Privacy Policy – 321spin

1.Introduction

This Privacy Policy ("Policy") describes how 321spin ("the Company", "we", "us", "our") collects, uses, stores, discloses, and protects personal data relating to users ("you", "your") of the 321spin website (https://321spin.org), mobile applications, and associated services (collectively, the "Platform").

321spin is committed to protecting your privacy and handling your personal data in a manner that is transparent, fair, and compliant with applicable data protection legislation and the requirements of our gaming licence issued by an internationally recognised regulatory authority.

By registering a 321spin account or continuing to use the 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 with any part of this Policy, please discontinue use of the Platform and contact us to request account closure.

2.Personal Data We Collect

321spin collects personal data in the following categories:

2.1 Data You Provide Directly

• Identity data: Full legal name, date of birth, gender, and nationality;
• Contact data: Email address, mobile phone number, and residential address (including city — e.g., Kuala Lumpur, Penang, Johor Bahru — postcode, and country);
• Account credentials: Username and encrypted password;
• Verification documents: Copies of government-issued identification (e.g., MyKad, passport), proof of address, and source-of-funds documentation submitted during KYC verification;
• Financial data: Payment method details (e.g., bank account or e-wallet identifiers such as Touch 'n Go or Boost account references) — note that 321spin does not store full payment card numbers on its servers;
• Communications: Records of your interactions with our support team via live chat or email.

2.2 Data Collected Automatically

• Technical data: IP address, device type, operating system, browser type and version, and screen resolution;
• Usage data: Pages visited, games played, bets placed, session duration, click-stream data, and login timestamps;
• Location data: Approximate geographic location derived from your IP address for regulatory compliance and fraud prevention purposes;
• Cookie data: As described in Section 8 of this Policy.

2.3 Data from Third Parties

321spin may receive data about you from third-party identity verification providers, payment processors, fraud detection services, and regulatory databases in the course of performing KYC and anti-money-laundering checks.

3.How We Use Your Personal Data

321spin processes your personal data for the following purposes:

• Account management: To create, operate, and maintain your 321spin account, including processing deposits and withdrawals in MYR;
• Regulatory compliance: To verify your identity, age (21+ requirement), and source of funds in accordance with our licensing obligations and applicable anti-money-laundering regulations;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform;
• Customer support: To respond to your queries, complaints, and account requests through our 24/7 live chat and email support channels;
• Platform improvement: To analyse usage patterns, diagnose technical issues, and improve the performance, features, and user experience of the 321spin Platform;
• Responsible gaming: To monitor gameplay patterns that may indicate problem gambling behaviour, and to administer self-exclusion, deposit limit, and cooling-off requests;
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent to receive such communications;
• Legal obligations: To comply with court orders, regulatory requests, or other legal obligations imposed on 321spin.

4.Legal Basis for Processing

321spin processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contractual obligations to you under the Terms & Conditions, including operating your account and processing transactions;
• Legal obligation: Processing required to comply with applicable laws, gaming regulations, anti-money-laundering legislation, and the requirements of our gaming licence;
• Legitimate interests: Processing for fraud detection, security, platform improvement, and responsible gaming monitoring, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given consent that you may withdraw at any time.

5.Data Sharing and Disclosure

321spin does not sell your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors and e-wallet providers: To process deposits and withdrawals through Touch 'n Go, Boost, GrabPay, FPX, Maybank, CIMB, Public Bank, and other supported payment channels;
• Identity verification and KYC providers: To fulfil our regulatory obligations to verify player identity and age;
• Fraud detection and security services: To identify and prevent fraudulent transactions and prohibited conduct;
• IT infrastructure and hosting providers: Who process data on our behalf under strict data processing agreements;
• Gaming regulators and licensing authorities: As required under our gaming licence or in response to legitimate regulatory enquiries;
• Law enforcement and government authorities: Where we are legally required to disclose data by court order, warrant, or applicable law.

All third-party service providers engaged by 321spin are contractually required to implement appropriate data security measures and to process your data only for the specific purpose for which it was shared.

6.Data Retention

321spin retains your personal data only for as long as is necessary for the purposes for which it was collected, and in accordance with our legal and regulatory obligations. The following general retention periods apply:

• Account and transaction records: Retained for a minimum of five (5) years following account closure, as required by anti-money-laundering regulations applicable to our gaming licence;
• KYC verification documents: Retained for the period required by the applicable regulatory framework, typically five (5) years from the date of verification;
• Customer support communications: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained until you withdraw consent or for three (3) years from the last interaction, whichever is earlier.

After the applicable retention period, your personal data will be securely deleted or anonymised in accordance with our data disposal procedures.

7.Data Security

321spin implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 321spin's servers;
• Encryption of sensitive data fields at rest in our databases;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of the Platform infrastructure;
• Two-factor authentication options for staff accessing internal systems containing personal data.

Notwithstanding these measures, no method of electronic transmission or storage is 100% secure. While 321spin takes its security obligations seriously, we cannot guarantee the absolute security of data transmitted to or from the Platform. You are responsible for maintaining the security of your own account credentials and for notifying us immediately of any suspected unauthorised access to your account.

8.Cookies and Tracking Technologies

321spin uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device by a website to enable certain functionality and to collect usage data. The types of cookies used by 321spin are:

• Strictly necessary cookies: Essential to the operation of the Platform, including maintaining your logged-in session and enabling core functionality. These cookies cannot be disabled without affecting Platform usability.
• Functional cookies: Used to remember your preferences (e.g., language settings, preferred game categories) and to personalise your experience on the Platform.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, which helps us improve performance and content. No personal identifying information is included in analytics data transmitted to analytics providers.

You may manage or disable non-essential cookies at any time through your browser settings. Disabling certain cookies may affect the functionality of parts of the Platform. 321spin does not use advertising or cross-site tracking cookies.

9.Your Data Rights

Subject to applicable law and the conditions of our gaming licence, you have the following rights in relation to your personal data held by 321spin:

• Right of access: You may request a copy of the personal data we hold about you;
• Right to rectification: You may request correction of any inaccurate or incomplete personal data;
• Right to erasure: You may request deletion of your personal data in certain circumstances, subject to our legal and regulatory retention obligations;
• Right to restriction: You may request that we restrict processing of your personal data in certain circumstances;
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format in certain circumstances;
• Right to withdraw consent: Where processing is based on consent (e.g., marketing communications, non-essential cookies), you may withdraw consent at any time without affecting the lawfulness of prior processing;
• Right to object: You may object to processing based on legitimate interests in certain circumstances.

To exercise any of the above rights, please contact the 321spin support team via live chat or at [email protected]. We will respond to all data rights requests within 30 days of receipt.

10.Children and Minors

The 321spin Platform is strictly for individuals aged 21 years and above. 21+ We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered a 321spin account or provided personal data to us, please contact our support team immediately via live chat so that we can investigate and take appropriate action.

11.Changes to This Privacy Policy

321spin reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will update the "Last updated" date at the top of this page. We may also notify registered players of significant changes via email or in-Platform notification.

Your continued use of the 321spin Platform following the posting of any changes to this Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we are protecting your data.

12.Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 321spin, please contact us through the live chat facility available on any page of the Platform. Our support team is available 24 hours a day, 7 days a week.

Email enquiries may be directed to: [email protected]

We take all privacy enquiries seriously and aim to respond within one business day for email contacts and under five minutes via live chat.