Privacy Policy

This Privacy Policy ("Policy") issued by spin99 ("spin99", "we", "us", "our") and applies to all personal data collected from individuals ("Users", "you", "your") who access, register with, or otherwise interact with the spin99 online gaming platform at https://spin99.lat, including any related mobile applications, sub-domains, or affiliated services (collectively, the "Platform" or "Service").

spin99 operates this Policy in alignment with internationally recognised data protection principles and, where applicable, the Personal Data Protection Act 2010 (PDPA) of Malaysia, which governs the processing of personal data in commercial transactions involving Malaysian residents.

By registering an account, making a deposit, or continuing to use the spin99 platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to the terms of this Policy, you must discontinue use of the Service and contact our support team to close your account.

For the purposes of this Policy, the following terms shall carry the meanings assigned below:

spin99 collects personal data through a number of channels, including account registration, KYC verification, financial transactions, platform usage, customer support interactions, and automated technical processes. The categories of data collected are as follows:

spin99 collects only the minimum data necessary to provide the Service effectively and to meet our regulatory obligations. We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or genetic data, except where expressly required for specific regulatory purposes and with appropriate safeguards in place.

spin99 processes your personal data for the following specific purposes. Each purpose is matched to the data categories relied upon and the legal basis that justifies the processing:

• Account Creation and Management: We process identity and contact data to create, maintain, and administer your spin99 account, including facilitating login, managing your profile, and communicating important account updates.
• Identity Verification (KYC): We process identity documents and contact data to verify your age (21+ requirement), confirm your identity, and comply with anti-money laundering obligations before processing withdrawals.
• Payment Processing: We process financial data to facilitate deposits and withdrawals through supported Malaysian payment channels including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank, and USDT TRC20.
• Platform Delivery and Improvement: We process usage and technical data to deliver the gaming service, diagnose technical issues, optimise platform performance, and develop new features.
• Security and Fraud Prevention: We process technical and usage data to detect and prevent fraudulent activity, unauthorised account access, collusion, and other prohibited conduct.
• Regulatory Compliance: We process identity and financial data to meet our obligations under applicable anti-money laundering (AML) frameworks, responsible gambling regulations, and any other legal requirements applicable to our operations.
• Customer Support: We process communications and identity data to respond to enquiries, resolve disputes, and manage complaints through our support channels.
• Promotional Communications: Where you have provided consent, we may process contact data to send you information about promotions, bonuses, and platform updates. You may withdraw this consent at any time.

spin99 processes personal data one or more of the following legal bases, as applicable to each processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you accepted at registration — including account management, payment processing, and KYC verification.
• Legal Obligation: Processing necessary to comply with applicable laws and regulations, including anti-money laundering requirements, age verification mandates, and reporting obligations to competent authorities.
• Legitimate Interests: Processing carried out for spin99's legitimate business interests, including fraud detection, platform security, and service improvement, where those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

spin99 does not sell, rent, or trade your personal data to third parties. We may share your personal data only in the following defined circumstances:

• Payment Processors: We share financial data with licensed payment service providers — including operators of DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, and supported Malaysian banking institutions — solely for the purpose of facilitating your transactions. These processors are bound by contractual data protection obligations.
• Identity Verification Providers: We may share identity and document data with KYC verification service providers who assist us in completing the verification process. All providers are subject to strict confidentiality agreements.
• Game Software Providers: Usage data relating to game activity may be shared with our licensed game software providers for the purpose of game delivery, fairness auditing, and jackpot processing. No personally identifiable information beyond a pseudonymous player identifier is shared in this context.
• Legal and Regulatory Authorities: We may disclose personal data to government agencies, law enforcement bodies, financial intelligence units, or regulatory authorities where we are legally required or authorised to do so, including in the context of AML reporting or fraud investigations.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets, personal data may be transferred as part of that transaction, subject to equivalent data protection obligations being maintained by the receiving entity.

spin99 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, to maintain complete and accurate business records, and to comply with applicable legal obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data governance procedures. Anonymised or aggregated data that can no longer be used to identify an individual may be retained indefinitely for analytical and reporting purposes.

spin99 uses cookies and similar tracking technologies to operate the platform, analyse usage patterns, and deliver a personalised experience. A "cookie" is a small text file placed on your device by a web server when you visit a website.

The types of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the platform to function correctly. These include session management cookies, authentication tokens, and security cookies. These cannot be disabled without impairing core functionality.
• Performance & Analytics Cookies: Used to collect anonymised information about how Users interact with the platform, including pages visited, session duration, and error events. This data helps us improve the platform experience.
• Functional Cookies: Remember your preferences such as language settings, game filters, and display preferences to provide a more personalised experience on return visits.
• Security Cookies: Used to detect and prevent fraud, unauthorised account access, and suspicious usage patterns, particularly across multiple sessions or IP addresses.

You may control cookie settings through your browser preferences. Please note that disabling strictly necessary cookies will affect your ability to log in and use core platform features. spin99 does not use third-party advertising cookies or tracking pixels for external advertising networks.

spin99 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security infrastructure includes:

• 256-bit Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers.
• AES-256 encryption for personal data stored in our databases, including KYC documents and financial records.
• Strict role-based access controls limiting employee access to personal data on a need-to-know basis.
• Multi-factor authentication requirements for all internal administrative systems.
• Regular penetration testing and independent security audits of our platform infrastructure.
• Automated anomaly detection systems monitoring for suspicious access patterns in real time.
• Segregated storage of KYC documents, separated from general account data, with access logging.

Despite these measures, no online platform can guarantee absolute security against all possible threats. In the unlikely event of a data breach that poses a risk to your rights and freedoms, spin99 will notify affected users and relevant regulatory authorities within the timeframes required by applicable law.

Subject to applicable law, you hold the following rights in respect of your personal data held by spin99. You may exercise any of these rights by contacting our support team at [email protected] or via Live Chat.

spin99 will respond to all data rights requests within 30 calendar days. In complex cases, this period may be extended by a further 60 days, with notification provided. We will not charge a fee for exercising your data rights unless requests are manifestly unfounded or excessive.

spin99 is strictly prohibited from collecting personal data from individuals under the age of 21. The platform is designed exclusively for adult entertainment and we take this restriction seriously.

During the registration process, all users are required to confirm that they are 21 years of age or older. The KYC verification process independently validates age through government-issued identification documents. Where spin99 discovers or has reasonable grounds to suspect that an Account has been registered by or on behalf of a minor, we will:

• Immediately suspend and permanently terminate the Account.
• Void all wagers placed and forfeit any associated balance.
• Delete all personal data collected in connection with the minor's Account, except where retention is required by applicable law for investigation purposes.
• Report the matter to relevant authorities where required by law.

If you believe a minor has accessed or registered on spin99, please contact us immediately at [email protected] so that we can investigate and take appropriate action without delay.

In the course of providing the Service, your personal data may be transferred to, stored on, or processed by systems located outside of Malaysia. Such transfers may occur where spin99 engages third-party service providers — such as cloud infrastructure operators, KYC verification platforms, or game software providers — whose systems are hosted in other jurisdictions.

Where personal data is transferred internationally, spin99 takes appropriate safeguards to ensure that the data receives an equivalent level of protection to that afforded within Malaysia, including through:

• Contractual data protection clauses binding third-party recipients to standards consistent with applicable privacy law.
• Limiting data shared with international processors to the minimum necessary for the specified purpose.
• Conducting due diligence assessments on third-party data processors prior to engagement and periodically thereafter.

spin99 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, the services we offer, or applicable legal requirements. The revised Policy will be published on this page with an updated effective date.

Where changes are material — for example, where we propose to use personal data for a new purpose not covered by this Policy — we will provide prominent notice to registered Users via in-platform notification or email prior to the change taking effect, and where required, seek renewed consent.

Your continued use of spin99 following the publication of a revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you should discontinue use of the Service and contact our team to arrange Account closure.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or need to report a privacy concern, please contact the spin99 Data Support team through the following channels. All privacy-related requests will be acknowledged within 5 business days.

Please include your registered email address, account username, and a clear description of your request or concern when contacting us. For data erasure requests, we may require identity verification before proceeding to protect against unauthorised requests.