Privacy Policy

1. Introduction

This Privacy Policy (hereinafter referred to as "this Policy" or "the Privacy Policy") is issued by Spingo (hereinafter referred to as "Spingo", "we", "us", or "our"), the operator of the online gaming and sports betting platform accessible at https://spingo.cam (the "Platform").

This Policy describes how Spingo collects, uses, stores, discloses, and protects the personal data of individuals who access or use the Platform, including registered players, account applicants, and visitors to the Spingo website (collectively referred to as "you", "your", or "the Data Subject").

By accessing or using the Spingo Platform — including registration, deposit, withdrawal, gameplay, and customer support interactions — you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must discontinue use of the Platform immediately.

This Privacy Policy forms an integral part of Spingo's Terms and Conditions, which govern your use of the Platform. We recommend reading both documents in full before registering an account.

2. Definitions

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

• "Personal Data" means any information that identifies or can be used to identify a natural person, including name, email address, date of birth, identification number, financial details, and device identifiers.
• "Processing" means any operation performed on personal data, including collection, storage, retrieval, use, disclosure, transfer, or deletion.
• "Data Controller" means Spingo, the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third-party service provider that processes personal data on behalf of Spingo in accordance with documented instructions.
• "KYC Data" means identity and age verification documentation collected as part of the Platform's Know Your Customer process, including government-issued identification and proof of address documents.
• "Cookies" means small text files placed on your device by the Platform to collect browsing information, session data, and user preferences.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement to the processing of personal data for a stated purpose.
• "Data Breach" means a security incident resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

3. Data We Collect

3.1 Data Provided Directly by You

When you register or use the Spingo Platform, you may provide the following categories of personal data directly:

• Registration Data: Full legal name, date of birth, residential address, email address, contact number, and username.
• Identity Verification (KYC) Data: Government-issued identification documents (e.g., Malaysian identity card, passport, driving licence), proof of address (e.g., utility bills, bank statements dated within three months), and, where required, proof of source of funds.
• Financial Data: Payment method details for deposits and withdrawals, including e-wallet account identifiers (Touch 'n Go eWallet, Boost, GrabPay), bank account numbers (for DuitNow, FPX, and direct bank transfers with Maybank, CIMB, Public Bank, RHB, Hong Leong Bank), and card details (Visa/Mastercard) processed via secure tokenisation.
• Communication Data: The content of support tickets, live chat transcripts, email correspondence, and any feedback submitted to Spingo.

3.2 Data Collected Automatically

When you access the Platform, certain data is collected automatically through technical systems:

• Device and Technical Data: IP address, browser type and version, operating system, device type and identifiers, screen resolution, and time zone.
• Usage and Behavioural Data: Pages visited, session duration, game titles accessed, betting activity, clicks, navigation paths, and feature usage.
• Transaction Data: Details of all deposits, withdrawals, wagers placed, games played, bonuses claimed, and account balance history.
• Cookies and Tracking Data: As described in Section 7 of this Policy.

4. Data Processing & Legal Basis

Spingo processes personal data on the following legal bases:

5. How We Use Your Data

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

• To create, verify, and maintain your player account on the Platform.
• To process deposits, wagers, and withdrawal requests in MYR through your selected payment methods.
• To conduct identity and age verification (KYC) as required by our licensing obligations and anti-money laundering (AML) framework.
• To monitor betting and gaming activity for signs of problem gambling and to administer responsible gambling tools, including deposit limits, session controls, loss alerts, and self-exclusion requests.
• To detect, investigate, and prevent fraudulent activity, unauthorised account access, bonus abuse, and other prohibited conduct as defined in our Terms and Conditions.
• To provide customer support, including responding to queries, complaints, and data subject rights requests.
• To send transactional communications, including account notifications, withdrawal confirmations, and security alerts.
• To send promotional communications and bonus notifications where you have provided explicit consent to receive such messages.
• To analyse platform usage patterns for the purpose of improving user experience, feature development, and performance optimisation.
• To comply with applicable legal, regulatory, and licensing obligations, including reporting requirements imposed by our international gaming licence.

6. Data Sharing & Disclosure

6.1 Third-Party Service Providers

Spingo may share your personal data with carefully selected third-party service providers who perform functions on our behalf, including payment processors (for DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, and card payments), KYC verification providers, fraud prevention and AML screening services, platform hosting and cloud infrastructure providers, and customer support software vendors. All such providers are bound by data processing agreements requiring them to process data solely on Spingo's instructions and to maintain appropriate security standards.

6.2 Regulatory and Legal Disclosure

Spingo may disclose personal data to competent authorities, regulatory bodies, or law enforcement agencies where required by applicable law, court order, or in connection with our licensing obligations. We will, where legally permitted, notify you of any such disclosure request.

6.3 Business Transfers

In the event of a merger, acquisition, asset sale, or corporate restructuring, personal data held by Spingo may be transferred as part of that transaction. Where such a transfer involves a change to the Data Controller, affected players will be notified in advance and provided the opportunity to close their account if they do not consent to the transfer.

6.4 No Sale of Personal Data

Spingo does not sell, rent, lease, or otherwise trade your personal data to any third party for commercial or marketing purposes. This restriction applies unconditionally and is not subject to any commercial arrangement.

7. Cookies & Tracking Technologies

Spingo uses cookies and similar tracking technologies on the Platform to support essential functionality, improve user experience, and analyse platform performance. The following categories of cookies may be in use:

• Strictly Necessary Cookies: Required for the Platform to function, including session management, login authentication, and security features. These cannot be disabled without significantly impairing Platform functionality.
• Functional Cookies: Store user preferences such as language settings, display preferences, and game history to provide a personalised experience.
• Analytics Cookies: Collect aggregated, anonymised data about how visitors use the Platform, which pages are most visited, and where errors occur. This data is used to improve Platform performance and usability.
• Marketing Cookies: Used only where you have provided explicit consent, to track the effectiveness of promotional campaigns and to deliver relevant offers within the Platform.

You may manage your cookie preferences via your browser settings. Please note that disabling certain categories of cookies may affect the functionality of some Platform features. We do not use third-party advertising network cookies to track your activity outside of the Spingo Platform.

8. Data Retention

Spingo retains personal data for as long as necessary to fulfil the purposes outlined in this Policy, or as required by applicable legal, regulatory, or licensing obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your account registration plus a minimum of five (5) years following account closure, as required by AML regulations applicable under our gaming licence.
• Transaction and Betting Records: Retained for a minimum of five (5) years following the date of the transaction, in compliance with AML and gaming regulatory requirements.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure or the end of the business relationship.
• Customer Support Communications: Retained for a minimum of three (3) years following the close of the relevant support case.
• Marketing Consent Records: Retained until consent is withdrawn plus an additional two (2) years for compliance evidence purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents identification.

9. Data Security

Spingo implements a comprehensive suite of technical and organisational security measures to protect personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS encryption for all data transmitted between your device and the Spingo Platform.
• AES-256 encryption for sensitive data stored at rest, including financial records and KYC documents.
• Multi-factor authentication options for player account access.
• Role-based access controls ensuring that only authorised personnel can access personal data, limited to what is strictly necessary for their function.
• Regular penetration testing and security audits conducted by independent third-party specialists.
• Incident response and data breach notification procedures in accordance with applicable regulatory requirements.

10. Your Rights as a Data Subject

Subject to applicable law and any overriding regulatory obligations, you have the following rights with respect to your personal data held by Spingo:

• Right of Access: You may request a copy of the personal data Spingo holds about you, including information on how it is being used.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held about you. For account data, many fields can be updated directly through your 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 overriding legal retention obligations (e.g., AML record-keeping requirements).
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Restrict Processing: You may request that Spingo restrict the processing of your data in certain circumstances, for example where you contest the accuracy of the data held.
• Right to Object: You may object to the processing of your personal data where Spingo relies on legitimate interests as the legal basis, including profiling for responsible gambling purposes, subject to Spingo's overriding obligations.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of the above rights, please submit a written request to our support team. We will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) calendar days.

11. International Data Transfers

As Spingo operates under international gaming licensing, your personal data may be processed and stored in jurisdictions outside Malaysia. Where such transfers occur, Spingo ensures that appropriate safeguards are in place, including contractual protections with data processors equivalent to those applicable under recognised international data protection frameworks.

In particular, personal data shared with our KYC verification providers, payment processors, and platform infrastructure providers may be processed in jurisdictions other than Malaysia. By using the Platform, you acknowledge and consent to these international data transfers as described in this Policy.

12. Minors & Age Verification

The Spingo Platform is strictly restricted to individuals aged 21 years and above. Spingo does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the KYC process for all players, and accounts where the age requirement is not satisfied are closed immediately.

If you believe that personal data from an individual under the age of 21 has been inadvertently collected, please contact us immediately at [email protected] and we will take prompt action to delete such data and close the associated account.

13. Third-Party Services

The Spingo Platform may incorporate third-party services for the purposes of payment processing, identity verification, analytics, and platform infrastructure. These include, but are not limited to, Malaysian payment providers (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank) and international payment networks (Visa, Mastercard).

Each third-party service provider operates under its own privacy policy and data handling practices. Spingo is not responsible for the privacy practices of third-party providers accessed through the Platform. We recommend reviewing the privacy policies of any third-party service you use in connection with your Spingo account.

The Spingo website does not link to external third-party websites. Any links displayed on the Platform navigate only to pages within the Spingo domain.

14. Policy Amendments

Spingo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable legal or regulatory requirements, or platform operations. Where amendments are material, we will notify registered players via email to the address registered to their account with reasonable advance notice prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically. Continued use of the Platform following the effective date of any amendments constitutes your acceptance of the revised Policy.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Spingo, please contact our Data Protection team using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please mark all data-related enquiries with "Privacy Request — [Your Registered Email]"
• Response Time: Acknowledgement within 5 business days; substantive response within 30 calendar days
• Live Chat: Available 24/7 on the Platform for general data queries

For complaints relating to our handling of your personal data that have not been resolved to your satisfaction through our internal process, you may contact the relevant data protection authority in the jurisdiction applicable to your situation.