321spin Privacy Policy – How We Protect Malaysian Players' Personal Data

1. Introduction

321spin ("we", "the platform", or "321spin") respects the privacy rights of every individual who uses our services. This Privacy Policy explains how we collect, store, use, disclose, and protect your personal data when you register, log in, or use any part of the 321spin platform.

321spin offers online entertainment services to Malaysian players, including live casino, slots, Sports Betting (Super League, EPL, badminton, e-sports, and more), poker, roulette, and a wide range of other games. In providing these services, we process your personal data as described in this document.

This policy is drawn up in accordance with Personal Data Protection Act 2010 (PDPA) Malaysia and applicable international data protection standards. We are committed to ensuring your data is handled with full accountability, transparency, and security.

2. Personal Data We Collect

2.1 Data You Provide Directly

When you register or use the 321spin platform, you provide us with the following data:

• Identity Data: Full name, date of birth, identification number (MyKad) or passport
• Contact Data: Email address, Malaysian phone number, residential address
• Financial Data: Payment method details (TNG eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX), bank account numbers, and deposit and withdrawal transaction records in MYR
• Verification Data: Copies of KYC documents such as MyKad, utility bills, or bank statements
• Account Data: Username, password (stored in encrypted form), account preferences

2.2 Automatically Collected Data

When you use the 321spin platform, our systems automatically record:

• Device Data: Device type, operating system, phone model, screen resolution
• Network Data: IP address, internet service provider (ISP) name, location (state/city)
• Usage Data: Games played, bet amounts, session duration, transaction history
• Technical Data: Error logs, platform performance, response times
• Cookie Data: Session cookies, preference cookies, analytics identifiers (see Section 6)

3. How We Use Your Data

321spin uses your personal data for the following purposes, all of which are lawful under Malaysia's PDPA:

• Account Management: Creating, verifying, and managing your 321spin account
• Transaction Processing: Processing deposits via TNG eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX, and withdrawal of your winnings
• Legal Compliance: Meeting KYC, anti-money laundering (AML), and regulatory reporting obligations
• Platform Security: Detecting and preventing fraud, duplicate accounts, and suspicious activity
• Service Improvement: Understanding how players use the platform to continuously improve the user experience
• Communications: Sending transaction notifications, terms updates, and important information relating to your account
• Marketing (with consent): Sending promotional information, bonuses, and special offers – only where you have given your consent
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and offer appropriate assistance

4. Sharing Data With Third Parties

321spin does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. However, in the course of delivering our services, we may share data with the following parties:

4.1 Technology Service Providers

We work with trusted third-party providers to operate the 321spin platform — including cloud computing providers, platform analytics providers, and cybersecurity providers. All third parties are bound by strict confidentiality agreements and are only permitted to use your data for purposes directed by 321spin.

4.2 Payment Providers

To process your deposits and withdrawals, the necessary information is shared with relevant local Malaysian payment providers — including TNG eWallet, GrabPay, Boost, ShopeePay, DuitNow, and financial institutions supporting FPX. This sharing is limited strictly to what is needed to complete the transaction.

4.3 Regulatory Bodies & Authorities

321spin may be required to disclose player data to the relevant authorities in the following situations: court orders, criminal investigations including money laundering, or other regulatory compliance requirements. In such cases, 321spin will ensure that only the minimum necessary data is disclosed and will notify you if permitted to do so by law.

5. Data Security

321spin implements comprehensive technical and organisational measures to protect your personal data against unauthorised access, loss, or inadvertent disclosure:

• 256-bit SSL Encryption: All data transmitted between your device and 321spin's servers is encrypted using 256-bit SSL standards
• Stored Data Encryption: Sensitive data such as financial details is stored in encrypted form in our database
• Strict Access Controls: Only specifically authorised 321spin staff may access player data, and every instance of access is automatically logged
• 24/7 Monitoring: Our cybersecurity systems operate around the clock to detect suspicious activity
• Regular Audits: Independent security audits are conducted periodically by third-party cybersecurity firms

While we implement all reasonable measures, no security system is 100% impenetrable. If you suspect your 321spin account has been accessed without authorisation, please contact our support team immediately.

6. Use of Cookies

321spin uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions properly. The types of cookies we use are as follows:

You can manage or disable cookies through your browser settings. Please note that disabling essential cookies may affect the functionality of the 321spin platform. Marketing cookies can be turned off without impacting your gaming experience.

7. International Data Transfers

In certain circumstances, your personal data may be transferred to or stored on servers located outside Malaysia — in particular with cloud computing providers and international-grade game providers. When such transfers occur, 321spin ensures:

• The recipient country maintains an adequate level of data protection
• Appropriate data transfer agreements have been put in place
• Data is encrypted during transfer
• Your rights under Malaysia's PDPA are protected regardless of where processing takes place

8. Data Retention Period

321spin retains your personal data only for as long as required to fulfil the stated purpose or as mandated by law:

• Active Account Data: Retained for as long as your 321spin account remains active
• Financial Records: Retained for a minimum of 7 years after the transaction (anti-money laundering legal requirement)
• KYC Records: Retained for 5 years after account closure
• Usage Logs: Retained for 2 years for security and audit purposes
• Marketing Data: Deleted within 30 days of your consent withdrawal

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

9. How to Exercise Your Rights

To exercise any of the rights outlined in this Privacy Policy, you may:

• Log in to your 321spin account and navigate to the "Privacy Settings" section
• Contact our Data Privacy Officer (DPO) by email at privacy@321spin.bet
• Submit a written request via live chat on the 321spin platform

321spin will process your request within 30 working days. For more complex cases, this period may be extended by up to 60 days with advance notice to you. No fee is charged for the first request made within a year; excessive additional requests may be subject to a reasonable fee.

10. Children's Privacy

The 321spin platform is not intended for use by individuals under 21 years of age. We do not knowingly collect personal data from minors. If you believe that an underage individual has created an account on 321spin, please contact us immediately at support@321spin.bet and we will investigate and delete the account along with all associated data.

11. Privacy Policy Amendments

321spin reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, evolving legal requirements, or new technological developments. The "Effective Date" at the top of this document will be updated whenever an amendment is made.

For significant amendments, we will notify you via your registered email or through a prominent in-platform notification on 321spin before the changes take effect. Continued use of the platform following such notification will be considered acceptance of the revised Privacy Policy.

12. Contact Us & Data Privacy Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please contact us at:

• 321spin Data Privacy Officer (DPO): privacy@321spin.bet
• General Support: support@321spin.bet
• Live Chat: Available on the 321spin platform, 24/7

We are committed to addressing all privacy-related enquiries seriously and within a reasonable timeframe. If you are not satisfied with our response, you have the right to lodge a complaint with Malaysia Personal Data Protection Department under the PDPA 2010.