Anonymised usage data may be retained for longer periods for platform improvement purposes, without being linked back to your identity.

Once the retention period expires, your data will be securely deleted or anonymised so that it can no longer be linked to you.

SpinLah uses cookies and similar tracking technologies to enhance user experience and understand how our platform is used. The following are the types of cookies we use:

• Essential cookies – Required for core platform functions such as login and session security. These cookies cannot be disabled without affecting platform functionality.
• Performance cookies – Collects information on how you use the SpinLah platform to help us improve performance and usability.
• Functional cookies – Saving your preferences such as language, display settings, and location to deliver a more personalised experience.
• Analytics cookies – Used by analytics tools to analyse aggregated usage patterns and help us make data-driven decisions.

You can manage your cookie preferences through your web browser settings. However, disabling certain cookies may affect the functionality of the SpinLah platform. For more information on managing cookies, refer to your web browser's documentation.

As a data subject, you have certain rights under Malaysia's Personal Data Protection Act 2010 (PDPA) regarding your personal data held by SpinLah:

• Right of Access – You have the right to obtain a copy of the personal data we hold about you. Data access requests can be submitted by emailing support@spinlah.net.
• Right to rectification – If your personal data is inaccurate or incomplete, you have the right to request that we correct it.
• Right to withdraw consent – You may withdraw your consent to data processing at any time, though this may affect our ability to provide certain services.
• Right to object to direct marketing – You may opt out of marketing communications from spinlah at any time by clicking the "unsubscribe" link in our emails or by contacting customer support.
• Right to complain – If you believe spinlah has violated your privacy rights, you are entitled to lodge a complaint with the Department of Personal Data Protection Malaysia.

To exercise any of the above rights, please submit a written request to support@spinlah.net. SpinLah will process your request within 21 business days in accordance with PDPA requirements.

SpinLah takes the protection of children and minors very seriously. The SpinLah platform is strictly for individuals aged 18 and above.

We do not knowingly collect or process personal data from individuals under the age of 18. If you believe we have inadvertently collected data from a minor, please notify us immediately at support@spinlah.net and we will take immediate action to delete that data.

If you are a parent or guardian and discover that your child has registered on SpinLah, please contact us immediately. We will close the account and delete all associated data without delay.

SpinLah reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological developments.

When we make material changes to this Privacy Policy, we will notify you via:

• A prominent notice on the SpinLah website homepage
• Email notification to registered members
• Updating the "Last Updated" date at the top of this page

Your continued use of the SpinLah platform after any changes take effect constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how spinlah handles your personal data, we are here to listen and help.

• Email: support@spinlah.net
• Response time: We aim to respond to all privacy-related enquiries within 5 business days
• Formal complaint: If you are not satisfied with our response, you may submit a complaint to the Department of Personal Data Protection Malaysia

SpinLah values the trust you place in us with your personal data. We are committed to ensuring your privacy is fully protected across every aspect of the SpinLah platform's operations.