Privacy Policy spin999 — Your Data, Your Rights, Our Protection

01Introduction

Spin999 ("we", "Platform") takes the privacy of every user seriously. This Privacy Policy explains in detail how spin999 collects, processes, stores, and protects your personal information when you use the spin999 website, mobile app, or any of its services.

We operate in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA). This means every action we take involving your personal data has a valid legal basis and is carried out with full respect for your privacy rights as an individual.

The term "personal data" in this document refers to any information that can be used to identify you directly or indirectly — including your name, identity card number, address, phone number, email address, and financial information.

02Data We Collect

Spin999 only collects data that is strictly necessary to provide you with a quality and secure service. The following are the categories of data we collect:

Data We Do Not Collect

Spin999 never collects data unrelated to the provision of our services, including sensitive data such as medical information, political views, or religious beliefs, unless specifically required by applicable law.

03How We Use Your Data

Data collected by spin999 is used exclusively for the following legitimate and clearly stated purposes:

• Identity verification and KYC: To verify that all members meet the age eligibility requirements and to prevent identity fraud.
• Financial transaction processing: Deposits and withdrawals require financial information to be processed accurately and securely.
• Customer support provision: spin999 support agents use your account data to resolve inquiries and issues more efficiently.
• Account security: Technical data such as IP addresses and device information is used to detect suspicious login activity.
• Legal compliance: spin999 is required by law to retain certain transaction records and to provide reports to the relevant authorities when required.
• Platform improvements: Anonymized usage data helps the spin999 development team understand usage patterns and improve the overall user experience.
• Account-related communications: Security notifications, terms updates, and transaction information are sent to your registered email or phone number.

04Data Sharing with Third Parties

Spin999 does not sell or trade your personal data. However, in the course of platform operations, there are certain situations where data may need to be shared with specific parties:

• Payment service providers: Providers such as FPX, Touch 'n Go eWallet, Boost, and other payment providers receive the information required to process your transactions.
• KYC service providers: Third parties conducting identity verification receive KYC documents submitted through our platform.
• Legal authorities: When required by court order or applicable laws and regulations in Malaysia.
• Cloud service providers: The spin999 server infrastructure is operated by internationally accredited cloud service providers that comply with the highest security standards.

All third parties who receive your data are bound by strict confidentiality agreements and are required to comply with data protection standards that match or exceed those of spin999.

05Data Security

Protecting your data is spin999's highest technical and organisational priority. We implement multiple layers of security measures to ensure your data remains protected at all times:

• 256-bit SSL/TLS encryption: All data communications between your device and our servers are encrypted using the latest protocols.
• Two-factor authentication (2FA): Account login and sensitive actions such as withdrawals require OTP verification via your registered phone number.
• 24/7 continuous monitoring: Our AI system monitors account activity around the clock to detect suspicious patterns or unauthorised access.
• Internal access controls: Only staff with a legitimate need are permitted to access user data, and all access is automatically audited.
• Regular security audits: Penetration testing is conducted periodically by independent security experts to identify and address vulnerabilities.

While spin999 takes all reasonable steps to protect your data, no system can be guaranteed 100% secure. We encourage you to take your own precautions as well, such as using a strong password and never sharing your login credentials with anyone.

06Cookies & Tracking Technologies

Spin999 uses cookies and similar tracking technologies to enhance the user experience and ensure platform security. The following are the types of cookies we use:

• Session cookies: Required to maintain your login session while browsing the platform. These cookies are automatically removed when you close your browser.
• Preference cookies: Storing your preferences such as language and theme to deliver a more personalised experience.
• Analytics cookies: Collecting anonymised usage data to help us understand how members interact with the platform and where improvements are needed.
• Security cookies: Helps detect fraudulent activity and ensures only you can access your account.

You can manage your cookie settings through your web browser. Please note that disabling certain cookies may affect the functionality of some parts of the spin999 platform.

07Your Rights Regarding Personal Data

As a spin999 member and data subject under Malaysia's PDPA, you have the following rights regarding your personal information:

08Data Retention Period

Spin999 retains your personal data only for as long as it is needed for the purposes stated in this policy, or as required by applicable Malaysian law.

• Active account data: Retained for the entire period your account is active and in use.
• Financial transaction records: Retained for a minimum of 7 years in accordance with Malaysia's financial and tax regulatory requirements.
• KYC Documents: Retained for the duration of membership and 5 years after account closure in accordance with anti-money laundering requirements.
• Security logs: Retained for 2 years for security incident investigation purposes if required.
• Closed account data: Deleted or anonymized after all mandatory retention requirements have been fulfilled.

09Child Data Protection

The spin999 platform is strictly for users aged 18 and above. spin999 does not knowingly collect or process personal data from anyone under the age of 18.

If we discover that personal data from a minor has been collected unknowingly, we will take immediate action to delete that data and close the account in question. Parents or guardians who suspect their child has registered on the spin999 platform are encouraged to contact our support team immediately.

10Privacy Policy Amendments

Spin999 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in law, industry practices, or the way we operate the platform. When material amendments are made, we will:

• Updating the "Last Updated" date at the top of this document.
• Sending notifications to members via email or in-platform notifications for significant changes.
• For major amendments, members may be asked to provide fresh consent before the changes take effect.

We encourage you to review this Privacy Policy page periodically to stay informed about how we protect your information.

11Contact Us About Privacy

If you have any questions, concerns, or complaints regarding this Privacy Policy or how spin999 handles your personal data, please contact us through the following methods:

We are committed to responding to all privacy-related inquiries within 5 business days, and to resolving data rights requests within 30 business days in line with Malaysia's PDPA.