Semutwin Privacy Policy – Malaysia Personal Data Protection

1. Introduction

Semutwin ("we", "Platform", or "company") values the privacy of every member who uses our services. This Privacy Policy document clearly and transparently explains how we collect, use, store, and protect your personal information when you access the semutwin website, use our mobile app, or interact with any of the services we offer.

This policy is prepared in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia, which governs how organisations handle individuals' personal data in this country. We are fully committed to complying with all provisions of the Act and ensuring your rights as a data subject are respected at all times.

By registering an account or continuing to use the semutwin platform after reading this policy, you hereby consent to the collection and use of your personal data as described in this document. If you do not agree with any provision, please contact our team or discontinue use of the platform.

2. Information We Collect

We collect various types of information depending on how you interact with the semutwin platform. Below is an overview of the data categories we may collect:

2.1 Data You Provide Voluntarily

Most of the data we collect is information you provide directly to us, such as when registering a new account, completing your user profile, contacting our support team, or participating in promotions and contests we run.

2.2 Automatically Collected Data

When you use the semutwin platform, our systems automatically record certain technical information including your IP address, browser type and version, pages visited, time and duration of each session, and the referral link that brought you to our platform. This information is used for analytics, platform improvement, and security detection purposes.

3. How We Use Your Data

Semutwin uses your personal data only for legitimate and necessary purposes. We do not use your data for purposes not stated in this policy without first obtaining your consent. The following are the primary purposes for which data is used:

• Account management: Create and maintain your account, process registrations, and verify identity through the KYC process.
• Transaction processing: Process deposits, withdrawals, and all financial transactions related to your account.
• Service delivery: Grants you access to all games, promotions, and platform features available.
• Platform security: Detect and prevent fraud, money laundering, unauthorized access, and any suspicious activity.
• Customer support: Address enquiries, resolve complaints, and provide the technical assistance you need.
• Communications: Send important account-related notifications, service updates, and, with your consent, information about the latest promotions.
• Legal compliance: Fulfil our obligations under applicable laws and regulations, including reporting requirements to the relevant authorities.
• Platform improvement: Analyse usage patterns to improve overall platform design, performance, and user experience.

4. Sharing Information with Third Parties

Semutwin does not share, sell, or disclose your personal information to outside parties except in the limited situations outlined below. Any data sharing is carried out with strict controls and only to the extent necessary for the stated purpose:

4.1 Trusted Service Providers

We share necessary data with third-party service providers who help us operate the platform — including payment processors, game providers, and technical infrastructure providers. All third parties are bound by strict confidentiality agreements and are not permitted to use your data for any purpose other than what has been agreed upon.

4.2 Legal Requirements

We may be required to disclose your personal information to government authorities, law enforcement bodies, or courts when obligated to do so by law, court order, or valid legal process. In such situations, we will disclose only the minimum information necessary.

4.3 Platform Integrity Protection

In cases where it is necessary to protect the rights, property, or safety of semutwin, its members, or the public, we reserve the right to share relevant information with the appropriate parties, including fraud investigators or cybersecurity firms.

5. Data Security

Protecting your personal data is a technical priority we take very seriously. semutwin implements multiple layers of security to ensure your information remains safe from unauthorized access, disclosure, alteration, or loss.

• SSL/TLS encryption: All data transmitted between your browser and our servers is protected with 256-bit SSL encryption, ensuring your information cannot be intercepted in transit.
• Encryption of data at rest: Sensitive data stored in our databases, including financial information and identity documents, is encrypted using industry-standard encryption protocols.
• Two-factor authentication: Our system supports two-factor authentication (2FA), which members can enable for an extra layer of security during login.
• Strict access control: Only authorised personnel with a legitimate operational need may access members' personal data, and all such access is logged and monitored.
• Regular security audits: Our platform undergoes independent security audits on a regular basis to identify and address any potential vulnerabilities.
• 24/7 Monitoring: Our automated monitoring system operates around the clock to detect any unusual or suspicious activity on member accounts.

While we take reasonable and comprehensive steps to protect your data, no system can be guaranteed 100% secure. In the event of any security breach affecting your data, we will notify you and the relevant authorities within the timeframe prescribed by law.

6. Cookies & Tracking Technologies

Semutwin uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website. The following are the types of cookies we use:

6.1 Necessary Cookies

These cookies are essential for the platform's core functions — including maintaining your login session, saving language preferences, and ensuring security features work properly. Without these cookies, the platform will not function correctly.

6.2 Analytics Cookies

We use analytics cookies to understand how members interact with our platform — which pages are visited most often, how long users spend in each section, and common navigation paths. This information helps us improve the platform's design and content.

6.3 Functional Cookies

Functional cookies allow the platform to remember your preferences such as display settings, preferred language, and saved login details for your convenience.

You may manage or disable cookies through your web browser settings. Please note that disabling certain cookies may affect some functionality of the semutwin platform.

7. Your Rights as a Data Subject

Under the Personal Data Protection Act 2010 of Malaysia, you have certain rights regarding the personal data we hold about you. semutwin is committed to respecting and facilitating the exercise of these rights:

To exercise any of the above rights, please contact our support team. We will process your request within 21 business days. In complex cases, this period may be extended with prior notification to you.

8. Data Retention & Deletion

Semutwin retains your personal data only for as long as necessary for the purposes stated in this policy or as required by applicable law. The following is a general guide to our data retention periods:

• Active account data: Retained for the duration your account remains active and for a reasonable period following account closure for record-keeping and compliance purposes.
• Financial transaction records: Retained for a minimum of seven (7) years in line with Malaysia's financial and accounting legal requirements.
• KYC records and identity documents: Retained for a minimum of five (5) years from the date of last verification, in accordance with anti-money laundering compliance requirements.
• Support communication logs: Retained for three (3) years for reference and service quality improvement.
• Technical data and system logs: Typically retained for 90 days and then automatically deleted or anonymised.

When data is no longer required, we will securely delete or anonymise it using appropriate procedures so that it can no longer be linked to any specific individual.

9. Changes to the Privacy Policy

Semutwin reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, technology used, legal requirements, or other operational reasons. When we make material changes, we will notify you through the following means:

• In-app or on-site notifications prominently displayed on semutwin
• Email notification to your registered address at least 7 days before the changes take effect
• Update the "Last Updated" date at the top of this document

Continued use of the semutwin platform after the effective date of any amendments constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your information.

10. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, we encourage you to reach out to us directly. Our data protection team is ready to help you obtain the information you need.

You may reach us via the Live Chat available on the platform, or through our official email. We are committed to responding to all privacy-related enquiries within 14 business days.

For more information on your rights and responsibilities as a member, please also refer to Terms and Conditions and the Responsible Gaming us.