Privacy Policy

1Introduction

Spribe ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all individuals who access or use the Spribe online gaming and sports betting platform at https://spribe.buzz ("the Platform"). This Privacy Policy ("Policy") sets out in formal terms how Spribe collects, processes, uses, stores, discloses, and protects personal data in connection with the operation of the Platform and the provision of gaming, sports betting, payment, and customer support services.

This Policy applies to all registered players and visitors to the Platform, including players based in Malaysia and any other jurisdiction from which the Platform may be accessed. By registering an Account on the Platform or by continuing to access the Platform after this Policy has been made available to you, you acknowledge that you have read, understood, and consent to the data processing practices described herein.

This Policy should be read alongside Spribe's Terms & Conditions, which together govern the overall relationship between Spribe and its players. In the event of a conflict between this Policy and the Terms & Conditions on a data protection matter, this Policy shall prevail.

2Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, telephone number, identification document details, IP address, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, organisation, structuring, retrieval, consultation, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" means Spribe, as the entity that determines the purposes and means of processing Personal Data in connection with the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of Spribe under a written data processing agreement.
• "Data Subject" means any living individual whose Personal Data is processed by Spribe — in practice, any registered player or Platform visitor.
• "Consent" means a freely given, specific, informed, and unambiguous indication of a Data Subject's agreement to the processing of their Personal Data for a stated purpose.
• "KYC Data" means identity verification documentation submitted by a player pursuant to Know Your Customer obligations, including government-issued identification, proof of address, and source-of-funds documentation.

3Data We Collect

Spribe collects Personal Data from players and Platform visitors through several channels, including direct registration, account usage activity, payment transactions, customer support interactions, and automated technical data collection. The categories of data we collect are detailed below.

3.1 Registration & Account Data

• Full legal name as it appears on your government-issued identification document.
• Date of birth (used to confirm compliance with the 21+ age requirement).
• Email address (primary communication channel).
• Mobile telephone number (used for two-factor authentication and account communications).
• Residential address, including postcode and city (e.g., Kuala Lumpur, Petaling Jaya, Shah Alam, Penang, Johor Bahru).
• Username and encrypted password.
• Currency preference (defaulted to Malaysian Ringgit — MYR — for Malaysian players).

3.2 KYC & Identity Verification Data

• Copy of government-issued photo ID (Malaysian MyKad, passport, or equivalent).
• Proof of residential address document (utility bill, bank statement, or official correspondence).
• Payment method ownership evidence (e.g., screenshot of Touch 'n Go eWallet account, bank statement reflecting account holder name).
• Source of funds documentation (where applicable, for accounts exceeding defined transaction thresholds).

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts, dates, and payment method references (Touch 'n Go eWallet, DuitNow, FPX, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank Online, cryptocurrency wallet addresses).
• Transaction history and account balance records.
• Bonus crediting and wagering activity records.

3.4 Gaming & Betting Activity Data

• Game session logs (game titles played, wager amounts, outcomes, session duration).
• Sports bets placed (sport, event, stake, odds, outcome).
• Live casino session records (table, dealer, stake, outcome).
• Responsible gambling tool settings (deposit limits, session timers, self-exclusion status).

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP.
• Device type, operating system, and browser type and version.
• Session timestamps and page interaction data.
• Cookie identifiers and analytics tracking tokens (see Section 10).

3.6 Communications Data

• Live chat transcripts and support ticket content.
• Email correspondence submitted to Spribe's support address.
• Feedback and survey responses submitted voluntarily by players.

4Data Processing

Spribe processes Personal Data for the following specific purposes:

5Legal Basis for Processing

Spribe relies on the following legal bases when processing your Personal Data. Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

• Contract Performance: Processing necessary for the conclusion or performance of the contract between you and Spribe — including operating your account, processing deposits and withdrawals, and delivering gaming services.
• Legal Obligation: Processing required to comply with our obligations under applicable law and our operating licence, including KYC verification, AML screening, and responsible gambling requirements.
• Legitimate Interest: Processing conducted for purposes that are necessary for Spribe's legitimate business interests, including fraud prevention, platform security, and analytics, provided those interests do not override your fundamental privacy rights.
• Consent: Processing based on your explicit, freely given consent — primarily in the context of optional marketing communications. Consent may be withdrawn at any time via your account settings or by contacting support.

6Data Sharing & Disclosure

Spribe does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data only in the circumstances described below, and only to the extent necessary for the stated purpose.

• Payment Service Providers: Spribe shares financial and identity data with payment processors, e-wallet operators (including Touch 'n Go eWallet, Boost, GrabPay), and banking institutions (including via DuitNow and FPX) to the extent required to process your deposits and withdrawals.
• Identity Verification Providers: KYC documentation may be processed by third-party identity verification platforms contracted by Spribe under binding data processing agreements.
• Gaming Software Providers: Game session data is shared with licensed third-party game content providers (slots, live casino software suppliers) to the extent necessary to operate those games. These providers operate under confidentiality and data security obligations.
• Regulatory and Law Enforcement Authorities: Spribe may disclose Personal Data to licensing authorities, financial intelligence units, law enforcement agencies, or courts where required to do so by applicable law, court order, or regulatory directive.
• Fraud Prevention Services: Transaction and account data may be shared with fraud detection and AML screening services that help identify suspicious activity patterns.
• Professional Advisers: Legal, accounting, or auditing firms may access Personal Data under professional confidentiality obligations where required in connection with a legal dispute, regulatory audit, or business review.
• Business Transfer: In the event of a merger, acquisition, restructure, or sale of all or part of Spribe's business, Personal Data held by Spribe may be transferred to the acquiring entity, subject to equivalent data protection obligations.

7International Data Transfers

The Spribe platform is operated internationally and certain service providers engaged by Spribe may process Personal Data in jurisdictions outside Malaysia. Where Personal Data is transferred to countries that do not provide the same level of data protection as the originating jurisdiction, Spribe will take appropriate safeguards to ensure that such transfers comply with applicable data protection requirements.

Safeguards for international data transfers may include: contractual clauses incorporating data protection obligations equivalent to those applicable in the originating jurisdiction; transfers only to countries or organisations that maintain recognised data protection standards; and the use of data processing agreements that restrict the recipient's use of data to the stated purpose.

8Data Retention

Spribe retains Personal Data for as long as is necessary to fulfil the purpose for which it was collected, to comply with legal and regulatory retention obligations, and to resolve any disputes or enforce agreements. The following general retention periods apply:

• Active Account Data: Retained for the full duration of the Account's active life, plus a minimum of 5 years following Account closure, in compliance with AML record-keeping requirements.
• KYC Documentation: Retained for a minimum of 5 years following the completion of the customer relationship, in accordance with financial crime prevention obligations.
• Transaction Records: Deposit, withdrawal, and betting history retained for a minimum of 5 years following the date of the transaction.
• Communications Data: Live chat transcripts and email correspondence retained for a minimum of 2 years for quality assurance and dispute resolution purposes.
• Technical & Log Data: Server and session logs retained for up to 12 months for security monitoring and platform integrity purposes.
• Marketing Preferences: Retained until you withdraw consent or opt out, plus an additional 3 months to ensure processing systems have been updated.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised so that it can no longer be associated with an identified individual.

9Security Measures

Spribe implements a range of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encrypted storage of passwords and sensitive account credentials using industry-standard hashing algorithms.
• Two-factor authentication (2FA) available to all registered players as an optional additional security layer.
• Role-based access controls limiting internal staff access to Personal Data on a strict need-to-know basis.
• Regular penetration testing and security audits of the Platform infrastructure.
• Anti-fraud monitoring systems operating 24/7 to detect and respond to suspicious transaction or account activity.
• Secure physical and cloud storage environments with access logging and audit trails.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. In the unlikely event of a data breach that poses a risk to your rights and freedoms, Spribe will notify affected individuals and relevant supervisory authorities in accordance with applicable legal requirements.

10Cookies & Tracking Technologies

Spribe uses cookies and similar tracking technologies (collectively, "Cookies") to operate the Platform, remember your preferences, maintain your login session, and collect anonymised usage analytics. Cookies are small text files stored on your device by your browser at the request of the Platform.

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled without impairing core Platform functionality.
• Functional Cookies: Remember your preferences (such as language settings, currency preference, and responsible gambling limits) to improve your experience.
• Analytics Cookies: Collect anonymised information about how visitors use the Platform — including pages visited, session duration, and device type — to help Spribe improve the Platform. No personally identifiable information is collected via analytics cookies.
• Marketing Cookies: Used only where you have given explicit consent to receive promotional communications. These track which promotions you have seen and help avoid repetitive messaging.

You may manage or disable non-essential Cookies through your browser settings. Please note that disabling certain Cookie categories may affect the functionality or performance of the Platform. For more detail on the specific cookies in use, please contact support.

11User Rights

Subject to applicable law and any overriding legal obligations (such as AML record-keeping requirements), you hold the following rights in respect of your Personal Data processed by Spribe. To exercise any of these rights, please contact us via the methods described in Section 15.

• Right of Access: You have the right to request confirmation of whether Spribe processes your Personal Data and, if so, to receive a copy of that data together with information about the purposes and categories of processing.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data held about you. Certain data corrections may require submission of supporting documentation.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing was unlawful. This right is subject to overriding legal retention obligations (e.g., AML requirements).
• Right to Restriction of Processing: You may request that Spribe restrict the processing of your Personal Data in certain circumstances, such as while the accuracy of data is being contested or while an objection is pending.
• Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, machine-readable format and to request its transmission to another controller, where technically feasible.
• Right to Object: You have the right to object to processing based on Spribe's legitimate interest or for direct marketing purposes. Where you object to direct marketing, Spribe will cease such processing immediately.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing.

12Minors

The Spribe platform is strictly intended for individuals aged 21 years and above. Spribe does not knowingly collect or process Personal Data from anyone under the age of 21. Age verification is a mandatory component of the KYC process, and accounts for which age verification cannot be completed will not be permitted to access deposit, withdrawal, or gaming services.

If Spribe becomes aware that it has collected Personal Data from a person under the age of 21 without appropriate verification, that data will be deleted promptly and the associated Account will be closed. If you believe that a minor has accessed the Platform and provided Personal Data, please notify us immediately at [email protected]. Parental control software (such as Net Nanny or similar tools) may be used by parents and guardians to restrict access to gambling websites.

13Third-Party Services

The Spribe platform may incorporate links or references to third-party services, including payment gateways, game software platforms, and identity verification providers. Spribe's Privacy Policy applies only to data processed directly by Spribe or by our contracted Data Processors acting on our instructions.

When you interact with third-party services — such as completing a payment via Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, or DuitNow — those services operate under their own privacy policies and data processing terms. Spribe has no control over, and accepts no responsibility for, the privacy practices of third-party services. We recommend that you review the privacy policies of any third-party service you interact with in connection with your use of the Platform.

14Changes to This Policy

Spribe reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. Where changes are material, we will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The "Last Reviewed" date at the top of this Policy reflects the date on which it was most recently amended. Your continued use of the Platform following publication of an updated Policy constitutes your acceptance of the updated terms. If you do not agree with any changes, you should cease using the Platform and may request Account closure in accordance with our Terms & Conditions.

15Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or Spribe's data processing practices, please contact our Data Protection team through the following channels:

• 24/7 Live Chat: Available directly on the Platform — average first-response time under 2 minutes for general enquiries.
• Email — Privacy Enquiries: [email protected] — please use the subject line "Privacy Enquiry" or "Data Rights Request" for routing to the appropriate team.
• Formal Data Rights Requests: Submit via email with the subject line "Data Rights Request — [Your Account Username]". Include your full name, registered email address, and a description of the specific right you wish to exercise. Spribe may request identity verification before processing the request.