Privacy Policy

SpinCity88 ("we", "us", "our", "the Company") operates the online casino and sports betting platform accessible at https://spincity88.cam (the "Platform"). We serve players across Malaysia, including users in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and beyond. As part of operating this Platform, we process personal data relating to registered players and website visitors.

This Privacy Policy ("Policy") describes, in clear and precise terms, the categories of personal data SpinCity88 collects, the purposes for which that data is processed, the legal bases that justify such processing, the circumstances in which data may be shared with third parties, and the rights available to individuals whose data we hold.

This Policy applies to all data subjects who interact with the SpinCity88 Platform, whether as registered Account holders or as unregistered visitors browsing the website. It should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference.

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information that relates to an identified or identifiable natural person — including, but not limited to, name, email address, date of birth, payment details, device identifiers, and IP address.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, and destruction.
• "Data Subject" means the individual to whom Personal Data relates — in the context of this Policy, this is primarily the registered Player or website visitor.
• "Data Controller" refers to SpinCity88, which determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" refers to a third-party entity that processes Personal Data on behalf of SpinCity88 and under its documented instructions.
• "Consent" means freely given, specific, informed, and unambiguous agreement by a Data Subject to the processing of their Personal Data for a stated purpose.
• "KYC" (Know Your Customer) refers to the identity and age verification process mandated by SpinCity88's licensing and anti-money-laundering obligations.
• "Cookie" means a small text file placed on a user's device by a website for purposes including session management, analytics, and personalisation.

SpinCity88 collects Personal Data through several channels, including the registration form, KYC submission, deposit and withdrawal transactions, customer support interactions, and automated technical means. The categories of data we collect are set out in the table below:

SpinCity88 does not collect Special Categories of Personal Data (such as biometric data, health data, or racial or ethnic origin data) unless required by a specific regulatory or responsible gambling obligation, in which case we will obtain explicit consent.

SpinCity88 processes Personal Data only where a valid legal basis exists. The legal bases we rely upon are as follows:

• Contractual Necessity: Processing required to perform our contractual obligations to you under the Terms & Conditions — including registering your Account, processing deposits and withdrawals, and providing gaming services.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including anti-money laundering (AML) obligations, KYC verification requirements, and responsible gambling regulations.
• Legitimate Interests: Processing necessary for the legitimate interests of SpinCity88 where those interests are not overridden by your rights — including fraud prevention, platform security, internal analytics, and improving the user experience.
• Consent: Processing for purposes beyond those above, including certain marketing communications and the use of non-essential cookies. Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

SpinCity88 uses the Personal Data it collects for the following purposes:

1. Account Management: To create, maintain, and administer your SpinCity88 Account, including verifying your identity during registration and KYC, managing your balance, and processing requests to update or close your Account.
2. Payment Processing: To process deposits and withdrawals via your chosen payment methods, including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect, and supported cryptocurrencies.
3. Gaming Services: To deliver and optimise the gaming experience, maintain game history records, calculate and credit winnings and bonuses, and manage the VIP loyalty programme.
4. Regulatory Compliance: To fulfil our obligations under applicable gaming regulations and AML frameworks, including transaction monitoring and the filing of required reports where mandated by law.
5. Responsible Gambling: To monitor gaming behaviour for indicators of problem gambling, to enforce responsible gambling tools such as deposit limits and self-exclusion, and to communicate responsibly with players who may be at risk.
6. Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover, and other security threats to the Platform and its users.
7. Customer Support: To respond to your enquiries, resolve complaints, manage disputes, and maintain records of support interactions.
8. Marketing & Promotions: To send promotional communications about offers, bonuses, and events — including Deepavali festival promotions — where you have provided consent or where we have a legitimate interest and have provided an opt-out mechanism.
9. Analytics & Platform Improvement: To analyse aggregated and anonymised usage data to understand how players interact with the Platform and to improve functionality, design, and performance.

SpinCity88 will not use your Personal Data for any purpose materially different from those listed above without first obtaining your consent or, where another legal basis applies, notifying you of the new purpose in advance.

SpinCity88 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We may share your data in the following circumstances:

• Payment Service Providers: We share financial data with payment processors (including e-wallet operators and banking partners) solely to the extent necessary to execute deposit and withdrawal transactions. These providers act as Data Processors under contractual data processing agreements.
• Identity Verification Services: We share identity and verification data with accredited KYC and AML service providers to fulfil our regulatory obligations. These providers are contractually bound to process data only on our instructions.
• Game Software Providers: Game studios that supply titles on the SpinCity88 Platform may receive anonymised or pseudonymised session data for the purpose of delivering and maintaining their games. No identifiable personal data is shared with game studios without your knowledge.
• Analytics and Technology Providers: We engage technology partners for infrastructure hosting, platform analytics, and cybersecurity services. All such partners operate under data processing agreements and are prohibited from using Platform data for their own purposes.
• Legal and Regulatory Authorities: We will disclose Personal Data to government authorities, regulators, or law enforcement agencies where required by law, court order, or our licensing obligations — including disclosure required under AML reporting frameworks.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a material portion of SpinCity88's business, Personal Data held by SpinCity88 may be transferred to the successor entity, subject to the same protections described in this Policy.

SpinCity88 uses cookies and similar tracking technologies (including web beacons and pixel tags) on the Platform. Cookies are small text files stored on your device that allow us to recognise you, maintain your session, and analyse usage patterns.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session management cookies that keep you logged in as you navigate between pages. These cookies cannot be disabled without breaking core Platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised data about how visitors interact with the Platform — including pages visited, time spent, and error encounters. This data is used to improve the Platform experience.
• Functional Cookies: Used to remember your preferences, such as language settings, responsible gambling limit configurations, and game lobby display options.
• Marketing Cookies: Used to deliver relevant promotional content and to measure the effectiveness of marketing campaigns. These cookies are set only with your consent.

You may manage your cookie preferences through your browser settings at any time. Note that disabling strictly necessary cookies may impair your ability to log in or use core Platform features. Consent for non-essential cookies can be withdrawn at any time without affecting your Account or game access.

SpinCity88 retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of the Account relationship plus a minimum of five (5) years following Account closure, as required by AML and gaming regulatory obligations.
• Financial and Transaction Data: Retained for a minimum of seven (7) years following each transaction, in accordance with financial record-keeping requirements.
• KYC and Verification Documents: Retained for a minimum of five (5) years following Account closure or the date the document was submitted, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, or longer if the records relate to an unresolved dispute or legal proceeding.
• Technical and Analytics Data: Anonymised analytics data may be retained indefinitely. Identifiable technical data (such as IP logs) is retained for a maximum of twelve (12) months unless required for an active investigation.
• Marketing Data: Retained until you withdraw consent or opt out, after which your contact details are suppressed rather than deleted to ensure we do not inadvertently re-contact you.

Upon expiry of the applicable retention period, Personal Data is securely destroyed or permanently anonymised. Players may request early deletion subject to the conditions described under Section 10 (Your Rights).

SpinCity88 implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and SpinCity88 servers is encrypted using industry-standard TLS (Transport Layer Security) protocols. Connections to the Platform are enforced over HTTPS.
• Encryption at Rest: Sensitive Personal Data stored on SpinCity88 servers — including financial data and identity documents — is encrypted using AES-256 encryption.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. SpinCity88 employees and contractors with access to production data systems are subject to background checks and are required to complete regular data protection training.
• Two-Factor Authentication: Player Accounts support two-factor authentication (2FA) to reduce the risk of unauthorised access resulting from compromised credentials. Players are strongly encouraged to enable 2FA.
• Penetration Testing & Vulnerability Management: SpinCity88 conducts regular security assessments, including third-party penetration testing, to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: SpinCity88 maintains a documented data breach response procedure. In the event of a breach that is likely to result in risk to affected individuals, SpinCity88 will notify relevant parties within timeframes required by applicable regulations.

While SpinCity88 takes all reasonable steps to protect your data, no system is entirely immune to risk. Players are also responsible for maintaining the security of their own Account credentials — including choosing a strong password and enabling 2FA.

As a data subject, you have a number of rights in relation to the Personal Data SpinCity88 holds about you. These rights are described below. To exercise any of these rights, please contact our support team using the details provided in Section 15. SpinCity88 will respond to all valid rights requests within thirty (30) calendar days of receipt, or within such shorter period as may be required by applicable law.

Certain rights are subject to exemptions — for example, we cannot erase data that we are legally required to retain for AML or regulatory purposes. Where an exemption applies, we will explain the reason clearly in our response to your request.

SpinCity88 strictly enforces a minimum age of 21 years for all registered players. The Platform is not directed at, and we do not knowingly collect Personal Data from, individuals under the age of 21. All Accounts are subject to mandatory KYC age verification before withdrawals are enabled.

If SpinCity88 becomes aware that Personal Data has been collected from an individual under the age of 21 — whether through a false declaration at registration or any other means — we will immediately suspend and permanently close the Account, delete all associated Personal Data to the extent permitted by our legal retention obligations, and return any real-money deposits made by that individual.

If you believe that a minor has gained access to the SpinCity88 Platform, please contact our support team immediately so that appropriate action can be taken.

The SpinCity88 Platform may contain links to third-party content or services — for example, game studio websites or payment provider portals accessed via redirect during the deposit process. SpinCity88 does not control the privacy practices of third-party websites and services, and this Policy does not apply to any data collected by those third parties once you leave the SpinCity88 Platform.

We recommend that you review the privacy policies of any third-party service you access in connection with your use of SpinCity88. SpinCity88 is not responsible for the content or privacy practices of third-party websites or services.

SpinCity88 is an internationally operated platform. In the course of providing services, your Personal Data may be transferred to and processed in countries outside Malaysia — including the jurisdictions where our servers, payment processors, and game studio partners are located. Some of these jurisdictions may not provide the same level of data protection as Malaysia.

Where such transfers occur, SpinCity88 ensures that appropriate safeguards are in place to protect your Personal Data, including:

• Contractual clauses in agreements with Data Processors that impose data protection obligations equivalent to those in this Policy;
• Use of service providers that maintain recognised international security certifications;
• Transfer impact assessments conducted where required for higher-risk transfer destinations.

By using the SpinCity88 Platform, you acknowledge that your Personal Data may be transferred internationally in accordance with the safeguards described in this section.

SpinCity88 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or our data processing practices. Material changes — defined as changes that substantively affect how we collect, use, or share your Personal Data — will be communicated to registered players by email and/or a prominent notice on the Platform at least seven (7) days before the changes take effect.

Minor amendments, such as typographical corrections, clarifications that do not alter the substance of the Policy, or changes required to comply with legal obligations on short notice, may take effect immediately. The "Last Updated" date at the top of this page reflects the date of the most recent revision.

Continued use of the SpinCity88 Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using the Platform and contact our support team to close your Account.

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or want to raise a data protection concern, please contact SpinCity88's Data Protection team through the following channels:

• Email: [email protected] (plain text only — not a clickable link). Please include "Privacy Request" in the subject line for faster routing.
• Live Chat: Available 24 hours a day, 7 days a week via the live chat widget on the SpinCity88 Platform. Our team operates on Malaysia Standard Time (MST, UTC+8).
• Response Time: We aim to acknowledge all privacy-related requests within 48 hours and to provide a substantive response within 30 calendar days.

For responsible gambling enquiries, please visit our Responsible Gambling page. For general terms questions, please refer to our Terms & Conditions.