Spade46 Privacy Policy – Malaysian Member Personal Data Protection

Introduction

Welcome to the spade46 Privacy Policy. This document explains in detail how the spade46 platform ("we", "spade46" or "Platform") collects, processes, stores and protects your personal information when you register, browse or use any of the services we offer.

Spade46 operates with full transparency about our data practices. We believe you have the right to know exactly what happens to your information — not just wade through a policy packed with hard-to-understand legal jargon. That is why we have written this document in plain language that every one of our members in Malaysia can easily understand.

By registering or using the spade46 platform, you agree to the collection and use of information as described in this privacy policy. If you disagree with any part of this policy, please contact our support team before continuing to use the platform.

1 Data We Collect

Spade46 collects various types of data depending on how you interact with our platform. Below is a comprehensive overview of the data categories we collect:

We never collect data that is irrelevant or exceeds our stated operational requirements. Data minimisation is a core principle of spade46's approach to privacy.

2 How We Use Your Data

Every piece of data we collect is used for a clear and legitimate purpose. Here is how spade46 uses your information:

• Account Management: To process registration, verify identity through KYC, manage logins and ensure the security of your account.
• Transaction Processing: To process deposits, withdrawals and all financial activities securely and accurately.
• Service Improvement: To analyse usage patterns and improve the gaming experience, platform speed and overall service quality.
• Security & Fraud Prevention: To detect suspicious activity, prevent unauthorised access and protect the integrity of the platform.
• Service Communications: To send important account-related notifications, security updates and changes to our terms.
• Marketing (with consent): To inform you about promotions, bonuses and new offers — only if you have opted in to receive such communications.
• Legal Compliance: To fulfil regulatory obligations, including reporting to relevant authorities where required by law.
• Responsible Gaming: To monitor gameplay patterns in order to identify members who may need support and offer appropriate responsible gaming tools.

Spade46 will not use your data for any purpose beyond those stated above without first obtaining your explicit consent.

3 Data Storage & Security

The security of your personal data is spade46's highest priority. We implement multiple layers of technical and organisational protection to ensure your data remains safe at all times:

• All data transmitted between your device and spade46 servers is protected using 256-bit SSL/TLS encryption — the same standard used by leading banking institutions worldwide.
• Sensitive data such as passwords is stored in bcrypt hashing which cannot be decrypted, meaning even spade46 staff cannot view your password.
• Spade46 data servers are protected by enterprise-grade firewalls, intrusion detection systems (IDS) and continuous vulnerability scanning.
• Access to user data within spade46's internal systems is restricted to staff who genuinely require it to perform their duties, and all access is logged for audit purposes.
• We conduct regular penetration testing by independent security specialists to identify and patch any vulnerabilities before they can be exploited.

Your personal data will be retained for as long as your account is active or as long as necessary to fulfil the purposes stated in this policy. Following account closure, data will be retained for the period required by applicable law (typically 5–7 years for financial records), after which it will be securely deleted.

4 Data Sharing With Third Parties

Spade46 does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. However, there are limited situations where we may need to share your information with other parties:

• Payment Service Providers: Transaction details required to process your deposits and withdrawals are shared with recognised payment processors to ensure secure handling.
• Technical Service Providers: Selected cloud infrastructure and technical service providers bound by strict confidentiality agreements.
• Regulatory Authorities: When required by Malaysian law or a valid court order, we will disclose the necessary information to the relevant authorities.
• Identity Verification Providers: Recognised third-party KYC services are used to verify your identity documents during the registration process.

All third parties who receive spade46 user data are bound by data protection agreements requiring them to safeguard that information to a standard at least equivalent to the spade46 privacy policy. We do not permit service providers to use your data for their own purposes.

5 Cookies & Tracking Technologies

The spade46 platform uses cookies and similar tracking technologies to enhance your experience, ensure the platform functions properly and understand how members use our services.

• Essential Cookies: Required for core platform functions such as login authentication and session management. Cannot be disabled without affecting platform usability.
• Performance Cookies: To collect information about how you use the platform (pages visited, time spent, errors encountered) and help us improve our services.
• Functional Cookies: To save your preferences such as language and display settings, providing a more personalised experience.
• Security Cookies: To help us detect and prevent fraudulent activity, suspicious login attempts and other security threats.

You can manage cookie settings through your web browser preferences. However, disabling certain cookies may affect the functionality or user experience of the spade46 platform.

6 Your Rights as a User

As a spade46 member, you have clear and enforceable rights regarding your personal data. Here is a summary of your key rights:

To exercise any of the rights above, contact the spade46 support team via live chat within the platform. We are committed to responding to all privacy-related requests within 14 business days.

7 Cross-Border Data Transfers

To ensure the reliability and performance of the spade46 platform, some data may be processed or stored on servers located outside Malaysia. Any such data transfers are carried out with adequate safeguards, including:

• Standard data transfer agreements that ensure a level of protection equivalent to Malaysia's data protection laws.
• Use of cloud infrastructure providers compliant with international security standards such as ISO 27001 and SOC 2.
• A data protection impact assessment (DPIA) is conducted before any new data transfer to a new location is implemented.

Spade46 ensures that wherever your data is stored or processed, it receives a level of protection consistent with our commitments in this Privacy Policy.

8 Children's Privacy

The spade46 platform is strictly for users aged 21 and above. We do not intentionally collect or process personal data from individuals below the applicable minimum age requirement.

If we become aware that personal data of a minor has been collected without appropriate knowledge or consent, we will take immediate steps to delete that data and close the account in question. If you believe a minor has registered on our platform, please contact our support team immediately.

9 Privacy Policy Changes

Spade46 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service improvements. Any material changes will be communicated to you via:

• In-platform notifications on spade46 the next time you log in.
• Email notification to your registered address at least 14 days before changes take effect.
• Updates take effect on the "Updated" date displayed at the top of this page.

Your continued use of the spade46 platform after any changes take effect constitutes your acceptance of the updated policy. We encourage you to review this page periodically.

10 Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or how spade46 handles your personal data, our team is ready to assist through the following channels:

• Live Chat: Available 24/7 directly within the spade46 platform for the fastest response.
• Privacy Email: [email protected] — for privacy-specific inquiries and data rights requests.
• FAQ: Visit the FAQ ours for answers to frequently asked questions about privacy and data security.

We are committed to responding to all privacy-related enquiries within 3 working days and fulfilling data rights requests within 14 working days of the date of receipt.