Privacy Policy

spin99c ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of every individual who interacts with our services. This Privacy Policy ("Policy") sets out the basis on which we collect, process, store, and share personal data obtained from players, registered account holders, and visitors to https://spin99c.cam (the "Website").

This Policy applies to all personal data processed by spin99c in connection with the operation of our online casino, sports betting, and related services targeting the Malaysian market. It applies whether you access our services from Kuala Lumpur, Penang, Johor Bahru, Shah Alam, Petaling Jaya, or any other location.

By registering an account on spin99c, making a deposit, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy, and you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

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

• "Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject"), including but not limited to name, identification number, contact details, financial information, and behavioural data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, spin99c.
• "Data Processor" means any third party that processes Personal Data on behalf of spin99c.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the processing of their Personal Data.
• "KYC" means Know Your Customer — the identity and age verification process mandated by our licensing obligations.
• "Cookie" means a small text file placed on your device by a website to store information about your browsing session, preferences, and activity.
• "Player" / "User" / "you" means any registered account holder or visitor to the spin99c Platform.

spin99c is the Data Controller responsible for the Personal Data collected through the spin99c Platform. As Data Controller, we determine the purposes for which Personal Data is collected and the manner in which it is processed.

For the purposes of this Policy, all references to "spin99c", "we", "us", and "our" refer to the operating entity behind the spin99c brand, which holds the applicable gaming licence under which the Platform operates. Our designated data protection contact can be reached via the channels listed in Section 17 of this Policy.

Where spin99c engages third-party service providers (including payment processors, game providers, and analytics platforms) to process Personal Data on our behalf, those parties act as Data Processors and are required to handle data in accordance with this Policy and applicable data protection law.

spin99c collects the following categories of Personal Data in the course of providing its services:

• Full legal name as stated on your government-issued identification document
• Date of birth (for age verification — players must be 21 or older)
• Malaysian Identity Card (MyKad) number, Passport number, or Driver's Licence number
• Residential address (street, city, postcode, state)
• Email address
• Mobile telephone number
• Selfie photograph submitted for identity verification purposes

• Deposit and withdrawal transaction records, including amounts, dates, and payment method used
• Bank account details or e-wallet account references (Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, DuitNow, FPX) submitted for payment processing
• Cryptocurrency wallet addresses used for USDT TRC20 or BTC transactions
• Transaction history within the spin99c Account

• Game history, bet records, wager amounts, and outcomes
• Sports betting selections, including markets wagered (EPL, Liga Super Malaysia, UFC, etc.)
• Bonus and promotion claims and wagering progress
• Session duration, login timestamps, and activity logs
• Responsible gambling settings, limits, and self-exclusion records

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Unique device identifiers
• Referring URL and navigation path through the Website
• Cookie and session data (see Section 10)

• Records of communications between you and our customer support team via live chat and email
• Feedback, complaints, and dispute records
• Marketing preference records and communication opt-in/opt-out history

spin99c collects only the minimum Personal Data necessary for the purposes described in this Policy. We do not knowingly collect special category data (such as racial or ethnic origin, political opinions, or health information) except where required for responsible gambling assessment, in which case it is handled with additional care and strict access controls.

spin99c collects Personal Data through the following means:

The majority of your Personal Data is provided by you directly when you: register an account; complete KYC identity verification; make a deposit or withdrawal; contact customer support; respond to a survey or promotion; or update your account profile.

As you use the Platform, spin99c automatically collects technical and behavioural data through server logs, cookies, web beacons, pixel tags, and similar technologies. This includes your IP address, session data, page views, click paths, and device information. See Section 10 for details on our cookie practices.

In limited circumstances, spin99c may receive Personal Data from third parties, including: payment processors who confirm transaction details; identity verification services used for KYC; fraud detection and anti-money laundering screening services; and game providers who report game session data to us for account management purposes.

spin99c processes your Personal Data for the following purposes:

spin99c will not use your Personal Data for any purpose other than those listed above without your prior consent, unless required to do so by law.

spin99c relies on the following legal bases when processing your Personal Data:

• Contract Performance: Processing is necessary to deliver the services you have contracted for — including account management, payment processing, and game access.
• Legal Obligation: Certain processing is required to comply with applicable laws, including KYC, AML, and responsible gambling regulations imposed by our licensing authority.
• Legitimate Interests: We process certain data to pursue our legitimate business interests, including fraud prevention, platform security, and service improvement — provided these interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent — for example, to send you promotional emails or push notifications — you may withdraw that consent at any time by contacting support or updating your communication preferences in your Account settings. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

spin99c does not sell, rent, or disclose your Personal Data to third parties for their own marketing purposes. We share data only in the circumstances described below, and only to the extent necessary for the stated purpose:

We engage third-party service providers to support the operation of the Platform. These include payment processors (such as the operators of Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank, DuitNow, and FPX integrations), KYC and identity verification services, IT infrastructure and cloud hosting providers, fraud detection platforms, customer support tools, and analytics providers. All such providers are contractually required to process data solely on our instructions and to maintain appropriate security standards.

Game providers whose software is hosted on the spin99c Platform may receive session data (such as player ID, bet amounts, game results, and timestamps) necessary for game operation, RNG auditing, and dispute resolution. Game providers do not receive identity documents or full financial records.

spin99c may disclose Personal Data to our gaming licensing authority, financial intelligence units, tax authorities, or law enforcement agencies where required to do so by applicable law, court order, regulatory directive, or where spin99c reasonably believes disclosure is necessary to prevent crime, protect the safety of individuals, or comply with a legal obligation.

In the event that spin99c undergoes a merger, acquisition, asset sale, or restructuring, Personal Data held by spin99c may be transferred to the successor entity as part of that transaction. Affected players will be notified in accordance with this Policy and applicable law.

spin99c retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, to meet our legal and regulatory obligations, and to resolve disputes or enforce our agreements.

The following general retention periods apply:

• Active account data: Retained for the duration of your active Account relationship with spin99c.
• KYC identity documents: Retained for a minimum of five (5) years following account closure, in accordance with applicable AML regulations.
• Financial and transaction records: Retained for a minimum of seven (7) years following the transaction date, as typically required for financial record-keeping purposes.
• Customer support communications: Retained for three (3) years from the date of the last interaction, unless retention is required for ongoing dispute resolution or compliance purposes.
• Marketing preference and consent records: Retained for the duration of your Account and for three (3) years following account closure or consent withdrawal.
• Self-exclusion records: Retained for a minimum of seven (7) years to prevent circumvention of exclusion commitments.

When Personal Data is no longer required for any lawful purpose, spin99c will securely delete or anonymise it in accordance with our data lifecycle procedures.

spin99c uses cookies and similar tracking technologies to operate and improve the Platform, personalise your experience, and for security monitoring purposes. By using the Platform, you consent to our use of cookies in accordance with this section.

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies, authentication tokens, and security cookies. You cannot opt out of these cookies without stopping use of the Platform.
• Functional Cookies: Remember your preferences — such as language settings, preferred payment method, and responsible gambling limits — to provide a more personalised experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate the Platform, which pages are visited most, and where errors occur. This data is used exclusively to improve the Platform and does not identify individual users.
• Security Cookies: Used to detect and prevent fraudulent activity, including session hijacking, bot access, and unusual account behaviour. These are an integral part of our player protection infrastructure.

You may control non-essential cookie categories through your browser settings. Most modern browsers allow you to refuse cookies, delete existing cookies, and receive warnings before cookies are stored. Disabling certain cookies may affect the functionality of the Platform — for example, disabling functional cookies may mean your preferences are not remembered between sessions. Disabling security cookies is not recommended and may result in heightened security checks on your Account.

spin99c takes the security of your Personal Data seriously and has implemented technical and organisational measures designed to protect it against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the spin99c Platform is encrypted using industry-standard TLS protocols. Look for the padlock icon in your browser's address bar when using the Platform.
• Data Encryption at Rest: Sensitive personal and financial data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Personal Data is accessible only to authorised spin99c personnel who require it to perform their duties. Access is managed through role-based controls and multi-factor authentication.
• Regular Security Audits: Our infrastructure undergoes regular penetration testing and security audits by independent third-party specialists.
• Real-Time Fraud Monitoring: Automated systems monitor all transactions and account activities for suspicious patterns, with human review escalation for flagged events.
• Secure Document Handling: KYC documents are stored in an access-restricted, encrypted document management system separate from the main Platform database.

Despite our best efforts, no system is entirely immune to security threats. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, spin99c will notify affected individuals without undue delay, in accordance with applicable data protection law.

You are also responsible for maintaining the security of your Account. Please use a strong, unique password, do not share your login credentials, and notify us immediately if you suspect unauthorised access to your Account.

spin99c operates a globally distributed technology infrastructure, which means that your Personal Data may be transferred to, stored in, or processed in countries outside of Malaysia. This may include countries where data protection laws differ from those applicable in Malaysia.

Where we transfer Personal Data outside of Malaysia, we take steps to ensure that appropriate safeguards are in place to protect your data. These safeguards may include:

• Contractual data processing agreements incorporating internationally recognised data protection clauses with all third-party processors.
• Restricting transfers to jurisdictions that maintain an adequate level of data protection as assessed by our legal and compliance team.
• Implementing technical security measures (encryption, pseudonymisation) for all cross-border data flows.

By using the spin99c Platform, you acknowledge and consent to the transfer of your Personal Data to other jurisdictions where spin99c or its service providers operate, subject to the safeguards described in this section.

Subject to applicable law and certain exceptions, you have the following rights in relation to your Personal Data held by spin99c. To exercise any of these rights, please contact us using the details in Section 17.

spin99c will respond to verified data rights requests within thirty (30) days of receipt. We may need to verify your identity before processing a request. Where requests are complex or numerous, we may extend this period by a further thirty (30) days, notifying you of the extension in advance.

Please note that certain rights are subject to limitations. For example, the right to erasure does not apply where spin99c is required to retain data to comply with a legal obligation (such as AML record-keeping requirements), or where data is needed to establish, exercise, or defend legal claims.

The spin99c Platform is strictly intended for adults aged 21 years and above. spin99c does not knowingly collect or process Personal Data from individuals under the age of 21. Our KYC verification process is specifically designed to identify and exclude underage users before they can access real-money gaming services.

If you are a parent or guardian and believe that a person under 21 years of age has registered an account on the Platform or provided personal data to us without your consent, please contact us immediately at the details provided in Section 17. Upon verification, spin99c will promptly close the account, erase or anonymise the associated data where legally permissible, and return any deposits that were made.

The spin99c Platform may contain references to third-party services, including payment method providers such as Touch 'n Go eWallet, Boost, GrabPay, Maybank, and DuitNow, whose services operate under their own terms of service and privacy policies. spin99c is not responsible for the privacy practices or content of any third-party platform or service.

When you leave the spin99c Website to access a third-party payment gateway or service, you are subject to the privacy policy of that third party. We recommend reviewing the privacy policy of any third-party service before providing your personal information to it.

spin99c does not include external third-party advertising links on the Platform. Any links displayed are for navigation to spin99c's own services and informational resources only.

spin99c reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or the nature of our services. The most current version of this Policy is always available at https://spin99c.cam/privacy-policy.

When material changes are made to this Policy, spin99c will notify active registered Players by posting a prominent notice on the Platform and, where feasible, by sending a notification to your registered email address. We encourage you to review this Policy periodically to remain informed about how we protect your data.

Your continued use of the Platform following the effective date of any amended Policy constitutes your acceptance of the revised terms. If you do not agree with a material change, you must stop using the Platform and contact support to arrange account closure.

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have a concern about how spin99c has handled your Personal Data, please contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week through the Platform interface. This is the fastest way to reach us for time-sensitive data requests.
• Email: [email protected] (plain text — not a clickable link). Please mark the subject line clearly: "Privacy Request — [Your Request Type]".
• Response Time: We aim to acknowledge all privacy-related enquiries within five (5) business days and provide a substantive response within thirty (30) days.
• Support Language: English. Aligned to Malaysian Time (MYT, GMT+8).

If you are dissatisfied with our response to a data protection concern, you have the right to escalate your complaint to the relevant data protection authority or regulatory body in your jurisdiction. spin99c will cooperate fully with any such regulatory investigation or enquiry.

We take all privacy complaints seriously and will investigate each one thoroughly. Where a complaint reveals a breach of this Policy or applicable law, we will take prompt remedial action and notify the affected individual of the outcome.