Privacy Policy

1. About This Policy

This Privacy Policy applies to all personal data processed by spade46 ("the Company", "we", "us", "our") in connection with your use of the spade46 platform, website, mobile application, and related services (collectively, the "Platform"). "Personal data" means any information that identifies or could reasonably identify you as an individual.

By registering a spade46 account or continuing to use the Platform after being made aware of this policy, you acknowledge that you have read and understood how your personal data is processed as described herein. If you do not agree to this Privacy Policy, you must discontinue use of the Platform.

This policy should be read together with the spade46 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data We Collect

2.1 Account & Identity Data

When you register a spade46 account, we collect: full legal name, date of birth, gender, email address, Malaysian mobile phone number, and chosen username. Where KYC (Know Your Customer) verification is required, we may additionally collect: Malaysian Identity Card (MyKad) number and scan, passport details, proof of residential address, and source-of-funds documentation.

2.2 Financial & Transaction Data

We collect records of all financial transactions on the Platform, including deposit amounts and methods (e.g., Touch 'n Go eWallet, Boost, FPX, DuitNow), withdrawal requests and method details, bonus claims, wagering history, account balance movements, and any cryptocurrency wallet addresses used for USDT TRC20 transactions.

2.3 Technical & Usage Data

We automatically collect certain technical data when you access the Platform, including: IP address, device type and operating system, browser type and version, session timestamps and duration, pages and games accessed, clickstream data, and mobile device identifiers (where applicable).

2.4 Communications Data

We retain records of communications between you and spade46, including Live Chat transcripts, support ticket correspondence, and any written communications submitted through the Platform. This data is used for service delivery, dispute resolution, and regulatory compliance.

3. How We Collect Data

spade46 collects personal data through the following means:

• Directly from you — during registration, account verification, deposit/withdrawal requests, and communications with our support team.
• Automatically — through cookies, server logs, and analytics tools as you interact with the Platform.
• From third parties — including payment processors (to confirm transaction status), KYC verification service providers, and fraud detection partners, all of whom are bound by appropriate data protection agreements.
• From game studios — aggregated session and wagering data from third-party game providers integrated into the Platform.

4. Legal Basis for Processing

spade46 processes your personal data on the following legal bases:

• Contractual necessity — processing required to provide the Platform services you have contracted for, including account management, payment processing, and game access.
• Legal obligation — processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, KYC obligations, and responsible gaming mandates.
• Legitimate interests — processing for fraud prevention, platform security, abuse detection, and service improvement, where these interests are not overridden by your privacy rights.
• Consent — for marketing communications and non-essential cookies, where we rely on your active opt-in consent, which you may withdraw at any time.

5. How We Use Your Data

spade46 uses your personal data for the following purposes:

• Creating, managing, and maintaining your spade46 account.
• Processing deposits and withdrawals via your chosen Malaysian payment methods.
• Verifying your identity and age (21+) in compliance with our KYC obligations.
• Delivering customer support and resolving disputes or complaints.
• Detecting, investigating, and preventing fraud, money laundering, collusion, and other prohibited conduct.
• Administering bonuses, promotions, and loyalty programmes.
• Monitoring for responsible gaming indicators and applying protective measures where required.
• Sending transactional communications (account alerts, OTPs, withdrawal confirmations).
• Sending promotional communications (where you have opted in and not subsequently opted out).
• Improving the Platform through usage analytics and performance monitoring.
• Complying with regulatory reporting obligations.

spade46 does not use your personal data to make solely automated decisions that produce legal or significant effects upon you without human review, except where required by applicable law.

6. Data Sharing & Disclosure

spade46 does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and under appropriate data protection safeguards:

• Payment processors — including banks, e-wallet providers (Touch 'n Go, Boost, GrabPay), and DuitNow/FPX infrastructure partners, for the purpose of executing your financial transactions.
• KYC and fraud prevention providers — third-party identity verification and fraud detection services engaged by spade46.
• Game studio partners — limited technical identifiers shared with certified game studios to enable game session functionality.
• IT and infrastructure providers — hosting, cloud storage, and cybersecurity service providers operating under data processing agreements.
• Regulatory and law enforcement authorities — where spade46 is legally required or compelled to disclose data in response to lawful requests, court orders, or regulatory investigations.
• Business successors — in the event of a merger, acquisition, or asset sale, your data may be transferred to the successor entity subject to equivalent privacy protections.

7. Cookies & Tracking Technologies

7.1 What We Use

spade46 uses cookies (small text files stored on your device) and similar tracking technologies (web beacons, pixel tags, local storage) to operate and improve the Platform. Cookies are categorised as:

• Strictly Necessary — required for Platform functionality including login sessions, security tokens, and payment flows. These cannot be disabled.
• Performance & Analytics — used to understand how Members use the Platform, identify errors, and measure feature adoption.
• Functional — remember your preferences (e.g., language, preferred games) to personalise your experience.
• Marketing — used only with your consent to deliver relevant promotional content. You may opt out at any time.

7.2 Managing Cookies

You may control cookie preferences through the cookie banner displayed on your first visit to the Platform, or via your browser settings. Disabling strictly necessary cookies will impair Platform functionality, including the spade46 Login process.

8. Data Retention

spade46 retains personal data for as long as necessary to fulfil the purposes described in this policy, and in any case for the minimum periods required by applicable laws and regulations. As a general guide:

• Account and transaction records are retained for a minimum of five (5) years after account closure, in line with standard AML record-keeping requirements.
• KYC documentation is retained for the duration of the account relationship and for a minimum of five (5) years thereafter.
• Support communications are retained for a minimum of three (3) years after resolution.
• Technical and usage logs are retained for up to twelve (12) months.

Following the applicable retention period, data is securely deleted or anonymised such that it can no longer be linked to an identifiable individual.

9. Data Security

spade46 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the Platform.
• Encryption of sensitive data at rest, including financial records and KYC documents.
• Role-based access controls limiting employee access to personal data strictly to what is required for their function.
• Two-factor authentication (2FA) for account access, which we strongly encourage all Members to enable.
• Regular security audits and penetration testing of Platform infrastructure.
• Incident response procedures for detecting, reporting, and responding to personal data breaches.

No method of electronic transmission or storage is 100% secure. While spade46 takes all reasonable precautions, we cannot guarantee absolute security. In the event of a material data breach affecting your personal data, we will notify affected Members in accordance with applicable requirements.

10. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data held by spade46:

• Right of Access — you may request a copy of the personal data spade46 holds about you.
• Right to Rectification — you may request correction of inaccurate or incomplete personal data.
• Right to Erasure — you may request deletion of your personal data where there is no longer a legal or contractual basis for its retention. Note that regulatory record-keeping obligations may prevent full erasure in certain cases.
• Right to Restriction — you may request that we restrict processing of your data in certain circumstances.
• Right to Data Portability — you may request a structured, machine-readable copy of personal data you have provided to us, where technically feasible.
• Right to Object — you may object to processing of your data for direct marketing purposes at any time, or to processing based on legitimate interests where you have grounds relating to your particular situation.
• Right to Withdraw Consent — where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact the spade46 Data Protection team via Live Chat or at: [email protected]. We will respond to verifiable requests within thirty (30) calendar days. We may need to verify your identity before processing your request.

11. Children's Privacy

The spade46 Platform is strictly intended for individuals aged 21 years and above. 21+ spade46 does not knowingly collect personal data from individuals below this age. If we become aware that personal data has been collected from a person below the minimum age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please notify us immediately at [email protected].

12. Policy Updates

spade46 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform operations. When material changes are made, we will update the "Last Updated" date at the top of this document and, where appropriate, notify affected Members via their registered email address or a prominent notice on the Platform. Your continued use of spade46 following the effective date of any updated policy constitutes your acknowledgement of the changes.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or spade46's data practices, please contact us:

• Live Chat — available 24/7 via the Platform (fastest response, typically under 3 minutes).
• Email: [email protected]

For disputes that cannot be resolved directly with spade46, you may also contact the relevant data protection authority in your jurisdiction.