spade54 Privacy Policy

This Privacy Policy ("Policy") describes how spade54 ("we", "us", "our") collects, uses, discloses, and safeguards personal information that you ("you", "the player") provide when accessing or using the spade54 website at spade54.lat and any related services, applications, or platforms operated by us (collectively, the "Platform"). By registering an account or continuing to use the Platform, you acknowledge that you have read, understood, and agreed to the terms of this Policy.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, both of which form part of your agreement with spade54.

1. Who We Are

spade54 is an international online betting and casino platform serving players across Malaysia and other jurisdictions where access to online gaming services is lawful. The Platform offers sports betting, live casino games, slots, fishing games, and horse racing under a single account framework with local Malaysian payment support.

For all data protection enquiries, the responsible entity is spade54 (the "Data Controller"). You may contact us at the email address provided in Section 13 of this Policy.

2. Information We Collect

We collect personal information from you in the following ways:

2.1 Information You Provide Directly

• Registration data: Full name, date of birth, nationality, email address, mobile number, and residential address.
• Identity verification (KYC): Copies of government-issued identification (e.g., MyKad, passport), proof of address, and in some cases selfie verification to comply with anti-money laundering ("AML") requirements.
• Payment information: Bank account details, e-wallet identifiers (Touch 'n Go, Boost, GrabPay), or cryptocurrency wallet addresses used for deposits and withdrawals. Full card numbers are not retained by spade54.
• Communications: Messages sent to our support team via live chat, WhatsApp, or email, including any attachments or records of disputes.
• Responsible gaming preferences: Self-exclusion elections, deposit limits, cooling-off period requests, and related account controls you configure.

2.2 Information Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and time zone.
• Usage data: Pages visited, games played, bet history, session duration, clickstream data, and feature interactions.
• Cookies and similar technologies: Refer to Section 8 for full details on how we use cookies.
• Location data: Approximate geographic location derived from your IP address to enforce jurisdictional access controls.

2.3 Information from Third Parties

• Identity verification providers for KYC and age verification purposes.
• Payment processors and banking institutions to confirm transaction legitimacy.
• Fraud detection and risk management services used to protect the Platform's integrity.
• Affiliate and referral partners where you accessed spade54 through a promotional link, limited to attribution data only.

3. How We Use Your Data

spade54 uses the personal information we collect for the following purposes:

• Account creation and management: To register your account, verify your identity, and maintain the integrity of your player profile on the Platform.
• Service delivery: To process bets, deposits, withdrawals, and any other transactions you initiate through spade54.
• Legal and regulatory compliance: To meet our obligations under applicable anti-money laundering, know-your-customer, and responsible gaming regulations, including age verification to ensure all players are aged 21 and above.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, collusion, or any other activity that may compromise the security of the Platform or its players.
• Customer support: To respond to your enquiries, resolve disputes, and improve the quality of our support services.
• Platform improvement: To analyse usage patterns, identify technical issues, and develop new features that enhance your experience on spade54.
• Marketing communications: To send you promotions, bonus offers, and event notifications (e.g., AFF Cup specials, World Cup qualifier odds boosts) where you have opted in to receive such communications. You may withdraw consent at any time.
• Responsible gaming: To monitor betting behaviour and intervene proactively where patterns suggest potential gambling harm, in line with our Responsible Gaming commitments.

4. Legal Bases for Processing

Where data protection legislation requires us to identify a lawful basis for processing your personal data, we rely on the following:

• Contractual necessity: Processing required to perform our contract with you, including account registration, payment processing, and service delivery.
• Legal obligation: Processing required to comply with AML, KYC, age verification, and other regulatory requirements applicable to online gaming operators.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and business analytics, provided these interests are not overridden by your rights and interests.
• Consent: Marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Disclosure to Third Parties

spade54 does not sell or rent your personal data to any third party. We may share your information with the following categories of recipients only to the extent necessary:

• Payment service providers: Banks, e-wallet operators (Touch 'n Go, Boost, GrabPay), and cryptocurrency processors used to facilitate your transactions.
• Identity and fraud verification providers: Third-party KYC and AML screening services that help us verify your identity and comply with regulatory obligations.
• IT and hosting providers: Cloud infrastructure and server hosting partners who process data on our behalf under strict data processing agreements.
• Customer support platforms: Live chat and communication tools used exclusively to deliver support services to you.
• Regulatory authorities and law enforcement: Where we are legally compelled to disclose information pursuant to a court order, regulatory request, or statutory obligation.
• Professional advisors: Lawyers, auditors, and compliance consultants engaged to advise spade54, bound by professional confidentiality obligations.

All third parties to whom we disclose personal data are required to process that data only for the specified purpose and to maintain appropriate security measures consistent with this Policy.

6. International Data Transfers

spade54 is an international online gaming platform. Your personal data may be transferred to, stored, or processed in countries outside Malaysia where our servers, service providers, or operational infrastructure are located. In such cases, we take reasonable steps to ensure that appropriate safeguards are in place — including contractual clauses with data processors — to protect your information to a standard equivalent to what you would expect domestically.

By using the Platform and agreeing to this Policy, you consent to the transfer of your personal data to jurisdictions outside Malaysia where necessary for service delivery.

7. Data Retention

We retain your personal data only for as long as is necessary for the purposes described in this Policy or as required by law. Specific retention periods include:

• Active account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, to satisfy AML and regulatory record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC and identity documents: Retained for the period required by applicable AML regulations, typically five (5) years from the end of the business relationship.
• Support communications: Retained for up to three (3) years from the date of the communication, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained until you withdraw consent, plus an additional period as required for compliance audit purposes.

When data is no longer required, we will securely delete or anonymise it in a manner that prevents reconstruction of the original personal information.

8. Cookies & Tracking Technologies

spade54 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit our site.

8.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, security tokens, and load balancing. These cannot be disabled.
• Performance and analytics cookies: Help us understand how players use the Platform — which pages are most visited, where errors occur, and how navigation flows. Data collected is aggregated and anonymised.
• Functional cookies: Remember your preferences such as language, currency display, and game settings to personalise your experience.
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of marketing campaigns. Only deployed with your prior consent.

8.2 Managing Your Cookie Preferences

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of parts of the Platform. Detailed instructions for managing cookies are available through your browser's help documentation.

9. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data held by spade54:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request that we correct any inaccurate or incomplete personal data.
• Right to erasure: You may request that we delete your personal data where it is no longer necessary for us to retain it, subject to legal retention obligations.
• Right to restrict processing: You may request that we limit the way we use your data in certain circumstances.
• Right to data portability: Where technically feasible and legally applicable, you may request your data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing communications), 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, including direct marketing, at any time.

To exercise any of these rights, please contact us using the details in Section 13. We will respond to all verified requests within thirty (30) calendar days. We may ask you to verify your identity before processing a request.

10. Security Measures

spade54 implements a range of technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

• Transport Layer Security (TLS) encryption for all data transmitted between your browser and our servers.
• Encryption of sensitive data fields at rest within our databases.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments and vulnerability testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Staff training on data protection obligations and incident response procedures.

While we take all reasonable precautions, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law.

11. Minors

spade54 is strictly an adults-only platform. We do not knowingly collect personal data from any individual under the age of 21. All players are required to verify their age during the registration and KYC process. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe a person under 21 has registered on the Platform, please contact us immediately using the details in Section 13.

12. Changes to This Policy

spade54 reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will notify registered players by email and by posting a prominent notice on the Platform prior to the changes taking effect. The revised Policy will show the updated effective date at the top of the document.

Your continued use of the Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your data.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way spade54 handles your personal data, please contact our Data Protection team:

• Email: [email protected]
• Live Chat: Available 24/7 directly on the Platform
• WhatsApp: Available 24/7 — number provided after login

Our support team operates in English, Bahasa Melayu, and Mandarin and will acknowledge your enquiry within two (2) business days.