Semutwinn Privacy Policy – Malaysian User Data Protection

1Introduction

Semutwinn (semutwinn.pro) takes user privacy very seriously. We understand that your personal information is a trust placed in us, and we are fully responsible for ensuring that data is handled with care, protected rigorously, and used only for purposes you have authorised.

This Privacy Policy is drafted in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and leading international standards for personal data management. It applies to all users who access the Semutwinn platform via the website, mobile app, or any other access method.

We encourage you to read this document thoroughly. If anything is unclear, the Semutwinn support team is ready to provide further clarification.

2Types of Data We Collect

Semutwinn collects personal data under two main categories — information you provide directly and information collected automatically as you use the platform.

Data You Provide Directly:

• Full name as shown on official identification documents
• Active email address and phone number
• Date of birth for age verification purposes
• Current residential address
• Identity documents (MyKad, passport) submitted during the KYC process
• Payment method details including bank account or e-wallet holder name
• Proof of address such as a utility bill or bank statement

Automatically Collected Data:

• IP address and geolocation data at country or city level
• Device type, operating system, and web browser version used
• Gaming session history including date, time, and session duration
• Financial transaction records including deposits, withdrawals, and wagering
• User interaction data with the platform interface
• Cookie information and session identifiers

3Data Collection Purpose

Every piece of data we collect has a clear and legitimate purpose. semutwinn does not collect data unnecessarily. The following are the primary purposes for collecting your personal data:

• Account registration and verification — To create and manage your user account, including verifying identity and confirming age eligibility through the KYC process.
• Financial transaction processing — To securely and accurately process deposits, withdrawals, and any other financial transactions related to your semutwinn account.
• Security & Fraud Prevention — To detect, investigate, and prevent any fraudulent activity, money laundering, or other security threats that may affect you or the platform.
• Regulatory compliance — To fulfill applicable legal and regulatory obligations, including anti-money laundering (AML) requirements and reporting required by law.
• Customer Support — To provide effective assistance when you contact the semutwinn support team.
• Platform improvements — To continuously analyze usage patterns and improve the quality, performance, and security of the platform.
• Marketing communications — To send you relevant promotional information, offers, and updates — only if you have given your consent to receive them.

4Cookie Usage

The semutwinn platform uses cookies and similar tracking technologies to enhance your experience. Cookies are small text files stored in your web browser that allow the platform to remember your preferences and settings.

Types of cookies used by Semutwinn:

• Essential cookies — Required for core platform operations such as login, game sessions, and transaction security. These cookies cannot be disabled without affecting platform functionality.
• Performance cookies — Collects information on how users interact with the platform to help us identify areas for improvement.
• Functional cookies — Remembers your preferences such as language settings, display themes, and game preferences to deliver a more personalized experience.
• Analytics cookies — Helps us understand aggregated and anonymized usage patterns for product improvement purposes.

5Data Storage & Security

Semutwinn implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, loss, alteration, or improper disclosure.

Key security measures we practise:

• 256-bit SSL Encryption for all data transmitted between your device and semutwinn servers
• Data encryption at rest for all personal and financial information stored in our databases
• Multi-layer access controls that ensures only authorized personnel can access sensitive data, and only to the extent required for their duties
• Regular security audits by independent third parties to identify and address any potential vulnerabilities
• 24/7 system monitoring to detect any unauthorized access attempts or suspicious activity
• Incident response plan that is comprehensive to ensure a swift and effective response in the event of any data breach

Your personal data is retained for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law — whichever is longer. Financial records are typically kept for a minimum of seven years in line with Malaysian legal requirements.

6Data Sharing with Third Parties

Semutwinn does not sell, rent, or trade your personal data to any third party for their own marketing purposes. This is non-negotiable. However, there are limited situations where we need to share certain information:

• Payment service providers — Information required to process your deposit and withdrawal transactions is shared with the relevant payment gateways and banks. These providers are bound by strict confidentiality agreements.
• Identity verification service providers — Data required to carry out KYC verification is shared with approved and trusted service providers.
• Regulatory bodies and law enforcement agencies — semutwinn will disclose data if ordered by a court, regulatory body, or competent law enforcement agency.
• Fraud investigators — Relevant data may be shared with third parties in the course of investigating suspected fraudulent activity to protect the interests of all users.

In all data sharing instances, Semutwinn ensures that data recipients are bound by confidentiality and security obligations equivalent to our own standards.

7Your Rights Over Personal Data

In accordance with Malaysia's Personal Data Protection Act 2010, you have the following rights regarding your personal data held by semutwinn:

8Children's Data

The semutwinn platform is intended for users aged 18 and above only. We do not knowingly collect any personal data from individuals under the age of 18.

If you believe your child under the age of 18 has registered an account at semutwinn, please contact us immediately through our customer support channels so we can take the appropriate action.

9Links to Third-Party Sites

The semutwinn platform may contain links or references to third-party websites such as game providers or payment partners. It is important that you understand the following:

• Semutwinn Privacy Policy not applicable to any third-party websites or services.
• Semutwinn is not responsible for the privacy practices or content of those third-party websites.
• We encourage you to read the privacy policy of any third-party website you visit.

The presence of third-party links on the semutwinn platform does not imply that we endorse or support the content, products, services, or privacy policies of those websites.

10Amendments to the Privacy Policy

Semutwinn reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, technological developments, legal requirements, or user feedback.

When material changes occur, we will:

• Updating the "Last Updated" date at the top of this document
• Displaying a clear notice on the platform at least 14 days before amendments take effect
• Sending email notifications to all registered users for amendments that materially affect their privacy rights

11Contact Us About Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by Semutwinn, we encourage you to contact us.

You can reach the Semutwinn data protection team via:

• In-platform live chat — Available 24 hours a day, 7 days a week for immediate response.
• Email: [email protected] — For written inquiries and official requests relating to personal data.

We are committed to responding to all privacy-related inquiries within 30 business days of receipt. For more complex requests such as data access or deletion requests, the response period may be longer — however, we will keep you informed of the progress.