Privacy Policy

Spade46 (hereinafter "Spade46", "we", "us", "our") operates the online gaming and sports betting platform accessible at https://spade46.cam (the "Platform"). This Privacy Policy describes how Spade46 collects, uses, stores, discloses, and protects the personal data of individuals who access or use the Platform, including registered Players and visitors who browse the Platform without registering.

We recognise and respect the importance of personal privacy. This Policy is designed to be transparent about our data practices so that you can make informed decisions about sharing your personal information with us. We encourage you to read this document in full before registering an Account or using any Spade46 service.

This Policy should be read in conjunction with our Terms & Conditions and our responsible gambling guidelines, which together form the complete legal framework governing your relationship with Spade46.

The following definitions apply throughout this Privacy Policy:

Spade46 collects Personal Data in the following circumstances and categories:

3.1 Data Provided Directly by You

• Account Registration: Full legal name, date of birth, residential address, email address, mobile phone number, and chosen username.
• Identity Verification (KYC): Copies of government-issued identification documents (e.g., Malaysian MyKad, passport, driver's licence), proof of address documents (e.g., utility bills, bank statements in your name), and payment method verification documentation.
• Financial Transactions: Payment method details used for deposits and withdrawals (e.g., bank account references, e-wallet identifiers such as Touch 'n Go eWallet or Boost account IDs, USDT wallet addresses). We do not store full card numbers or complete banking credentials.
• Communications: Content of messages, complaints, and queries submitted to our customer support team via live chat, email, or WhatsApp.
• Responsible Gambling Elections: Deposit limit settings, self-exclusion requests, cooling-off elections, and any other responsible gambling tool preferences you activate on your Account.

3.2 Data Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and language settings.
• Usage Data: Pages visited, games accessed, session duration, betting history, game outcomes, click patterns, and navigation paths within the Platform.
• Location Data: Approximate geographic location derived from your IP address, used to verify jurisdictional eligibility and detect prohibited access from Restricted Jurisdictions.
• Cookie and Tracking Data: See Section 7 (Cookies & Tracking) for full details.

Spade46 processes Personal Data for the following specific purposes. The table below maps each processing activity to its corresponding purpose and applicable legal basis:

Spade46 processes Personal Data only where a valid legal basis exists. The primary legal bases on which we rely are as follows:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions that govern your Account, including Account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with our licensing conditions, anti-money laundering obligations, age verification requirements, and any applicable regulatory directives or court orders.
• Legitimate Interests: Processing undertaken in pursuit of Spade46's legitimate business interests, including fraud prevention, platform security, internal analytics, and responsible gambling monitoring, provided that such interests are not overridden by your fundamental privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where required by applicable law to be based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent for marketing communications at any time by adjusting your Account notification preferences or contacting customer support.

Spade46 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. Your data may be shared in the following limited and controlled circumstances only:

• Third-Party Service Providers (Processors): We engage selected third-party companies to assist in operating the Platform, including payment processors (handling MYR transactions via DuitNow, FPX, Touch 'n Go eWallet, Boost, Maybank, CIMB, and other Malaysian payment channels), KYC and identity verification service providers, fraud detection and anti-money laundering analytics providers, customer support platform operators, and cloud infrastructure and hosting services. All Third-Party Processors are bound by contractual data processing agreements that prohibit them from using your Personal Data for any purpose other than the specific service they provide to Spade46.
• Game Software Providers: Where necessary to deliver specific games on the Platform, limited transactional data (such as game session identifiers and bet amounts) may be shared with our licensed game software suppliers. These providers are bound by strict data confidentiality obligations.
• Regulatory and Law Enforcement Authorities: We may disclose Personal Data to competent regulatory authorities, law enforcement agencies, or courts where required by applicable law, licence condition, regulatory investigation, or lawful court order. We will use reasonable endeavours to notify you of such disclosure where legally permissible to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of Spade46's assets, your Personal Data may be transferred to the acquiring entity as part of that transaction, subject to appropriate confidentiality undertakings and continued compliance with this Privacy Policy.

The Spade46 Platform uses cookies and similar tracking technologies to deliver functionality, improve user experience, support security measures, and gather aggregate analytics data. Below is a summary of the cookie categories we employ:

You may manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of some Platform features. Spade46 does not serve third-party advertising cookies and does not participate in cross-site advertising networks.

Spade46 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, regulatory obligations, or legitimate business needs. The following indicative retention periods apply:

• Account Data: Retained for the duration of your active Account plus a minimum of five (5) years following Account closure, in compliance with standard anti-money laundering record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years from the date of submission or from the date of Account closure, whichever is later, in accordance with applicable AML regulations.
• Transaction Records: Full deposit and withdrawal records, including payment method references and transaction timestamps, are retained for a minimum of five (5) years.
• Customer Support Communications: Retained for a minimum of two (2) years following resolution of the relevant query or complaint.
• Marketing Consent Records: Retained for the duration of your marketing consent and for a reasonable period thereafter to evidence compliance in the event of a regulatory inquiry.
• Technical and Usage Logs: Aggregated or anonymised analytics data may be retained indefinitely. Individually identifiable usage logs are retained for a maximum of twelve (12) months.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised in a manner that prevents re-identification.

Spade46 implements a layered approach to data security, employing appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your device and the Spade46 Platform is protected by 256-bit SSL/TLS encryption. You should ensure that the padlock icon is visible in your browser's address bar when using the Platform.
• Encryption at Rest: Sensitive data stored on Spade46's servers, including KYC documentation and financial records, is encrypted at rest using industry-standard encryption protocols.
• Access Controls: Access to systems holding Personal Data is restricted on a strict need-to-know basis, protected by multi-factor authentication, and subject to regular access review audits.
• Infrastructure Security: Spade46's Platform is hosted on hardened cloud infrastructure subject to regular security patching, vulnerability scanning, and penetration testing by qualified third-party security professionals.
• Staff Training: All Spade46 personnel who handle Personal Data receive mandatory data protection and security awareness training and are bound by confidentiality obligations.
• Incident Response: Spade46 maintains a documented data breach response procedure. In the event of a personal data breach that poses a material risk to affected individuals, we will notify relevant authorities and, where appropriate, affected Data Subjects within the timeframe required by applicable law.

Subject to applicable law and any necessary verification of your identity, you have the following rights with respect to your Personal Data held by Spade46:

To exercise any of the above rights, please contact our Data Protection team via the contact details in Section 14. We will acknowledge all valid requests within a reasonable period and respond substantively within thirty (30) days, or such extended period as may be permitted by applicable law with prior notification to you.

Spade46 will verify your identity before processing any data rights request to protect against unauthorised access to your Personal Data by third parties.

The Spade46 Platform is strictly intended for use by individuals who are 21 years of age or older. We do not knowingly collect, process, or retain the Personal Data of individuals under the age of 21.

Age verification is a mandatory component of our KYC process. Any Account that is found — through verification or any other means — to belong to a person under 21 years of age will be immediately suspended. All associated Personal Data will be retained only for the minimum period required to fulfil our reporting and anti-money laundering obligations, and will thereafter be securely deleted.

If you are a parent or guardian and you believe that a minor in your care has registered an Account on the Spade46 Platform, please contact us immediately at the email address provided in Section 14. We take underage gambling concerns extremely seriously and will take prompt remedial action upon receipt of a credible notification.

Spade46 may engage Third-Party Processors located in jurisdictions outside Malaysia. Where your Personal Data is transferred to or accessed from a country other than Malaysia, Spade46 will take appropriate steps to ensure that such transfers are conducted in accordance with applicable data protection standards and that the recipient provides an adequate level of protection for your Personal Data.

Such steps may include, where appropriate, relying on adequacy decisions made by the relevant regulatory authority, implementing standard contractual clauses approved for international data transfers, or engaging only processors that participate in internationally recognised data privacy frameworks.

You may request information about the safeguards applied to any specific international transfer of your Personal Data by contacting us using the details in Section 14.

Spade46 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or business operations. Where changes are material — meaning they could significantly affect your privacy rights or the way we use your Personal Data — we will provide you with reasonable prior notice by email (to the address registered on your Account) and/or by posting a prominent notice on the Platform.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Policy periodically. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

If you have any concerns about a proposed or implemented change to this Privacy Policy, please contact us using the details provided in Section 14.

If you have any questions, concerns, or requests relating to this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 10, please contact the Spade46 data protection team using the following details. All contact information is provided as plain text only and should not be used for automated, unsolicited, or bulk communications.

• General & Privacy Enquiries: [email protected]
• Data Rights Requests: Contact via email to [email protected] with subject line "Data Rights Request — [Your Full Name]".
• Live Chat Support: Available 24 hours a day, 7 days a week, including Malaysian public holidays. Live Chat response average: 3–5 minutes.
• Languages Supported: English, Bahasa Melayu, and Mandarin Chinese.

Spade46 serves players across the whole of Malaysia, including Kuala Lumpur, Petaling Jaya, Penang, Johor Bahru, Shah Alam, Ipoh, Kota Kinabalu, Kuching, and all other cities and states. Wherever you are, our team is available to respond to your privacy concerns.