Privacy Policy

1. Introduction

spade46 ("spade46", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who access or use the spade46 platform at https://spade46.club. This Privacy Policy ("Policy") describes the types of personal data we collect, the purposes for which it is processed, how it is stored and protected, with whom it may be shared, and the rights available to you as a data subject.

This Policy applies to all registered players, visitors to the spade46 website, and individuals who interact with spade46 through any channel including live chat and support email. By registering an account or continuing to use the spade46 platform following the posting of any updated version of this Policy, you acknowledge that you have read and understood its terms.

This Policy should be read alongside the spade46 Terms & Conditions, which govern the overall legal relationship between you and spade46.

2. Data Controller

spade46 operates as the data controller with respect to the personal data of registered players and platform visitors. As data controller, spade46 determines the purposes and means of processing your personal data in accordance with applicable data protection legislation and the requirements of our international gaming authority licence.

All data protection queries, subject access requests, and complaints should be directed to the spade46 support team. Contact details are provided in Section 15 of this Policy.

3. Data We Collect

spade46 collects the following categories of personal data:

3.1 Registration & Identity Data

• Full legal name as it appears on government-issued identification;
• Date of birth and age verification information;
• Residential address, including postcode and state;
• Email address;
• Mobile phone number.

3.2 KYC Verification Data

• Government-issued photo identification (MyKad, passport, or equivalent);
• Proof of address documentation (utility bill, bank statement);
• Proof of payment method ownership where required;
• Selfie or liveness verification where requested.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts, dates, and payment method references;
• Betting and gaming activity records;
• Account balance history.

3.4 Technical & Usage Data

• IP address and approximate geolocation at time of access;
• Device type, operating system, and browser version;
• Session timestamps and duration;
• Pages visited and features accessed within the spade46 platform;
• Cookie identifiers and analytics identifiers.

3.5 Communications Data

• Records of live chat conversations with spade46 support;
• Email correspondence;
• Feedback and complaint records.

4. How We Collect Data

spade46 collects personal data through the following channels:

• Direct registration: Data you provide when creating your spade46 account, completing KYC, or updating account settings;
• Platform interaction: Data generated automatically when you use the spade46 website, including session logs, device fingerprinting, and cookie data;
• Payment processing: Transaction data received from our licensed payment partners when you make a deposit or withdrawal;
• Support interactions: Data exchanged during live chat, email support, or formal complaint processes;
• Third-party verification: Identity and fraud-check data received from licensed KYC and AML service providers with whom spade46 contracts.

5. Purposes & Legal Basis for Processing

spade46 processes personal data for the following purposes and under the following legal bases:

• Account registration and management — necessary for the performance of the contract between you and spade46;
• Identity verification and KYC compliance — necessary for compliance with our legal obligations under gaming and anti-money laundering regulations;
• Processing deposits, bets, and withdrawals — necessary for the performance of the contract;
• Fraud prevention and security monitoring — necessary for our legitimate interests in protecting the platform and its players;
• Customer support — necessary for the performance of the contract and our legitimate interest in maintaining service quality;
• Regulatory reporting — necessary for compliance with legal obligations under our gaming authority licence;
• Responsible gaming monitoring — necessary for our legal obligations and legitimate interest in player welfare;
• Platform analytics and improvement — based on our legitimate interest in developing and improving spade46 services, subject to your right to object;
• Marketing communications — based on your consent, where you have opted in to receive promotional communications. You may withdraw consent at any time.

6. Sharing Your Data

spade46 does not sell, rent, or trade your personal data to third-party marketing organisations. We may share your data with the following categories of recipients, strictly limited to what is necessary for the stated purpose:

• Licensed payment service providers — to process deposits and withdrawals via Touch n Go eWallet, Boost, DuitNow, FPX, Maybank, CIMB, Public Bank, Visa, Mastercard, and other accepted methods;
• Identity verification and KYC providers — to verify player identity and conduct AML checks as required by our licence obligations;
• Fraud prevention services — to detect and prevent fraudulent account activity and protect the integrity of the platform;
• Regulatory and licensing authorities — as required under our international gaming authority licence for regulatory reporting, audit, and compliance purposes;
• Law enforcement and legal authorities — where required or permitted by applicable law, including in response to a court order or to comply with legal proceedings;
• Technology and infrastructure providers — cloud hosting, database, and platform support providers who process data on our behalf under strict contractual data processing agreements.

All third parties with whom spade46 shares personal data are required to implement appropriate security measures and to process data only for the specified purpose and in accordance with applicable data protection law.

7. International Data Transfers

spade46 may transfer personal data to service providers and infrastructure partners located outside Malaysia. Where such transfers occur, spade46 ensures that appropriate safeguards are in place — including contractual data transfer agreements, equivalent data protection standards, or the use of providers operating in jurisdictions with recognised adequate protections — to maintain the security and integrity of your personal data throughout the transfer.

8. Data Retention

spade46 retains personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law and our gaming authority licence obligations. Specific retention periods include:

• Active account data: Retained for the duration of your account and for a minimum of five years following account closure;
• Transaction and betting records: Retained for a minimum of five years to comply with anti-money laundering and gaming audit requirements;
• KYC documents: Retained for a minimum of five years from the date of verification or account closure, whichever is later;
• Support communications: Retained for up to three years from the date of the communication;
• Analytics and usage data: Retained in aggregated or anonymised form for internal analysis purposes without retention limit.

Data that is no longer required for any legitimate purpose and is not subject to a legal retention obligation will be securely deleted or irreversibly anonymised.

9. Cookies & Tracking Technologies

spade46 uses cookies and similar tracking technologies on the platform. Cookies are small data files stored on your device that help us maintain your session, remember your preferences, and analyse how the platform is used.

The categories of cookies used by spade46 include:

• Essential cookies: Required for core platform functionality including login session management, game loading, and deposit processing. These cannot be disabled without affecting platform usability;
• Preference cookies: Store your language preference and display settings to improve your experience;
• Analytics cookies: Collect aggregated, anonymised data on page visits, session duration, and feature usage to help us improve the platform;
• Security cookies: Support fraud detection and account security functions including device fingerprinting and anomalous login detection.

You can manage or disable non-essential cookies through your browser settings. Disabling essential cookies will prevent login and access to platform features. spade46 does not use advertising or cross-site tracking cookies.

10. Your Rights as a Data Subject

Subject to applicable law and any overriding legal obligations, you have the following rights with respect 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 it is no longer necessary, subject to our legal retention obligations;
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, for example while a dispute is being resolved;
• Right to Data Portability: You may request a copy of your data in a structured, commonly used, and machine-readable format where technically feasible;
• Right to Object: You may object to processing based on legitimate interests, including direct marketing. Objections to marketing will be honoured immediately;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please contact the spade46 support team via live chat or support email. We aim to respond to all data subject requests within 30 days. Where a request is complex or numerous, we may extend this by a further two months, with prior notification.

11. Children's Privacy

The spade46 platform is strictly for adults. 21+ spade46 does not knowingly collect personal data from individuals under the age of 21. Where we become aware that a minor has registered an account or submitted personal data, we will take immediate steps to close the account, delete the data, and if applicable, refund any deposited funds. Age verification is conducted as part of the account registration and KYC process for all players.

12. Security Measures

spade46 implements a comprehensive set of technical and organisational security measures to protect your personal data, including:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the spade46 platform;
• AES-256 encryption for sensitive data stored in our databases;
• Role-based access controls limiting data access to authorised personnel on a need-to-know basis;
• Multi-factor authentication for platform administrative access;
• Continuous intrusion detection and monitoring systems;
• Regular security audits and penetration testing by independent third parties;
• Formal incident response procedures including breach notification protocols.

In the event of a data breach that poses a risk to your rights and freedoms, spade46 will notify the relevant regulatory authority within 72 hours of becoming aware of the breach, and will inform affected players without undue delay where required by law.

13. Third-Party Links

The spade46 platform may contain references to game providers and other third-party services. spade46 does not embed third-party marketing links or direct players to external websites from within the platform content. Where third-party services are integrated (such as licensed game providers), those providers operate under their own privacy policies with respect to data they independently collect. spade46 is not responsible for the privacy practices of third-party game studios or platform integrations.

14. Changes to This Policy

spade46 reserves the right to update or amend this Privacy Policy at any time. Material changes — including changes to the purposes for which we process your data, the categories of data collected, or your rights — will be communicated to registered players via the email address on file and by a prominent notice on the platform prior to the changes taking effect. The date at the top of this Policy indicates when it was last updated. Continued use of the spade46 platform following a notified change constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you should cease using the platform and contact support to close your account.

15. Contact Us

For privacy-related enquiries, subject access requests, data deletion requests, or complaints regarding spade46's handling of your personal data, please contact our support team:

• Live Chat: Available 24/7 directly via the spade46 website
• Email: [email protected]
• Response Time: We aim to acknowledge all privacy requests within 48 hours and resolve them within 30 calendar days

If you are dissatisfied with our response to a privacy complaint, you may have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction.