Semutwin Privacy Policy – Malaysian Member Personal Data Protection

Semutwin ("we", "Platform") is committed to protecting the privacy of all users of our online entertainment platform. This Privacy Policy is drawn up in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA) and applicable international data protection standards.

This document clearly outlines the types of personal data we collect, the purposes for collection, how we protect your data, and the rights you hold as a data subject. We believe that transparency in data handling is the foundation of trust between a platform and its users.

If you have any questions or concerns about how we handle your personal data, our data protection team is ready to assist. Contact details are available at the end of this document.

Semutwin collects personal data from various sources during your use of our platform. The following are the main categories of data we collect:

We do not collect sensitive data categories such as medical information, religious beliefs, or political views unless specifically required by law.

The personal data we collect is used solely for the following purposes:

• Account management: Creating, verifying, and maintaining your account on the Semutwin platform.
• Identity verification (KYC): Ensuring you meet the minimum age requirement and verifying your identity for security and compliance purposes.
• Payment processing: Processing deposits, withdrawals, and other financial transactions you conduct on the platform.
• Service provision: Enabling you to access all games, promotions, VIP programmes, and other platform features.
• Service communications: Sending important notifications related to your account, transactions, policy changes, and security information.
• Fraud prevention: Detecting and preventing fraudulent activity, money laundering, and platform abuse.
• Platform improvement: Analysing usage patterns to improve the overall user experience.
• Legal compliance: Fulfilling legal and regulatory obligations applicable to platform operations.

Semutwin only processes your personal data on a lawful basis in accordance with applicable data protection laws:

• Contract performance: Processing necessary to fulfil the service agreement between you and Semutwin.
• Legal obligation: Processing required by law, including anti-money laundering (AML) and KYC requirements.
• Legitimate interest: Processing for the purposes of fraud prevention, platform security, and service improvement.
• Consent: For marketing communications, we request your explicit consent and you may withdraw that consent at any time.

Semutwin does not sell your personal data to any party. However, we may share your data with the following parties in limited circumstances:

• Payment service providers: To process your deposits and withdrawals – such as FPX processors, digital wallet gateways, and partner banks.
• Game software providers: Minimum data required to operate your gaming session with our partner providers.
• Identity verification services: To carry out KYC checks as required by law.
• Competent authorities: When required by a court order, applicable law, or a legitimate law enforcement agency.
• Technical infrastructure providers: Such as cloud computing and security services used to operate the platform.

All third parties that receive your data are required to comply with strict data protection standards and may only use that data for the purposes specified.

Semutwin continually invests in security infrastructure to ensure your personal data is protected against unauthorised access, disclosure, alteration, or destruction.

Security measures we implement include:

• 256-bit SSL/TLS encryption for all data transmissions between client and server.
• Passwords are stored using secure hashing algorithms — we never store passwords in plain text.
• 24/7 security monitoring systems that detect suspicious access attempts.
• Two-factor authentication (2FA) is available for all accounts as an additional layer of security.
• Regular security audits conducted by qualified third parties.
• Strict internal access controls – only staff who require access to specific data are permitted to do so.

Semutwin only retains your personal data for as long as necessary for the purposes stated in this policy or as required by law:

• Active account data: Retained for the duration your account is active and for the required period following account closure.
• Financial & transaction records: Retained for a minimum of 7 years in accordance with applicable financial and tax regulations.
• KYC records: Retained in accordance with applicable anti-money laundering regulations, typically for a minimum of 5 years.
• Security logs: Retained for 12 months for fraud detection and security investigation purposes.
• Customer support communication: Retained for 3 years for reference and service improvement purposes.

Once the retention period expires, data will be securely deleted or anonymised in accordance with our data deletion procedures.

The Semutwin platform uses cookies and similar tracking technologies to enhance your experience and ensure the platform functions smoothly. Types of cookies we use:

• Essential cookies: Required for core platform functions such as login authentication and session security. These cookies cannot be disabled.
• Performance cookies: Collecting information on how you use the platform to help us improve our services.
• Functional cookies: Remembering your preferences and settings such as language and display mode.
• Analytics cookies: Helping us understand platform traffic and usage patterns in an aggregated and anonymous manner.

You can manage cookie settings through your web browser. However, disabling certain cookies may affect platform functionality. The Semutwin mobile app uses equivalent device identifiers for the same purposes.

As a data subject, you have the following rights, which you may exercise at any time:

To exercise any of the above rights, please contact our data protection team via email or live chat. We will process your request within 30 business days.

The Semutwin platform is intended exclusively for adult users aged 18 and above. We do not knowingly collect or process personal data of individuals under the age of 18.

If we find that we have collected data from a minor without proper verification, we will take immediate steps to delete that data and close the relevant account.

If you become aware that a minor has registered or is using the Semutwin platform, please contact us immediately so we can take appropriate action.

Semutwin reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or new technologies we adopt.

When we make significant changes, we will notify you via:

• In-app or on-site notification upon login.
• Email sent to the address registered to your account.
• Update the "Updated" date at the top of this document.

Your continued use of the Semutwin platform after changes are published constitutes your acceptance of the amended Privacy Policy. We encourage you to review this page from time to time.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact our data protection team:

• Privacy Email: [email protected]
• Support Email: [email protected]
• Live Chat: Available 24/7 on the Semutwin app and website
• Targeted Response Time: 2 to 4 hours for general inquiries, 30 working days for data subject access requests

For general information about the platform, you may refer to the FAQ us. For matters relating to terms of use, please read Terms and Conditions us.