Privacy Policy

This Privacy Policy ("Policy") is published by Spade88 ("we", "us", "our", or "the Platform") and applies to all personal data collected from individuals ("you", "the User", or "the Player") who access or use the Spade88 online gaming platform, including the website at spade88.cam, any associated mobile interfaces, account management portals, live chat systems, and email communications operated by or on behalf of Spade88.

We are committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection principles. This Policy sets out the types of personal data we collect, the purposes for which we process it, the parties with whom it may be shared, how long we retain it, the security measures we apply to protect it, and the rights you hold as a data subject.

By registering an Account with Spade88, accessing the platform, or interacting with our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Spade88 platform.

In this Privacy Policy, the following terms shall carry the meanings ascribed below:

• "Personal Data" means any information relating to an identified or identifiable natural person. This includes names, identification numbers, location data, email addresses, IP addresses, and any other data that can, directly or indirectly, identify you.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, restriction, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, Spade88.
• "Data Processor" means any third party that processes personal data on behalf of the Data Controller under a contractual arrangement.
• "KYC" means Know Your Customer — the identity and age verification procedures required for regulatory compliance before certain platform functions are activated.
• "Cookies" means small data files placed on your device by a website to store session preferences, authentication tokens, and behavioural analytics data.
• "Third Party" means any person or entity other than you, Spade88, or a Data Processor acting under Spade88's instruction.
• "Sensitive Personal Data" means data revealing racial or ethnic origin, political opinions, religious beliefs, biometric data for identification purposes, health data, or data concerning a person's sexual life. Spade88 does not intentionally collect sensitive personal data beyond what is strictly required for identity verification and age compliance.

Spade88 collects the following categories of personal data in the course of operating its platform and providing services to Users:

Spade88 collects personal data through the following channels:

• Direct Submission: Data you actively provide when completing the registration form, submitting KYC documents, making a deposit or withdrawal request, contacting customer support via live chat or email, or updating your account profile.
• Automated Technical Collection: Data collected automatically when you access the Spade88 platform, including IP addresses, device identifiers, browser fingerprints, and session activity logs. This collection occurs whether or not you are logged into your Account.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, and similar technologies deployed on the Spade88 platform to maintain login state, store user preferences, and gather analytics data. For full details, refer to Section 8 (Cookies & Tracking).
• Third-Party Data Sources: In limited circumstances, Spade88 may receive data from third-party identity verification providers used in the KYC process, fraud screening services, or payment processors to validate the accuracy of information you have provided.
• Communications: When you contact Spade88 via live chat, email, or any other supported channel, we collect and retain the content of that communication and associated metadata.

Spade88 processes your personal data for the following clearly defined purposes:

1. Account Management: To register your Account, maintain your player profile, authenticate your identity at login, and provide access to the full range of Spade88 gaming and account services.
2. Transaction Processing: To process deposits and withdrawals via Malaysian payment methods (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect) and cryptocurrency channels (BTC, ETH, USDT, LTC), reconcile account balances, and maintain accurate financial records.
3. Identity & Age Verification (KYC): To verify that you are who you claim to be, that you are at least 21 years of age, and that you are not registering from a prohibited jurisdiction. This is a regulatory obligation and may be required before withdrawal processing is activated.
4. Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, money laundering, bonus abuse, account impersonation, and other prohibited activities as defined in our Terms & Conditions.
5. Platform Improvement: To analyse usage patterns, game performance data, and player behaviour (in aggregated, anonymised form where possible) to improve the platform's features, performance, and user experience.
6. Customer Support: To handle enquiries, complaints, disputes, and technical support requests submitted via live chat or email.
7. Responsible Gambling: To monitor gaming behaviour for signs of problem gambling, enforce deposit limits and self-exclusion requests, and comply with responsible gambling obligations.
8. Legal & Regulatory Compliance: To meet obligations under applicable anti-money laundering (AML) regulations, gaming licensing requirements, tax reporting obligations, and responses to lawful requests from regulatory authorities or law enforcement agencies.
9. Marketing Communications (Opt-in Only): To send promotional emails, bonus notifications, and platform updates to Players who have explicitly opted in to marketing communications. You may withdraw your consent at any time by updating your account preferences or contacting support.

Spade88 processes personal data on one or more of the following lawful bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to fulfil the agreement between Spade88 and the Player — including account registration, transaction processing, and the delivery of gaming services.
• Legal Obligation: Processing required to comply with applicable law — including KYC/AML obligations, age verification requirements, and responses to lawful regulatory or law enforcement requests.
• Legitimate Interests: Processing necessary for Spade88's legitimate business interests where these are not overridden by the Player's fundamental rights. This includes fraud detection, platform security, analytics, and internal business operations.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Spade88 does not sell, rent, or commercially trade your personal data with any third party. We may share your personal data with the following categories of recipients only to the extent strictly necessary for the purposes described in this Policy:

• Payment Service Providers: Third-party payment processors and gateway operators that facilitate deposit and withdrawal transactions on Spade88 — including those supporting Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and banking integrations with Maybank2u, CIMB Clicks, Public Bank Online, and Hong Leong Connect. These processors receive only the minimum data required to execute transactions.
• Identity Verification Providers: Third-party KYC and AML service providers engaged to verify the identity and age of Players, and to screen against relevant sanctions lists or politically exposed persons databases.
• Technology & Infrastructure Partners: Cloud hosting providers, content delivery networks, cybersecurity services, and platform software vendors that process data on Spade88's behalf under strict data processing agreements.
• Regulatory Authorities & Law Enforcement: Where required by applicable law, court order, or lawful regulatory demand, Spade88 may disclose personal data to the relevant governmental or regulatory authority. We will notify you of such disclosure where legally permitted to do so.
• Professional Advisers: Legal counsel, auditors, and compliance consultants acting under duties of professional confidentiality.
• Business Succession: In the event of a merger, acquisition, restructuring, or sale of Spade88 or its relevant business assets, personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

Spade88 uses cookies and similar tracking technologies to operate the platform, maintain session continuity, and gather analytical data. The following categories of cookies are deployed:

• Strictly Necessary Cookies: Essential for the platform to function. These include session tokens, authentication cookies, and security identifiers. They cannot be disabled without impairing platform functionality.
• Functional Cookies: Store your preferences such as language settings, login state, and responsible gambling configuration. These enhance your experience but are not strictly required for core functionality.
• Analytical Cookies: Collect aggregated, anonymised data on how Players navigate and use the platform — including pages visited, time on page, and game interactions. Used to improve platform performance and UX.
• Security Cookies: Used for fraud detection and bot prevention — analysing device fingerprints, IP addresses, and behavioural patterns to identify suspicious account activity.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the Spade88 platform. Spade88 does not deploy third-party advertising or cross-site tracking cookies.

Spade88 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of the account relationship, plus a minimum of five (5) years following account closure, to comply with AML, KYC, and gaming regulatory retention requirements.
• Financial Transaction Records: Retained for a minimum of seven (7) years from the date of the transaction to comply with applicable financial record-keeping and tax reporting obligations.
• Communications (Support Interactions): Retained for two (2) years from the date of the interaction, or longer where the communication is relevant to an ongoing dispute or regulatory investigation.
• Technical and Usage Data: Retained in aggregated, anonymised form for up to three (3) years for platform analytics and performance improvement purposes.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, in compliance with AML regulatory requirements.
• Marketing Preferences: Retained until consent is withdrawn or the account is closed. Post-closure, a record of opt-out status is maintained for compliance purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with Spade88's data disposal procedures.

Spade88 implements a comprehensive set of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and the Spade88 platform is encrypted using 256-bit SSL/TLS protocols, providing the same level of protection used by major Malaysian banking portals including Maybank2u and CIMB Clicks.
• Encryption at Rest: Personal data and financial records stored on Spade88's servers are encrypted at rest using industry-standard AES-256 encryption.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis, enforced through role-based access control (RBAC) systems and multi-factor authentication for staff with data access privileges.
• Infrastructure Security: Spade88's platform is hosted on secured cloud infrastructure with intrusion detection systems, web application firewalls, and regular penetration testing.
• Data Breach Response: Spade88 maintains an incident response plan for data breach scenarios. In the event of a breach that is likely to result in a high risk to your rights and freedoms, we will notify affected individuals without undue delay in accordance with applicable notification requirements.
• Staff Training: All Spade88 personnel with access to personal data receive regular data protection and information security training.

Subject to applicable law, you hold the following rights with respect to the personal data Spade88 holds about you. To exercise any of these rights, please contact us at [email protected] with your Account username and a clear description of your request. We will respond within thirty (30) calendar days.

The Spade88 platform is strictly intended for adults aged 21 years and above. Spade88 does not knowingly collect personal data from individuals under the age of 21. Registration on the platform by any person under the minimum age is a violation of our Terms & Conditions and is subject to immediate account termination.

If Spade88 becomes aware that personal data has been collected from a person under the age of 21 without appropriate age verification, such data will be deleted immediately and any associated Account will be permanently closed. Any balances in such an Account will be dealt with in accordance with applicable regulatory requirements.

All deposits, withdrawals, and promotional interactions on the platform are subject to identity verification procedures designed to confirm minimum age compliance. If you believe that a minor may have registered on the Spade88 platform using your details or those of someone in your household, please contact us immediately at [email protected].

As an online gaming platform serving players primarily in Malaysia, including those in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam, some of Spade88's infrastructure and service providers may process personal data in jurisdictions outside of Malaysia. This may include cloud hosting providers and KYC verification services operating in other countries.

Where personal data is transferred outside Malaysia, Spade88 ensures that appropriate safeguards are in place to maintain an equivalent level of data protection. These safeguards may include:

• Standard contractual clauses approved by the relevant data protection authority.
• Transfers to jurisdictions that provide an adequate level of protection for personal data as determined under applicable law.
• Binding corporate rules where the transfer is within a corporate group subject to such rules.

The Spade88 platform may contain references to third-party payment processors, licensing authorities, or industry bodies. While Spade88 does not include external hyperlinks in its published content, interactions with third-party payment gateways (for example, when completing a deposit via a bank's online portal) will involve that third party's own privacy practices.

Spade88 is not responsible for the privacy practices of any third-party entity. We encourage you to review the privacy policies of any third-party service you interact with in connection with your Spade88 account activities, particularly payment service providers such as Touch 'n Go eWallet, Boost, GrabPay, or your banking institution.

Spade88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform operations. Material amendments will be communicated to registered Players via email notification to the address on file and/or by a prominent notice displayed on the Spade88 platform for a minimum of 14 days prior to the amended Policy taking effect.

The "Last Updated" date displayed at the top of this Policy indicates when the most recent revision was published. We recommend reviewing this Policy periodically to remain informed of how Spade88 protects your personal data. Continued use of the platform following publication of an updated Policy constitutes your acceptance of the revised terms.

If a material change affects the basis on which we process your personal data in a way that requires fresh consent, we will seek that consent through an appropriate mechanism before continuing such processing.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the Spade88 Data Privacy team using the details below. All data-related enquiries are handled in English:

If you are not satisfied with Spade88's response to a privacy complaint, you may have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction.

This Privacy Policy was last updated on 1 January 2026. Spade88 reserves all rights not expressly granted herein. For entertainment purposes only. 21+ only.