spade66 Privacy Policy

spade66 ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of all members and visitors who access the spade66 platform at spade66.club. This Privacy Policy ("Policy") describes how spade66 collects, uses, stores, discloses, and otherwise processes personal data in connection with the operation of the Platform.

This Policy applies to all personal data processed by spade66 in connection with your use of the Platform, including account registration, gaming activity, financial transactions, customer support interactions, and marketing communications. It should be read in conjunction with the spade66 Terms & Conditions, which governs your overall use of the Platform.

By registering an account on spade66 or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform immediately.

For the purposes of applicable data protection legislation, spade66 acts as the data controller in respect of personal data processed in connection with the Platform. As data controller, spade66 determines the purposes and means of processing your personal data and bears primary responsibility for ensuring that processing is carried out in accordance with applicable law.

For all privacy-related enquiries, requests to exercise data subject rights, or concerns regarding the processing of your personal data, please contact the spade66 Data Protection contact via the details set out in Section 15 of this Policy.

spade66 collects the following categories of personal data from members and Platform visitors:

spade66 does not collect or process special categories of personal data (such as health data, biometric data, or political opinions) unless specifically required by law or consented to explicitly by you.

spade66 collects personal data through the following means:

• Direct Interactions: Data you provide directly when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or updating your account profile.
• Automated Technologies: Technical data collected automatically when you access the Platform, including IP address, device identifiers, browser information, and session activity logs, via server logs, cookies, and similar tracking technologies.
• Third-Party Sources: Identity and fraud screening data from licensed identity verification providers and payment processors used to verify your identity and prevent financial crime in accordance with regulatory requirements.
• Payment Providers: Transaction confirmation data from Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank, and other payment partners used to verify deposit and withdrawal status.

spade66 processes personal data on the following legal bases, depending on the purpose of the processing:

• Contractual Necessity: Processing required to perform the contract between you and spade66, including operating your account, processing transactions, and providing gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) obligations, know-your-customer (KYC) requirements, age verification, and responsible gaming regulations.
• Legitimate Interests: Processing carried out for spade66's legitimate business interests where those interests are not overridden by your rights — for example, fraud prevention, platform security, and improving the quality of the Platform.
• Consent: Processing based on your specific, informed, and freely given consent — for example, sending you promotional marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

spade66 uses the personal data we collect for the following purposes:

• To register and maintain your spade66 member account and verify your identity in accordance with KYC requirements.
• To process deposits, withdrawals, and gaming transactions in Malaysian Ringgit (MYR) and provide accurate account balance information.
• To detect, investigate, and prevent fraud, money laundering, identity theft, and other prohibited conduct on the Platform.
• To enforce the spade66 Terms & Conditions, including the prohibition on underage gambling and multi-accounting.
• To administer responsible gaming tools including deposit limits, self-exclusion, and cool-off periods, and to monitor gaming behaviour for signs of problem gambling.
• To provide customer support and resolve account-related enquiries, complaints, and disputes.
• To send transactional communications, including deposit confirmations, withdrawal notifications, and account security alerts.
• To send promotional and marketing communications where you have provided consent or where permitted by applicable law, including offers, bonuses, and platform news relevant to Malaysian players.
• To improve the Platform, develop new features, and conduct internal analytics to understand how members use spade66 services.
• To comply with applicable legal and regulatory obligations, including responding to lawful requests from regulatory authorities.

spade66 does not sell your personal data to third parties. We share personal data only where necessary and with appropriate safeguards in place, and only with the following categories of recipients:

• Payment Processors: Touch n Go eWallet, Boost, and Malaysian banking institutions (Maybank, CIMB, Public Bank) to process your financial transactions. These providers process data as data processors under contract with spade66.
• Identity Verification Providers: Licensed KYC and AML screening service providers used to verify your identity and screen against financial crime databases, as required by applicable regulation.
• Game Content Providers: Technology providers whose games operate on the spade66 Platform may receive limited session and wagering data necessary to operate their games. Game providers are bound by contractual data protection obligations.
• Customer Support Infrastructure: Providers of live chat and customer support technology platforms who process communications data on spade66's behalf under data processing agreements.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or regulatory direction, spade66 may disclose personal data to relevant authorities. spade66 will notify affected members of such disclosures where legally permitted to do so.
• Group Companies: Where spade66 operates through affiliated entities, personal data may be shared within the corporate group for the purposes described in this Policy, subject to the same data protection standards.

All third parties with whom spade66 shares personal data are required to implement appropriate technical and organisational security measures and to process data only in accordance with spade66's instructions and applicable law.

spade66 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small data files stored on your device that enable the Platform to recognise returning users, maintain session state, and collect usage analytics.

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without affecting Platform functionality.
• Performance Cookies: Used to collect anonymised data on how members use the Platform — for example, which games are played most frequently or where errors occur — to enable spade66 to improve the user experience.
• Functional Cookies: Enable the Platform to remember your preferences, such as language settings and previously selected filters in the games lobby.
• Marketing Cookies: Where you have provided consent, marketing cookies may be used to deliver relevant promotional content. You may withdraw consent to marketing cookies via your browser settings or by contacting spade66 support.

You may control cookie settings through your browser. Note that disabling certain cookies may affect the functionality of the spade66 Platform.

spade66 retains personal data for as long as necessary to fulfil the purposes for which it was collected, to maintain your account, and to comply with applicable legal and regulatory retention obligations. The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in accordance with AML and gaming regulatory requirements.
• Financial transaction records: Retained for a minimum of seven (7) years following the date of the transaction, in compliance with financial record-keeping obligations.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the activity.
• Customer support communications: Retained for two (2) years from the date of the final communication, unless a longer period is required in connection with a complaint or legal proceeding.
• Marketing preferences: Retained until you withdraw consent or request erasure, subject to any applicable minimum retention periods.

Where personal data is no longer required, spade66 will delete or anonymise it in a secure and irreversible manner.

spade66 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and spade66 servers.
• Encryption of sensitive data at rest, including financial and identity data stored in spade66 databases.
• Role-based access controls limiting access to personal data to authorised personnel with a legitimate operational need.
• Regular security assessments, penetration testing, and vulnerability management processes.
• Multi-factor authentication requirements for administrative access to systems containing member data.
• Incident response procedures for identifying, containing, and notifying affected members and regulators in the event of a data security incident.

While spade66 takes all reasonable precautions to protect your personal data, no internet transmission or electronic storage system is completely secure. You should ensure that your own device security is maintained and that you use a strong, unique password for your spade66 account.

spade66 may transfer personal data to service providers or data processors located outside of Malaysia. Where such transfers occur, spade66 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under applicable Malaysian data protection law. These safeguards may include contractual data protection clauses incorporated into agreements with the relevant data processors.

By using the spade66 Platform, you acknowledge and consent to such international transfers of your personal data where necessary for the operation of the Platform, subject to the safeguards described above.

As a data subject, you have the following rights in relation to the personal data spade66 holds about you. To exercise any of these rights, please contact spade66 via the details in Section 15:

• Right of Access: You have the right to request a copy of the personal data spade66 holds about you and information about how it is processed.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. You may update basic account information directly via your spade66 account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to spade66's legal and regulatory retention obligations.
• Right to Restrict Processing: You have the right to request that spade66 temporarily restrict the processing of your personal data in certain circumstances, for example while you contest the accuracy of data spade66 holds.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing of your personal data based on legitimate interests, and to opt out of direct marketing communications at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

spade66 will respond to all valid data subject requests within thirty (30) calendar days of receipt. We may need to verify your identity before processing your request.

The spade66 Platform is strictly for use by persons aged 21 years and above. spade66 does not knowingly collect personal data from individuals under the age of 21. If spade66 becomes aware that personal data has been collected from an individual under 21, that data will be deleted and the associated account will be closed immediately.

If you believe a minor has registered or is using a spade66 account, please contact support immediately so that appropriate action can be taken. For more information about our age restriction policies, please visit our Responsible Gaming page.

spade66 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Material changes to this Policy will be communicated to registered members via email to the address associated with their account and/or via a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically. Your continued use of the spade66 Platform following notification of changes constitutes acceptance of the revised Policy.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by spade66, please contact our support team using the following channels:

• Live Chat: Available 24/7 via the spade66 Platform — the fastest channel for urgent privacy concerns.
• Email: [email protected] (plain text — not a clickable link)

spade66 acknowledges all privacy-related written requests within five (5) business days and aims to resolve matters fully within thirty (30) calendar days. For complex requests, we will notify you if additional time is required.