Privacy Policy – ezspin5

1 Overview and Scope of This Privacy Policy

This Privacy Policy ("Policy") is published by ezspin5 (hereinafter "ezspin5," "we," "us," "our"), the operator of the online gaming platform accessible at ezspin5.co and its associated subdomains and mobile interfaces (collectively, "the Platform").

This Policy applies to all personal data collected from individuals ("you," "Player," "User") who access, register on, or interact with the ezspin5 Platform, including prospective players who visit the website without completing registration. It covers data collected via the Platform's website, live chat support, email communications, and any promotional channels operated by ezspin5.

ezspin5 is the data controller for personal data processed under this Policy. This means ezspin5 determines the purposes and means by which your personal data is processed.

This Policy is incorporated by reference into the ezspin5 Terms & Conditions. By registering or using the ezspin5 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing activities described herein.

2 Categories of Personal Data We Collect

ezspin5 collects the following categories of personal data from Players:

ezspin5 does not collect special categories of sensitive personal data (such as racial origin, health data, or biometric data) except where liveness verification is used as part of the KYC process, in which case facial image data is processed solely for identity verification and immediately deleted after the verification outcome is determined.

3 How We Collect Your Personal Data

ezspin5 collects personal data through the following channels:

• Directly from you: when you register an account, complete KYC, make a deposit or withdrawal, contact customer support, participate in a promotion, or update your account settings on the ezspin5 Platform.
• Automatically: when you browse or interact with the ezspin5 Platform, through server logs, session cookies, analytics tracking, and fraud detection systems that capture technical and behavioural data.
• From third-party KYC providers: ezspin5 may use licensed third-party KYC verification services to validate identity documents. These providers share the verification outcome and, where relevant, document validity status with ezspin5.
• From payment service providers: transaction data and payment method confirmation is received from ezspin5's integrated payment processors, including FPX gateway partners and e-wallet operators.
• From fraud prevention services: ezspin5 may receive risk signals and device fingerprinting data from third-party fraud prevention tools to protect the Platform and its users.

4 Purposes for Which We Process Your Data

ezspin5 processes personal data for the following purposes:

1. Account Registration and Management: to create and maintain your ezspin5 account, verify your identity, and provide access to Platform services.
2. KYC and Regulatory Compliance: to fulfil our obligations under international gaming authority licensing requirements, including mandatory age verification and anti-money laundering (AML) screening.
3. Payment Processing: to process deposits, withdrawals, and refunds in MYR via approved Malaysian payment methods including Touch 'n Go eWallet and FPX bank transfers.
4. Fraud Prevention and Security: to monitor account activity for suspicious behaviour, prevent unauthorised access, detect multi-accounting, and protect the integrity of the Platform.
5. Responsible Gaming: to monitor gaming behaviour for indicators of problem gambling, enforce deposit limits and self-exclusion instructions, and contact Players who may require responsible gaming support.
6. Customer Support: to respond to enquiries, resolve disputes, and provide technical assistance to ezspin5 Players.
7. Marketing Communications: to send promotional offers, bonus notifications, and event updates to Players who have opted in to marketing communications from ezspin5. You may opt out at any time via account settings.
8. Platform Analytics and Improvement: to understand how Players use the ezspin5 Platform and to improve game library, UX, payment flows, and support quality.
9. Legal and Regulatory Obligations: to comply with applicable legal requirements, respond to lawful requests from regulatory or law enforcement authorities, and manage legal claims.

5 Legal Basis for Processing

ezspin5 processes your personal data on the following legal bases:

• Contractual necessity: processing required to perform the contract between ezspin5 and the Player — including account operation, payment processing, and gaming service provision.
• Legal obligation: processing required to comply with ezspin5's licensing conditions, AML obligations, KYC requirements, and any applicable regulatory directives.
• Legitimate interests: processing conducted in ezspin5's legitimate business interests, including fraud prevention, security monitoring, platform analytics, and responsible gaming monitoring — where these interests are not overridden by the Player's rights.
• Consent: processing based on your explicit consent, specifically marketing communications. Consent may be withdrawn at any time without affecting prior processing.

6 Data Sharing and Third-Party Disclosure

ezspin5 does not sell personal data to third parties. We may share personal data with the following categories of recipients in the following circumstances:

• KYC and Identity Verification Providers: licensed identity verification services used to validate MyKad and other documents during account registration and ongoing compliance reviews.
• Payment Processors: banks, e-wallet operators (Touch 'n Go, Boost), DuitNow participants, and FPX gateway partners required to process deposits and withdrawals.
• Fraud Prevention and Security Services: third-party fraud detection and device fingerprinting tools that assist ezspin5 in identifying suspicious account activity.
• Game Providers: game session data (session ID, bet amounts, RNG outcomes) is shared with ezspin5's game providers for the purpose of game operation and dispute resolution. Game providers do not receive your identity or payment information.
• Legal and Regulatory Authorities: where required by applicable law, court order, or regulatory direction, ezspin5 will disclose personal data to law enforcement agencies, financial intelligence units, or licensing authorities.
• Professional Advisors: lawyers, auditors, and consultants acting under professional confidentiality obligations, where disclosure is necessary for ezspin5 to obtain professional advice.

All third-party service providers engaged by ezspin5 are contractually required to handle personal data in a manner consistent with this Privacy Policy and applicable data protection standards. ezspin5 conducts due diligence on service providers before engagement and periodically reviews data processing arrangements.

7 Data Retention Periods

ezspin5 retains personal data only for as long as necessary to fulfil the purposes set out in this Policy, or as required by applicable legal and regulatory obligations. The following standard retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with ezspin5's data destruction procedures.

8 Data Security Measures

ezspin5 implements a multi-layered approach to personal data security, including the following technical and organisational measures:

• Encryption at rest: all personal data stored on ezspin5 servers is encrypted using AES-256 encryption.
• Encryption in transit: all data transmitted between Player devices and ezspin5 servers is protected by TLS 1.3.
• Access controls: access to personal data is restricted on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and undergo data protection training.
• KYC document isolation: identity documents are stored in isolated, separately access-controlled environments distinct from general account data systems.
• Intrusion detection: ezspin5's infrastructure is monitored 24/7 for anomalous access patterns, intrusion attempts, and data exfiltration indicators.
• Incident response: ezspin5 maintains a data breach response plan. In the event of a breach that poses risk to Players, affected individuals will be notified in accordance with applicable legal requirements.

9 Cookies and Tracking Technologies

ezspin5 uses cookies and similar tracking technologies on the Platform. Cookies are small data files stored on your device. The following categories of cookies are used by ezspin5:

• Strictly necessary cookies: required for the Platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cookies cannot be disabled.
• Analytics cookies: used to understand how Players interact with the Platform — including pages visited, session duration, and navigation paths. Analytics data is aggregated and does not identify individual players.
• Fraud prevention cookies: used to generate device fingerprints and detect suspicious behaviour patterns. These are necessary for the security of the Platform.
• Preference cookies: used to remember your Platform settings and preferences, such as language selection and game filter configurations.

You may manage non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the ezspin5 Platform. ezspin5 does not use third-party advertising cookies or behavioural retargeting cookies.

10 Your Rights as a Data Subject

As a Player whose personal data is processed by ezspin5, you have the following rights, subject to applicable legal limitations:

• Right of Access: you may request a copy of the personal data ezspin5 holds about you.
• Right of Rectification: you may request correction of inaccurate or incomplete personal data in your ezspin5 account.
• Right of Erasure: you may request deletion of your personal data where ezspin5 no longer has a legitimate legal basis to retain it. Note that regulatory retention obligations (AML, licensing) may limit ezspin5's ability to fully satisfy erasure requests.
• Right to Restrict Processing: you may request that ezspin5 pause certain processing activities while a data accuracy or lawfulness dispute is pending.
• Right to Data Portability: you may request a structured, machine-readable copy of personal data you provided to ezspin5 on the basis of consent or contract.
• Right to Withdraw Consent: where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time via account settings. Withdrawal does not affect the lawfulness of prior processing.
• Right to Object: you may object to processing based on legitimate interests, including profiling for marketing purposes.

To exercise any of the above rights, contact the ezspin5 data team at the address set out in Section 14. ezspin5 will respond to rights requests within 30 days. Where a request is complex or numerous, this period may be extended by a further 60 days with notification.

11 Minors and Age Restrictions

The ezspin5 Platform is strictly for use by individuals aged 21 and above. ezspin5 does not knowingly collect or process personal data from individuals under the age of 21.

Where ezspin5 discovers that personal data has been collected from a minor — whether through fraudulent account registration or any other means — the account will be immediately suspended, all associated funds will be handled in accordance with ezspin5's underage gaming policy, and all personal data collected from the minor will be deleted as soon as practicable.

If you believe a minor has registered on the ezspin5 Platform, please contact ezspin5 support immediately.

12 International Data Transfers

ezspin5's primary server infrastructure is located within the operator's licensing jurisdiction. Personal data of Malaysian Players may be transferred to and processed in countries outside Malaysia in connection with the use of third-party service providers described in Section 6, including KYC verification services, payment processors, and cloud infrastructure providers.

Where personal data is transferred internationally, ezspin5 ensures that appropriate safeguards are in place, including contractual data processing agreements with service providers that require adherence to data protection standards consistent with this Policy.

13 Changes to This Privacy Policy

ezspin5 may update this Privacy Policy from time to time to reflect changes in data processing practices, regulatory requirements, or Platform functionality. Updated versions will be published on the ezspin5 Platform with a revised effective date. Material changes will be communicated to registered Players via email or in-platform notification.

Continued use of the ezspin5 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. We recommend reviewing this Policy periodically. The version number and date of last update are displayed in the page header above.

14 How to Contact Us

For any queries, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ezspin5, please contact us through the following channels:

When submitting a data subject rights request, please include your registered email address and, where applicable, your ezspin5 account username to assist us in locating your records promptly.