Phspin Privacy Policy – Personal Data Protection for Malaysian Players

Phspin collects two main categories of information from platform users — information you provide directly to us, and information collected automatically as you use the phspin platform.

Information You Provide Directly:

• Identity Information: Full name as stated on your MyKad or valid identification document, date of birth, gender, and MyKad number (for identity verification purposes).
• Contact Information: An active email address, Malaysian mobile number, and current residential address.
• Financial Information: Bank account numbers or e-wallet details (Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow) used for deposits and withdrawals. phspin does not store credit or debit card numbers directly — card transactions are processed by certified third-party payment providers.
• Verification Documents: A copy of your MyKad or passport submitted during the KYC (Know Your Customer) process.
• Account Information: Username, password stored in encrypted hash form, and account preference settings.

Information Collected Automatically:

• Usage Data: Pages visited, games played, session duration, login frequency, and betting patterns.
• Technical Data: IP address, browser type and version, device type, operating system, and screen resolution.
• Location Data: General location information based on IP address, used to verify that you are accessing the platform from Malaysia and for security purposes.
• Cookie Data: Session information, user preferences, and analytics data collected through cookies and similar technologies (see Section 6 for details).

Phspin collects your personal information through the following channels:

• Account Registration: When you create a new account at phspin, you will be asked to complete a registration form with basic details such as your name, email address, phone number, and date of birth.
• KYC Process: When you submit your first withdrawal request, phspin will ask for identity verification documents to comply with legal anti-money laundering (AML) and KYC requirements.
• Financial Transactions: Each time you make a deposit or withdrawal using Malaysian payment methods such as Touch 'n Go eWallet, GrabPay, DuitNow, or FPX, the transaction details are recorded in phspin's system.
• Platform Usage: Data is collected automatically as you browse the phspin platform, play games, or interact with platform features through cookie and session-tracking technologies.
• Support Communications: When you contact the phspin support team via live chat, email, or WhatsApp, the contents of the conversation and any information you provide are stored for reference and service improvement purposes.
• Feedback & Surveys: If you participate in a customer satisfaction survey or provide feedback to phspin, that information is collected and retained.

Phspin never collects your personal information from third-party sources without your knowledge and consent, except where permitted or required by law.

Phspin uses collected personal information solely for legitimate and transparent purposes. The table below outlines each purpose for data use along with its corresponding legal basis:

Phspin will not use your data for any purpose beyond those stated in the table above without first obtaining your explicit consent. Should we wish to use your data for a new purpose, we will inform you and seek fresh consent where required.

Phspin takes seriously its responsibility to protect your privacy in all dealings involving third parties. We do not sell or disclose your personal information to third parties except in the following limited circumstances:

• Payment Service Providers: To process your deposits and withdrawals via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX, the minimum necessary transaction information is shared with the respective payment providers. All payment providers we work with comply with the stringent PCI DSS security standard.
• Game Service Providers: To deliver slots, Live Casino, and table games, session information and minimum bet details may be shared with independently licensed and audited game software providers.
• Regulatory Authorities: phspin is legally required to disclose certain information to the relevant authorities in Malaysia upon lawful request, including for financial crime investigations, money laundering, or licensing compliance.
• Technical Service Providers: Hosting providers, cloud services, and analytics tools used by phspin may have limited access to data for technical purposes only. All such providers are bound by strict confidentiality agreements.

Every third party that receives your data from phspin is contractually bound to use it only for the specified purpose and to protect it to a standard equal to or higher than phspin's own security practices.

Phspin continually invests in robust data security infrastructure to ensure your personal information is always protected against unauthorised access, disclosure, alteration, or destruction. The technical and organisational security measures we implement include:

• Data Encryption in Transit: All data transmitted between your browser or app and phspin's servers is protected by TLS 1.3 with AES-256 encryption — the highest security standard currently available.
• Data Encryption at Rest: Sensitive data such as identification numbers, financial information, and passwords are stored in fully encrypted form using industry-recognised encryption algorithms.
• Strict Access Controls: Access to user data within phspin's systems is restricted to staff with a legitimate business need. All access is logged and monitored. Employees who leave the company have their access rights revoked immediately.
• Two-Factor Authentication (2FA): All phspin internal systems that store user data are protected by mandatory 2FA for all staff. We also offer 2FA as an option for user accounts.
• 24/7 Security Monitoring: An automated threat detection system monitors all activity on the phspin platform around the clock to detect and respond to any unauthorised access attempts or suspicious activity.
• Regular Security Audits: phspin undergoes penetration testing and security audits conducted by accredited independent firms at least once a year.

While phspin takes all reasonable precautions, no digital security system can guarantee 100% absolute protection. In the event of a data breach involving your personal information, phspin is committed to notifying you within 72 hours of becoming aware of the breach, in line with industry best practices.

Phspin uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and understand how the platform is used for ongoing improvement purposes.

Types of cookies we use:

• Essential Cookies (Required): These cookies are necessary for the phspin platform to function properly. They manage your login session, store security preferences, and ensure a smooth gaming experience. These cookies cannot be disabled without affecting platform functionality.
• Performance & Analytics Cookies: These cookies help phspin understand how members use the platform — which pages are visited most frequently, how long sessions last, and where users encounter difficulties. This data is used in aggregate to improve the phspin platform and is not linked to any individual's identity.
• Functional Cookies: These cookies store your preferences — such as interface language, preferred betting limits, and display settings — to deliver a more personalised experience on your next visit.
• Marketing Cookies (Optional): With your consent, phspin uses cookies to display relevant promotional offers based on your gaming activity. You may decline these cookies during your first visit or through the cookie settings in your account at any time.

Phspin does not use cross-site tracking technology to follow your activity outside of the phspin platform. Data collected through cookies is limited solely to your interactions within the phspin ecosystem.

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and international privacy best practices, you have the following rights regarding your personal data held by phspin:

Phspin retains your personal data only for as long as it is needed for the purposes described in this Privacy Policy, or as required under applicable Malaysian law.

Phspin's data retention guidelines are as follows:

• Active Account Data: For as long as your account remains active with phspin, all account and transaction data is retained for operational and customer support purposes.
• Data After Account Closure: Identity information and financial transaction records are retained for 7 years after account closure to comply with the legal requirements of Malaysia's Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA).
• Support Communication Logs: Customer support communication records are retained for 3 years for reference and resolution of any disputes that may arise.
• Anonymised Analytics Data: Fully anonymised usage data (containing no personal identifiers) may be retained for a longer period for analytics and platform improvement purposes.
• Inactive Account Data: Accounts that have been inactive for 12 consecutive months may be archived. Data within an archived account is retained for the same period stated above, but active access to the platform may be restricted until you contact us to reactivate your account.

Phspin reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or changes to the services we offer. We are committed to notifying you of any material changes to this policy.

The notification procedure for amendments to the Privacy Policy is as follows:

• An email notification will be sent to your registered address at least 30 days before any material changes take effect — a longer notice period than most standard terms documents, given the more direct implications for your privacy rights.
• In-platform notifications will be displayed when you log in to your phspin account.
• The latest version of the Privacy Policy is always available on this page, with the date of the most recent update clearly displayed at the top.

If you do not agree with the amended Privacy Policy, you have the right to close your phspin account before the amendment takes effect and to request deletion of your personal data in accordance with the procedure set out in Section 7. Continued use of the phspin platform after the effective date of any changes will be deemed acceptance of the amended Privacy Policy.

We strongly encourage you to review this Privacy Policy page periodically. If you have any questions about changes made, phspin's support team is available via 24/7 live chat or email.

Phspin has appointed a Data Privacy Officer responsible for ensuring compliance with our privacy policy and handling all privacy-related enquiries from members. If you have any questions, concerns, or complaints regarding how phspin handles your personal data, please reach us through the following channels:

If you are not satisfied with phspin's response to your privacy complaint, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia under the Ministry of Communications and Digital. phspin is fully committed to cooperating with regulatory authorities in any privacy-related investigations.