Spin 99 Privacy Policy – Our Commitment to Protecting Your Personal Data in Malaysia

This Privacy Policy is published by Spin 99 ("we", "platform") and applies to all users of the Spin 99 platform at spin99.wine ("you", "member"). This Policy provides a comprehensive explanation of how Spin 99 manages your personal data in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA).

Spin 99 is an online betting platform serving Malaysian players. We understand that your trust in us depends not only on the quality of our games and services, but also on how we respect and safeguard the personal information you entrust to us.

By registering for or using the Spin 99 platform, you agree to the terms of this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the platform and contact us to close your account.

Spin 99 collects your personal data through several channels — directly when you register or use the platform, automatically via tracking technologies, and occasionally from licensed third-party sources. The categories of data we collect are as follows:

We only collect data that is strictly necessary to deliver Spin 99's services effectively and securely. We do not collect irrelevant or excessive data.

Spin 99 uses your personal data on lawful legal bases in accordance with the PDPA 2010. The following are the primary purposes for which your data is used:

• Account Management: Creating, verifying, and managing your Spin 99 account, including the KYC process and age verification (minimum 21 years old).
• Transaction Processing: Processes deposits and withdrawals in MYR via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX (Maybank2u, CIMB Clicks).
• Service Provision: Gives you access to all Spin 99 games, including slots, live casino, Sports Betting (Malaysia Super League football, EPL, badminton), virtual sports, and e-sports.
• Platform Security: Detecting and preventing fraud, money laundering, and multiple account usage.
• VIP Programme & Bonuses: Manages your participation in the Spin 99 VIP programme and ensures bonuses are distributed correctly.
• Service Communications: Sending account notifications, transaction updates, policy changes, and security information.
• Marketing Communications: With your consent only — sending information about Spin 99 promotions, bonuses, and the latest offers.
• Platform Improvements: Analysing usage patterns to enhance the user experience and platform performance.
• Legal Compliance: Fulfilling our obligations under the PDPA 2010, Malaysia's AML laws, and directives from competent authorities.

Spin 99 operates on a "need-to-know" principle when it comes to data sharing. We do not sell or rent your personal data to third parties. Your data is shared only under the following limited circumstances:

• Payment Service Providers: Required transaction information is shared with licensed payment providers such as Touch 'n Go eWallet, GrabPay, and the FPX network to process your MYR deposits and withdrawals.
• Game Providers: Minimum technical details required are shared with licensed game providers to enable access to slots, Live Casino, and Sports Betting.
• KYC Service Providers: Your identity information may be verified through a licensed third-party identity verification service that complies with PDPA standards.
• Malaysian Authorities: We will disclose your data to Malaysian authorities (including the police, courts, and financial regulators) when required by law or a valid court order.
• Business Transfers: In the event that Spin 99 is involved in a merger, acquisition, or asset sale, user data may be transferred as part of that process. You will be notified in advance.

All third parties who receive your personal data from Spin 99 are bound by strict confidentiality and data protection obligations, in accordance with Malaysia's PDPA 2010.

The security of your personal data is a top technical priority at Spin 99. We implement comprehensive technical and organisational measures to protect your data from unauthorised access, loss, destruction, or accidental disclosure.

Our technical security measures include:

• Data encryption in transit using 256-bit SSL/TLS protocol
• Encryption at rest for sensitive information
• Role-based access control (RBAC) — only authorised staff may access personal data
• Intrusion detection system (IDS) and continuous 24/7 monitoring
• Regular penetration testing by independent security experts
• Secure, encrypted data backups stored at separate locations
• Two-factor authentication (2FA) for internal access to systems containing personal data

Data Retention Period: Spin 99 retains your personal data for as long as your account remains active or as long as necessary to provide our services. Financial transaction records are kept for a minimum of 7 years in accordance with Malaysia's AML legal requirements. Once the retention period expires, data is securely deleted.

Spin 99 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device by your browser when you visit spin99.wine.

You can manage cookie usage through your browser settings. Please note, however, that disabling essential cookies may affect core Spin 99 platform functions, including login and transaction processing.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data held by Spin 99:

As an online platform, your personal data may be processed by our service providers operating outside Malaysia — for example, international game providers or cloud computing services.

When your personal data is transferred outside Malaysia, Spin 99 ensures that protections equivalent to or exceeding those under PDPA 2010 are applied through:

• Legally binding data transfer agreements with overseas service providers
• Selection of service providers that comply with internationally recognised data protection standards
• Additional technical measures such as data encryption prior to transfer

Spin 99 does not transfer your personal data to countries without adequate data protection unless we have your explicit consent or are required to do so by law.

The Spin 99 platform is exclusively for users aged 21 and above. We do not knowingly collect or process the personal data of children or individuals below the stipulated age limit.

Should we discover that personal data belonging to an individual under the age of 21 has been collected without valid consent, we will take immediate steps to delete that data and close the account in question. Any deposits made will be refunded once the verification process is complete.

If you believe a minor is using the Spin 99 platform, please contact us immediately at support@spin99.wine.

Spin 99 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other relevant factors.

When material changes are made to this policy, we will:

• Updating the "Last Updated" date at the top of this page
• Sending email notifications to all registered Spin 99 members at least 14 days before the changes take effect
• Displaying in-platform notices to inform members of important changes

Continued use of the Spin 99 platform after the effective date of any policy amendment constitutes acceptance of the revised terms. You are encouraged to review this page periodically.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how Spin 99 handles your personal data, our team is here to help:

Spin 99 is committed to addressing all privacy-related enquiries seriously and in a timely manner. If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP) in accordance with the provisions of PDPA 2010.