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OFFICIAL SPADE46 PRIVACY POLICY

Spade46 Privacy Policy โ€“ Personal Data Protection for Malaysian Members

At spade46, your privacy is more than a legal obligation โ€” it is a promise we uphold wholeheartedly. This document transparently explains how we collect, store, use, and protect your personal data in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA).

Last updated: 1 January 2026 PDPA 2010 Compliant 256-bit SSL Protected

Your Data, Your Rights

Spade46 is fully compliant with Malaysia's PDPA and does not sell members' personal data to any third party

Spade46's 6 Core Privacy Commitments to Malaysian Members

These are the data protection principles we uphold every day, without exception

Bank-Grade Encryption

All your personal data and financial transactions on the spade46 platform are protected with 256-bit SSL encryption โ€” the same security technology used by Maybank and CIMB Bank. Your data cannot be intercepted or read by anyone while in transit.

We Do Not Sell Your Data

Spade46 has never and will never sell, rent, or trade members' personal data to any third party for marketing purposes. Your data belongs to you โ€” we only use it for purposes you have consented to.

Full PDPA 2010 Compliance

Spade46's privacy policy is designed and regularly updated to ensure full compliance with Malaysia's Personal Data Protection Act 2010. We conduct quarterly internal reviews and annual independent audits to verify this compliance.

Right to Access & Data Correction

As a spade46 member, you have the right to request access to your personal data, make corrections where there are errors, and apply for data deletion under certain circumstances. All requests will be processed within 14 business days.

Cookie & Tracking Controls

You have full control over the cookies we use. Essential cookies required for platform functionality cannot be disabled, but marketing and analytics cookies can be managed through your browser settings at any time without affecting core spade46 functionality.

Clear Data Retention Policy

Spade46 retains your personal data only for as long as necessary for the stated purposes or as required by law. Accounts that have been inactive for 3 consecutive years will be processed in accordance with our secure and irreversible data deletion procedure.

Content

This Privacy Policy forms part of the agreement between you and spade46. By using the spade46 platform, you agree to the collection and use of information as described in this policy. Please review this page periodically, as we may update it from time to time.

1

Introduction & Scope of This Privacy Policy

This Privacy Policy is issued by spade46 ("we", "spade46", or "Platform") and applies to all users, visitors, and registered members of the spade46 platform, accessible via spade46.bet and all associated websites.

Spade46 is an online entertainment platform providing Live Casino, slots, Sports Betting covering the Malaysia Super League, EPL, BWF badminton, poker, and a wide range of other games to users across Malaysia. In delivering these services, we necessarily collect and process personal data from our users.

We are committed to handling your personal data responsibly, transparently, and in full compliance with all relevant legal requirements โ€” in particular, Malaysia's Personal Data Protection Act 2010 (PDPA). This policy explains in detail what data we collect, why we need it, how we use it, and what rights you have as a data subject.

Applicable Scope: This Privacy Policy applies to all your interactions with the spade46 platform โ€” whether you are browsing our website, registering a new account, making a deposit via Touch 'n Go eWallet or DuitNow, playing live baccarat, or contacting our support team.
2

Types of Personal Data We Collect

Spade46 collects only the personal data that is strictly necessary to provide our services safely and effectively. The data we collect falls into several key categories:

Data Category Sample Data Mandatory / Optional
Identification Information Full name, MyKad / passport number, date of birth, gender Mandatory (KYC)
Contact Information Malaysian phone number, email address, residential address Mandatory
Financial Information Deposit/withdrawal records, payment methods (TnG, DuitNow, FPX), account balance Mandatory
Platform Usage Data Game records, betting history, results, login timestamps Automatic
Technical Data IP address, device type, browser, operating system, cookie data Automatic
Communication Data Live chat records, support emails, feedback, complaints Where applicable

Spade46 does not collect sensitive data such as health information, religious beliefs, or political views unless you voluntarily provide such information in specific contexts, such as a self-exclusion request on health grounds.

3

How We Collect Your Personal Data

Spade46 collects personal data through three primary channels:

  • Directly from you โ€” during account registration, KYC verification, form submissions, interactions with our support team, or feedback you voluntarily provide to spade46
  • Automatically โ€” when you use the spade46 platform, our systems automatically record technical data such as your IP address, device type, browsing activity, session cookies, and interface interaction history
  • From approved third parties โ€” payment service providers such as Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX may share limited transaction information with us for verification and security purposes

All automatically collected data is gathered through approved technologies and disclosed to users via a cookie notice. You may configure your browser settings to limit certain automatic data collection, though this may affect the functionality of some spade46 platform features.

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How We Use Your Personal Data

Spade46 uses your personal data solely for legitimate purposes to which you have consented, or as required by law. Key purposes include:

  • To process and maintain your spade46 membership registration and account
  • To verify your identity (KYC) in compliance with AML legal requirements and fraud prevention
  • Processing deposits via Touch 'n Go eWallet, GrabPay, DuitNow, FPX, and withdrawals to your account
  • To provide Live Casino, slots, Sports Betting, and other gaming services that you access
  • To inform you about relevant spade46 promotions, bonuses, and offers (with your consent)
  • To handle customer enquiries, complaints, and support requests
  • Detecting and preventing fraud, money laundering, and other illegal activities
  • Analysing usage patterns to improve the spade46 platform
  • Complying with legal obligations and relevant court orders
  • Supporting responsible gaming programmes, including the detection of at-risk gaming behaviour
Legal Basis for Processing: Spade46 processes your data on the basis of: (a) the performance of a service contract with you; (b) compliance with legal obligations; (c) our legitimate interests in operating a secure business; and (d) your consent for optional marketing purposes.
5

Personal Data Sharing & Disclosure

Spade46 does not sell, rent, or transfer your personal data to third parties for their marketing purposes. We only share data in limited, legitimate circumstances as outlined below:

  • Payment Service Providers โ€” Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, Maybank2u, CIMB Clicks, and other FPX providers receive the transaction information necessary to process your deposits and withdrawals
  • Game Providers โ€” gaming companies that provide content for the spade46 platform may receive player IDs and game records necessary to deliver their services
  • Authorities โ€” government agencies, courts, or law enforcement bodies when lawfully required by court order or applicable Malaysian law
  • Security & Anti-Fraud Providers โ€” companies that assist in fraud detection and platform security for spade46, bound by strict confidentiality agreements

All third parties that receive data from spade46 are required to uphold security and privacy standards no less stringent than those of spade46 itself. They are not permitted to use such data for any purpose other than those specified in their agreement with us.

6

Data Security Measures We Practise

Spade46 employs multiple layers of technical and organisational security to protect your personal data from unauthorised access, loss, misuse, or unintended disclosure:

  • 256-bit SSL/TLS encryption for all communications between your browser and spade46's servers
  • Passwords are stored using strong hashing algorithms โ€” we do not store passwords in plain text
  • Two-factor authentication (2FA) available for all member accounts
  • 24/7 monitoring system to detect suspicious activity or unauthorised access
  • Network segregation and access controls based on the principle of least privilege
  • Independent third-party security audits conducted every six months
  • Regular data security and privacy training for all spade46 staff
  • A tested incident response plan to ensure prompt action in the event of a breach

While we take all reasonable measures to protect your data, no security system is 100% foolproof. In the event of a security incident affecting your personal data, spade46 will notify you within 72 hours of becoming aware of it, in line with industry best practices.

7

Cookie Usage & Tracking Technologies

The spade46 platform uses cookies and similar tracking technologies to enhance user experience, analyse traffic, and ensure platform security. The following are the types of cookies we use:

Essential Cookies (Always Active) Functional Cookies Analytics Cookies Marketing Cookies (Optional)
  • Essential Cookies โ€” required for core spade46 platform functions such as login session authentication, security, and platform stability. These cookies cannot be disabled.
  • Functional Cookies โ€” remembering your preferences such as language, theme, and display settings to provide a more personalised experience on spade46.
  • Analytics Cookies โ€” helping us understand how users interact with the spade46 platform so we can improve the overall user experience. Data is collected in aggregate form and is not personally identifiable.
  • Marketing Cookies โ€” used to display more relevant advertisements. You may withdraw consent for these cookies at any time through your browser settings.

To manage your cookie preferences, visit the "Privacy Settings" section in your spade46 account or configure them directly through your browser settings. Disabling certain cookies may affect some platform features, but core functions such as gaming and financial transactions will not be impacted.

8

Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010, you have several important rights regarding your personal data held by spade46. We respect and facilitate the exercise of these rights:

Right to Access

You have the right to request a copy of the personal data we hold about you. Requests will be processed within 14 business days.

Right to Rectification

If any of your personal data is inaccurate or out of date, you have the right to request a correction by providing appropriate supporting evidence.

Right to Erasure

Under certain circumstances, you may request the deletion of your data. This is subject to our legal data retention obligations.

Right to Object

You may object to the processing of your data for direct marketing purposes at any time, without providing a reason.

Right to Data Portability

You have the right to receive your personal data in a structured, machine-readable format for transfer to another platform.

Right to Restrict Processing

Under certain circumstances, you may request that spade46 restrict the processing of your data while a dispute is being resolved.

How to Submit a Request: To exercise any of the above rights, please contact our Data Privacy Officer at privacy@spade46.bet with the email subject "Privacy Rights Request โ€“ [Full Name]". Please include a copy of your identification document for identity verification purposes. All requests are processed within 14 business days.
9

Data Retention & Deletion Policy

Spade46 retains your personal data only for as long as it is genuinely needed for the purposes outlined in this policy, or as required by applicable Malaysian law.

  • Active member account data โ€” retained for the duration of active membership plus 7 years after account closure (AML requirement)
  • Financial transaction records โ€” retained for 7 years in compliance with Malaysian legal requirements
  • Customer support communication records โ€” retained for 3 years from the date of last interaction
  • Analytics data and technical logs โ€” retained for a maximum of 24 months
  • Inactive accounts (no login for 3 years) โ€” processed for deletion after notice has been sent to the member

Once the retention period expires, spade46 will securely delete or anonymise your personal data using industry-recognised methods to ensure the data cannot be recovered.

10

Cross-Border Data Transfers

In the normal course of spade46's operations, your personal data may be processed outside Malaysia for specific purposes such as secure backup storage or processing by international game providers. Spade46 takes reasonable steps to ensure that any such data transfers are carried out with protections equivalent to those in place in Malaysia.

Safeguards we have in place for cross-border data transfers include:

  • Data processing agreements with all overseas data recipients that comply with international standards
  • Rigorous data protection assessments prior to sharing data with third parties overseas
  • Use of approved data transfer mechanisms such as standard contractual clauses
  • Data minimisation โ€” only the minimum necessary data is transferred
11

Children's Privacy & Minor Protection

Spade46 has a zero-tolerance policy on access by individuals under the age of 18. Our platform is strictly limited to adult users only. We do not knowingly collect personal data from anyone under 18.

If we discover that personal data of a child has been collected without valid parental or guardian consent, we will take immediate action to delete that data and close the associated account. If you believe a child may have submitted personal data to spade46, please contact us immediately at privacy@spade46.bet.

Spade46 employs a multi-layered age verification system that includes MyKad number checks, phone verification, and KYC document review to prevent underage access. Any individual who provides false age information during registration is in breach of spade46's Terms & Conditions and may be subject to legal action.

12

Contact the Spade46 Data Privacy Officer

Spade46 has appointed a Data Protection Officer responsible for ensuring compliance with our privacy policy and handling all privacy-related enquiries from our members. If you have any questions, concerns, or wish to exercise your privacy rights, please reach out to us through the following channels:

  • Data Privacy Officer Email: privacy@spade46.bet (processed within 14 business days)
  • Live Chat: Available 24/7 within the spade46 platform โ€” select the "Privacy & Personal Data" topic
  • General Support Email: support@spade46.bet for general privacy-related enquiries

If you are dissatisfied with our response to your privacy request, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia, appointed under the PDPA 2010. Contact details for this authority are available on the official website of the Ministry of Communications Malaysia.

Policy Updates: Spade46 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, technological developments, or new legal requirements. When significant changes are made, we will notify you via your registered email or through an in-platform notification on spade46 at least 7 days before the changes take effect. The revision date at the top of this page indicates when the last update was made.
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YOUR DATA IS PROTECTED

Play with Peace of Mind at Spade46 โ€“ Your Privacy Is Guaranteed

Now that you understand how spade46 carefully and responsibly safeguards your personal data, register today and enjoy a safe, fair, and entertaining betting experience โ€” with the assurance that your information is always protected in accordance with Malaysian law.

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