spade88 Privacy Policy

1. Introduction

spade88 ("the Company", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who access or use the spade88 platform, accessible at spade88.club and its associated subdomains ("the Platform"). This Privacy Policy describes how spade88 collects, processes, stores, shares, and protects personal data in connection with the operation of the Platform and all associated services.

By registering an account with spade88 or continuing to use the Platform, you ("the Member", "you") acknowledge that you have read this Privacy Policy and consent to the processing of your personal data as described herein. If you do not consent, you must discontinue use of the Platform and contact the spade88 support team to request account closure.

This Policy should be read in conjunction with the spade88 Terms and Conditions. In the event of any inconsistency, the Terms and Conditions shall prevail with respect to gameplay and account matters, while this Privacy Policy governs all personal data processing activities.

2. Personal Data We Collect

spade88 collects personal data through several channels, including account registration, platform use, financial transactions, customer support interactions, and automated technical collection. The categories of personal data collected include:

spade88 collects only the minimum personal data necessary for the purposes described in this Policy. We do not collect sensitive personal data such as racial or ethnic origin, political opinions, or health information, except where strictly required by applicable gaming regulatory compliance obligations.

3. How We Use Your Personal Data

spade88 processes personal data for the following purposes:

• Account administration: To create, maintain, verify, and manage your spade88 account, including identity verification as required under our international gaming licence;
• Service delivery: To provide access to games, sportsbook, live casino, and all other Platform services, and to process deposits and withdrawals in Malaysian Ringgit (MYR);
• Regulatory compliance: To fulfil anti-money laundering (AML), know-your-customer (KYC), responsible gaming, and other obligations imposed by applicable gaming licensing authorities;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other prohibited conduct as defined in the spade88 Terms and Conditions;
• Customer support: To respond to enquiries, resolve disputes, and provide technical assistance;
• Platform improvement: To analyse aggregate usage patterns, diagnose technical issues, and improve the Platform's performance and user experience;
• Marketing communications: To send promotional offers, bonus notifications, and platform updates to Members who have not opted out of such communications. Members may withdraw consent for marketing communications at any time via account settings or by contacting support.

4. Legal Basis for Processing

spade88 processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil the agreement between spade88 and the Member, including account operation, game access, and financial transaction processing;
• Legal obligation: Processing required to comply with applicable gaming licensing conditions, AML legislation, and regulatory reporting obligations;
• Legitimate interests: Processing carried out for the legitimate business interests of spade88, including fraud prevention, platform security, and service improvement, where such interests are not overridden by Member rights and freedoms;
• Consent: Processing based on the Member's freely given, specific, and informed consent — principally for direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

spade88 does not sell, rent, or trade personal data to any third party. Personal data may be shared only in the following limited circumstances:

• Service providers: Third-party processors engaged by spade88 to provide platform infrastructure, payment processing, identity verification, fraud detection, and customer support services. All such processors are contractually bound to process personal data only on spade88's documented instructions and to maintain appropriate security standards;
• Game providers: To the extent technically necessary, account identifiers may be shared with certified game software providers for the purpose of delivering game content and recording outcomes. Game providers do not receive full identity or financial data;
• Payment processors: Financial data is shared with payment processors — including those facilitating Touch n Go eWallet, Boost, Maybank, CIMB, Hong Leong Bank, and GrabPay transactions — solely for the purpose of completing the requested financial transaction;
• Regulatory and legal authorities: spade88 will disclose personal data to gaming regulators, law enforcement agencies, financial intelligence units, or courts where required to do so by applicable law, court order, or regulatory direction. Where legally permissible, spade88 will notify the affected Member of such disclosure;
• Corporate transactions: In the event of a merger, acquisition, or sale of all or substantially all of spade88's assets, personal data held by spade88 may be transferred to the acquiring entity, subject to equivalent privacy protections.

6. Cookies & Tracking Technologies

The spade88 Platform uses cookies and similar tracking technologies to support platform functionality, maintain login sessions, analyse usage patterns, and deliver relevant content. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management and security functions. These cannot be disabled without impairing Platform functionality;
• Functional cookies: Enable personalisation features such as language preferences, display settings, and account dashboard configurations;
• Analytical cookies: Collect aggregated, anonymised data about how Members navigate and interact with the Platform, used to improve design and performance. No individually identifiable data is collected through analytical cookies;
• Security cookies: Support fraud detection, login verification, and account protection mechanisms.

Members may manage cookie preferences through their browser settings. Disabling strictly necessary cookies will impair the ability to log in and use the spade88 Platform. spade88 does not use cookies for the purpose of serving third-party advertising.

7. Data Retention

spade88 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, and to comply with applicable legal, regulatory, and licensing retention obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of account operation and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• Financial transaction records: Retained for a minimum of seven (7) years following the date of each transaction;
• Customer support communications: Retained for three (3) years following resolution of the relevant support matter;
• Technical and session logs: Retained for up to twelve (12) months from collection date, then anonymised or deleted.

Where personal data is retained beyond the active account period solely for regulatory compliance purposes, it will be stored in a restricted environment with access limited to authorised personnel only.

8. Data Security

spade88 implements a multi-layered security architecture to protect personal data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between Member devices and spade88 servers;
• Encryption at rest for sensitive stored data including identity documents and financial records;
• Access controls restricting personal data access to authorised personnel with documented business need;
• Regular independent security audits and penetration testing;
• Intrusion detection systems monitoring for anomalous access patterns;
• Two-factor authentication options for Member accounts to prevent unauthorised login.

Despite these measures, no digital platform can guarantee absolute security. Members are responsible for maintaining the confidentiality of their login credentials and for notifying spade88 promptly if they suspect unauthorised access to their account.

9. Your Data Rights

Subject to applicable law and regulatory limitations, Members have the following rights with respect to their personal data held by spade88:

• Right of access: To request a copy of the personal data spade88 holds about you;
• Right of rectification: To request correction of inaccurate or incomplete personal data;
• Right to erasure: To request deletion of personal data where it is no longer necessary for the purposes collected, subject to overriding legal and regulatory retention obligations;
• Right to restrict processing: To request that spade88 limit the processing of your personal data in certain circumstances;
• Right to data portability: To receive your personal data in a structured, machine-readable format where processing is based on consent or contractual necessity;
• Right to object: To object to processing based on legitimate interests, including objection to direct marketing communications;
• Right to withdraw consent: To withdraw consent for marketing communications at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact the spade88 support team via live chat or at [email protected]. spade88 will respond to verified data rights requests within thirty (30) calendar days.

10. Third-Party Services

The spade88 Platform integrates with third-party game providers, payment processors, and identity verification services to deliver its full range of products and services. spade88 is not responsible for the privacy practices of third-party providers beyond the contractual obligations imposed on them as data processors acting on spade88's instructions. Members should review the privacy policies of any third-party services they interact with independently of the spade88 Platform.

11. Children's Privacy

The spade88 Platform is strictly for adults aged 21 and above. spade88 does not knowingly collect personal data from any individual under the age of 21. If spade88 becomes aware that personal data has been collected from an individual under 21, that account will be immediately closed, all associated data will be deleted or anonymised, and the matter will be reported to the relevant regulatory authority. If you have reason to believe a minor has registered with spade88, please contact the support team immediately.

12. Updates To This Privacy Policy

spade88 reserves the right to update this Privacy Policy from time to time to reflect changes in law, regulatory requirements, platform operations, or data processing practices. Where a change is material, spade88 will provide notice via the Platform or to the Member's registered email address prior to the change taking effect. The "Last updated" date at the top of this Policy indicates when the most recent revision was made. Continued use of the Platform following the effective date of any update constitutes acceptance of the revised Policy.

13. Contact & Data Enquiries

For any enquiries, concerns, or requests relating to this Privacy Policy or spade88's data processing practices, Members may contact the spade88 Data & Privacy team via:

• Live chat: Available 24/7 through the Platform dashboard;
• Email: [email protected] — please include "Privacy Enquiry" in the subject line.

spade88 will acknowledge all written privacy enquiries within five (5) business days and will endeavour to resolve them within thirty (30) calendar days of receipt.