Privacy Policy scarplay — User Data Protection Commitment

01 Introduction

Scarplay ("we", "our platform") values the privacy of every user who uses our services. This Privacy Policy is crafted to ensure you fully understand how your personal data is handled by us from the moment you register through the duration of your membership.

As an online entertainment platform operating for Malaysian users, we understand that your trust is the most valuable asset we must safeguard. We therefore enforce strict data protection standards and continuously update our security practices in line with technological advancements and the evolving cyber threat landscape.

This policy applies to all information collected through the Scarplay website, our mobile app, and any interactions you have with our support team via live chat, email, or other communication channels we provide.

02 Personal Data We Collect

We collect various types of personal data to enable us to provide a complete, secure, and personalised experience to every user. The following are the categories of data collected:

We only collect data that is strictly necessary for the stated purposes. We do not collect sensitive information such as biometric data, political affiliations, or religious beliefs.

03 How We Use Your Data

The personal data you provide to us is used for the following purposes, all of which are directly related to the delivery of Scarplay services:

• Account Management — registering your account, verifying your identity, and ensuring secure login for every session.
• Transaction Processing — processing deposits, withdrawals, and all financial transactions accurately and securely.
• Legal Compliance — fulfilling KYC, AML (Anti-Money Laundering), and related regulatory reporting obligations.
• Platform Security — detecting and preventing fraud, unauthorized access, and account abuse.
• Service Improvement — analyzing usage patterns to improve the user experience and develop new features.
• Communication — sending important notifications related to your account, transactions, and service updates.
• Customer Support — resolving inquiries, complaints, and support requests more efficiently.

We do not use your data for any purpose beyond those stated above without first obtaining your additional consent.

04 Data Sharing & Disclosure

Scarplay does not sell or transfer your personal data to third parties for commercial purposes. However, there are limited situations where data sharing is necessary:

• Service Providers — technical partners such as payment gateway providers, game providers, and cloud computing services that help us operate the platform. All such parties are bound by strict confidentiality agreements.
• Legal Requirements — when required by court order, regulatory authority directive, or legitimate compliance obligation.
• Fraud Prevention — sharing information with relevant industry bodies or authorities to prevent financial crime and protect other users.
• Your Consent — in cases where you have given explicit consent for a specific purpose.

05 Data Security Measures

We implement multiple layers of technical and organisational security measures to protect your personal data from unauthorised access, loss, or accidental disclosure:

• Data encryption in transit using 256-bit TLS/SSL protocols for all communication between your device and our servers.
• Data encryption at rest — sensitive information such as passwords is stored in hashed form that cannot be decrypted.
• Two-factor authentication (2FA) is available for all accounts as an additional layer of protection during login.
• Regular independent security audits to identify and address any system vulnerabilities.
• A comprehensive incident response plan to ensure swift action in the event of any data breach.
• Ongoing security awareness training for all Scarplay staff who handle user data.

While we take all reasonable precautions, no security system can be guaranteed 100% safe. We encourage you to take your own protective measures, such as using a strong password and not sharing your login credentials.

06 Cookies & Tracking Technology

The scarplay platform uses cookies and similar tracking technologies to enhance the user experience and ensure essential functions operate correctly.

• Essential Cookies — required for core platform operations such as login session verification and security. These cookies cannot be disabled.
• Performance Cookies — collecting anonymized information about how users interact with the platform to help us improve the overall experience.
• Functional Cookies — storing your preferences such as language and location settings to enable a more personalized experience.
• Analytics Cookies — helps us understand which pages are most visited and where users encounter difficulties, for improvement purposes.

You can manage cookie settings through your web browser preferences. However, disabling certain cookies may affect the functionality of some parts of our platform.

07 Your Rights as a User

As a scarplay platform user, you have the following rights regarding the personal data we hold about you:

• Access Rights — you have the right to request a copy of the personal data we hold about you at any time.
• Right to Rectification — you have the right to request that we correct any data that is inaccurate or incomplete.
• Right to Erasure — in certain circumstances, you have the right to request the deletion of your personal data, subject to our legal retention obligations.
• Right to Restrict Processing — you may request that we restrict the processing of your data while a dispute is being resolved.
• Data Portability Rights — you have the right to receive your data in a machine-readable format for transfer to another service provider.
• Right to Object — you may object to the processing of your data for specific purposes such as direct marketing.

To exercise any of the rights above, please contact the scarplay support team via live chat or email. We will process your request within 30 business days from the date of receipt.

08 Data Retention Period

Scarplay retains your personal data for as long as your account is active or as long as necessary to provide services to you. The following are our data retention guidelines:

• Active account data is retained for the duration of your membership.
• After account closure, basic data is retained for a minimum of 5 years to meet AML-related legal and regulatory compliance requirements.
• Financial transaction records are retained in accordance with applicable Malaysian legal requirements.
• Technical log data such as access logs is retained for 12 months for security and investigation purposes.
• Data collected through anonymous analytics cookies is retained for a maximum of 24 months.

Once the required retention period has expired, your data will be securely deleted or anonymised in accordance with established data disposal procedures.

09 Children's Privacy

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

Should we find that personal data of a child has been inadvertently collected, we will take immediate action to delete that information and terminate the relevant account. If you believe a child has registered on our platform, please contact our support team immediately so appropriate action can be taken.

10 Amendments to the Privacy Policy

Scarplay reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. Whenever changes are made:

• The "Last Updated" date at the top of this document will be updated to reflect the date of the latest amendment.
• For significant changes that affect how we process your data, we will notify you via in-platform notification or email at least 14 days before the changes take effect.
• Continued use of the scarplay platform after a change notice is considered acceptance of the updated policy.
• Previous versions of this Privacy Policy are available upon request from our support team for reference.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

11 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, do not hesitate to contact us:

• Live Chat: Available 24/7 via the chat icon at the bottom-right corner of the scarplay platform — the fastest way to get an immediate response.
• Privacy Email: [email protected] — for formal complaints or requests relating to personal data.
• FAQ: Reference FAQ page for answers to common questions about privacy and account security.

We are committed to responding to all privacy-related enquiries within 5 business days. For formal data rights requests, please clearly state the type of request and include the required identity verification information so we can process your request accurately and securely.