Privacy Policy
Spade54 — Your Data, Our Responsibility

1 Introduction

This Privacy Policy ("Policy") is published by Spade54 ("the Company", "we", "us", "our"), the operator of the online gaming platform accessible at spade54.cam ("the Platform"). This Policy applies to all personal data collected from individuals who visit, register on, or otherwise interact with the Platform ("Users", "you", "your").

Spade54 is committed to processing personal data in a lawful, fair, and transparent manner, consistent with applicable data protection legislation and international best practices. We act as the data controller in respect of personal data collected and processed through the Platform.

By creating an Account, making a deposit, or continuing to use the Platform after this Policy is made available to you, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact our support team to arrange closure of your Account.

2 Definitions

For the purposes of this Policy, the following terms carry the meanings assigned below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial information, and online identifiers.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, transfer, alteration, or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. Spade54 is the data controller for all personal data processed under this Policy.
• "Data Processor" — a third party that processes personal data on behalf of the data controller, pursuant to a written data processing agreement.
• "KYC" — Know Your Customer; the mandatory identity and age verification process required under applicable anti-money laundering (AML) regulations.
• "Sensitive Data" — a subset of personal data warranting enhanced protection, including financial account details, identity document numbers, and health or vulnerability information provided in connection with responsible gambling tools.
• "User" — any individual who accesses, registers on, or uses the Platform, including registered Players and unregistered visitors.

3 Data We Collect

3.1 Registration Data

When you create an Account with Spade54, we collect:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address, including city (e.g., Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam)
• Email address
• Mobile telephone number
• Preferred username and encrypted password

3.2 Identity Verification (KYC) Data

To comply with AML obligations and to verify your identity and age, we collect:

• Copy of valid government-issued identity document (Malaysian MyKad, passport, or driver's licence)
• Proof of residential address (utility bill or bank statement dated within 90 days)
• Evidence of ownership of the payment method used (e.g., screenshot from Touch 'n Go eWallet, Boost, GrabPay, or bank statement from Maybank, CIMB, Public Bank, or Hong Leong Bank)

3.3 Financial Transaction Data

We collect records of all financial transactions conducted through the Platform, including:

• Deposit amounts, timestamps, and payment method identifiers
• Withdrawal requests, amounts, and processing status
• Account balance history
• Cryptocurrency transaction hashes where USDT TRC20 is used

3.4 Gaming Activity Data

We collect records of your gaming and betting activity on the Platform, including game sessions, wager amounts, game outcomes, sport and event selections, and bonus utilisation records. This data is used for account management, dispute resolution, and responsible gambling monitoring.

3.5 Technical & Device Data

We automatically collect certain technical data when you access the Platform, including:

• IP address and approximate geolocation (country/city level)
• Device type, operating system, and browser type and version
• Session duration, pages visited, and navigation patterns
• Referral source (how you arrived at the Platform)

3.6 Communications Data

When you contact our customer support team via Live Chat or email, we retain records of those communications, including the content of the conversation and the date and time of contact, for quality assurance, dispute resolution, and training purposes.

4 How We Collect Your Data

Spade54 collects personal data through the following channels:

• Directly from you — when you complete the registration form, submit KYC documents, make deposits or withdrawals, or contact customer support.
• Automatically — through cookies, server logs, and similar technologies when you browse or use the Platform.
• From third-party providers — including identity verification services, payment processors (such as FPX, DuitNow, and e-wallet providers), and fraud detection services, who may share data with us to fulfil contractual and regulatory obligations.
• From publicly available sources — in limited circumstances, for identity verification or fraud prevention purposes only.

5 Purposes of Data Processing

We process your personal data for the following specific purposes:

6 Legal Basis for Processing

Spade54 processes personal data on the following legal bases, as applicable to each processing activity:

• Contractual Necessity: Processing required to perform the contract between you and Spade54, including Account administration, payment processing, and game delivery. Without this processing, we cannot provide our services to you.
• Legal Obligation: Processing required to comply with applicable laws, including AML regulations, KYC obligations, and financial record-keeping requirements. Compliance with these obligations is mandatory and cannot be waived.
• Legitimate Interests: Processing carried out in pursuit of Spade54's legitimate business interests, including fraud prevention, platform security, and responsible gambling monitoring, where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing of data for optional purposes, such as direct marketing communications, where you have provided explicit prior consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7 Data Sharing & Disclosure

Spade54 does not sell, rent, or trade your personal data. We share personal data only in the limited circumstances described below:

7.1 Service Providers (Data Processors)

We engage carefully vetted third-party service providers who process personal data on our behalf, subject to binding contractual obligations that restrict their use of your data to the purposes specified by Spade54. Categories of processor include:

• Payment processors and e-wallet operators (including providers facilitating Touch 'n Go eWallet, Boost, GrabPay, DuitNow, and FPX bank transfers through Maybank, CIMB, Public Bank, and Hong Leong Bank)
• Identity verification and KYC service providers
• Cloud infrastructure and hosting providers
• Fraud detection and cybersecurity service providers
• Customer support platform providers

7.2 Regulatory & Legal Disclosure

We may disclose personal data to regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, a valid legal order, or where we believe in good faith that disclosure is necessary to prevent fraud, money laundering, or harm to persons or property.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of Spade54's assets, personal data may be transferred to the acquiring entity. We will notify affected Users of any such transfer and the Privacy Policy applicable to their data following the transaction.

8 Cookies & Tracking Technologies

The Platform uses cookies and similar technologies (such as local storage and session identifiers) to operate core Platform functions and to understand how Users interact with the site. We categorise our cookies as follows:

• Strictly Necessary Cookies: Essential to the operation of the Platform. These cookies enable session authentication, maintain your logged-in status, and remember your language and display preferences. They cannot be disabled without impairing Platform functionality.
• Functional Cookies: Store your preferences (such as last visited game category or notification settings) to personalise your experience across sessions.
• Analytics Cookies: Collect anonymised, aggregated data about how Users navigate the Platform (pages visited, session duration, error events) to help us identify and resolve technical issues and improve the user experience.

We do not deploy third-party advertising, retargeting, or social media tracking cookies. You may manage or disable non-essential cookies through your browser settings. Note that disabling strictly necessary cookies will prevent certain Platform features from functioning correctly.

9 Data Retention

We retain personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and Registration Data: Retained for the duration of your Account and for a period of 5 years following Account closure, in accordance with AML record-keeping obligations.
• KYC Documents: Retained for 5 years from the date of verification, as required by applicable AML legislation.
• Financial Transaction Records: Retained for 7 years from the date of the transaction, in accordance with financial record-keeping requirements.
• Gaming Activity Logs: Retained for 3 years from the date of the activity, for dispute resolution and responsible gambling monitoring purposes.
• Customer Support Communications: Retained for 2 years from the date of last contact.
• Technical Logs: Retained for 90 days, after which they are automatically deleted or anonymised.
• Marketing Consent Records: Retained until consent is withdrawn and for 1 year thereafter, as evidence of lawful processing.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where data cannot immediately be deleted due to technical constraints, it is restricted from further processing until deletion is completed.

10 Data Security

Spade54 implements a comprehensive information security programme to protect personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest using industry-standard algorithms.
• Multi-factor authentication for internal administrative access to systems containing personal data.
• Regular independent penetration testing and security audits conducted by certified third-party specialists.
• Strict role-based access controls ensuring that personal data is accessible only to personnel who require it to perform their duties.
• Documented data breach response procedures, including notification protocols compliant with applicable regulatory requirements.

While we maintain robust security measures, no online system can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account login credentials and for ensuring the security of the device you use to access the Platform.

11 Your Rights as a Data Subject

Subject to applicable law and certain conditions, you hold the following rights in respect of your personal data processed by Spade54:

To exercise any of the above rights, please contact our Data Protection team via the Live Chat or by emailing [email protected] (plain text — not a clickable link). We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days. Where requests are complex or numerous, we may extend this period by a further 30 days, with prior notice.

We may require you to verify your identity before processing a data subject request to prevent unauthorised disclosure of personal data.

12 Children's Privacy

The Platform is strictly intended for individuals who are 21 years of age or older. Spade54 does not knowingly collect personal data from any person under the age of 21. All Account registrations are subject to mandatory age verification as part of our KYC process.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated Account. If you are a parent or guardian and believe that a minor has accessed or registered on the Platform, please contact our support team immediately via Live Chat.

13 International Data Transfers

Spade54 may transfer personal data to service providers and infrastructure systems located outside of Malaysia. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under applicable Malaysian and international data protection law.

Safeguards for international transfers may include standard contractual clauses, data processing agreements incorporating binding commitments on the data importer, or transfers to jurisdictions that provide an adequate level of data protection as recognised by relevant regulatory authority.

14 Changes to This Privacy Policy

Spade54 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Material changes will be communicated to registered Players via the email address on their Account and/or via a prominent notice on the Platform, with a minimum of 7 calendar days advance notice before the amended Policy takes effect.

Continued use of the Platform following the effective date of any amended Policy constitutes your acceptance of the revised terms. The "Effective Date" at the top of this document reflects the date on which the current version entered into force. We recommend reviewing this Policy periodically.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by Spade54, please contact us through the following channels:

• Live Chat: Available 24/7 directly from the Platform. This is the fastest channel for all enquiries, with average first-response under 2 minutes.
• Email: [email protected] (plain text — not a clickable link). We aim to respond to privacy-related enquiries within 2 business days.

Spade54 serves players across Malaysia, including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam. All correspondence regarding this Policy must be conducted in English.

For concerns relating to responsible gambling, self-exclusion, or deposit limit adjustments, please also refer to our dedicated Responsible Gambling page, or raise the matter directly with our support team. Responsible gambling requests are prioritised and handled without delay.