Privacy Policy

Semutwin ("Company", "Platformwe", "us", "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the Semutwin website located at semutwin.cam and all associated products and services (collectively, the "Services"). This Privacy Policy ("Policy") explains in plain and clear language how Semutwin collects, uses, stores, shares, and protects personal data relating to registered players and website visitors ("you", "your", "User").

This Policy applies to all personal data processed by Semutwin in connection with the delivery of the Services, regardless means of access — desktop browser, mobile browser, or any other device. By creating an Account on the Semutwin platform or by continuing to use the Services, you acknowledge that you have read and understood this Privacy Policy and consent to the data processing activities described herein.

The following key terms are used throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, location data, online identifier, or factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, combination, restriction, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, Semutwin.
• "Data Processor" means any third party that processes Personal Data on behalf of Semutwin, pursuant to a contractual arrangement.
• "Consent" means any freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• "KYC" means Know Your Customer — the identity and age verification procedures applied by Semutwin in accordance with applicable regulations.
• "Cookies" means small text files placed on your device by the Semutwin website to facilitate platform functionality, session management, and analytics.

The Data Controller responsible for the personal data collected and processed through the Semutwin platform is Semutwin, operating the website at semutwin.cam. All data protection enquiries and requests to exercise data subject rights should be directed to our support team using the contact details provided in Section 16 of this Policy.

Semutwin is committed to ensuring that all Personal Data is processed in accordance with applicable data protection legislation, including principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

Semutwin collects the following categories of Personal Data in connection with the provision of the Services:

We do not collect special categories of Personal Data (such as health data, racial or ethnic origin data, or biometric data) except where strictly required by law or where you have provided such data expressly in connection with a responsible gambling support request.

Semutwin collects Personal Data through the following means:

• Direct Collection: Information you provide voluntarily when registering an Account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or updating your account settings.
• Automated Collection: Technical and Usage Data collected automatically when you interact with the Semutwin website, via server logs, cookies, and similar tracking technologies. See Section 11 for details on our cookie practices.
• Third-Party Sources: Identity verification data received from KYC service providers during the verification process; fraud risk signals from payment processors; and, where applicable, data from publicly accessible sources to verify identity or investigate suspected fraudulent activity.

Semutwin processes Personal Data for the following purposes:

1. Account Management: To create, maintain, and administer your Account, verify your identity and age, and communicate with you about your Account.
2. Service Delivery: To provide, operate, and improve the Semutwin Services, including processing deposits, withdrawals, and bets.
3. KYC & Regulatory Compliance: To verify your identity in accordance with applicable Know Your Customer and anti-money-laundering requirements, and to report to regulatory or law enforcement authorities where legally required.
4. Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions money laundering, collusion, and other prohibited activities. This includes automated fraud screening of transactions.
5. Responsible Gambling: To monitor gaming behaviour for indicators of problem gambling, to implement and enforce deposit limits, cooling-off periods, and self-exclusion requests, and to provide responsible gambling support where appropriate.
6. Customer Support: To respond to your enquiries, resolve disputes, and provide technical support via live chat and email.
7. Marketing Communications: Where you have provided explicit consent, to send you promotional communications including bonus offers, platform news, and personalised recommendations. You may withdraw this consent at any time.
8. Platform Improvement: To analyse usage patterns, conduct A/B testing, and make data-informed decisions about platform features and user experience improvements.
9. Legal Obligations: To fulfil any legal or regulatory obligations to which Semutwin is subject.

Semutwin relies on the following legal bases to process Personal Data, depending on the processing activity in question:

• Contractual Necessity: Processing required to perform our contract with you, including account management, deposit and withdrawal processing, and bet settlement.
• Legal Obligation: Processing required to comply with KYC, anti-money-laundering, and other applicable legal or regulatory obligations.
• Legitimate Interests: Processing carried out in pursuit of Semutwin's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given consent, including the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Semutwin does not sell your Personal Data to third parties. We may share Personal Data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate contractual data protection obligations:

• KYC & Identity Verification Providers: Third-party services used to verify your identity and age during account registration and as required on an ongoing basis.
• Payment Service Providers: Including operators of Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank, RHB, DuitNow, FPX, and cryptocurrency payment gateways — strictly for the purpose of processing deposits and withdrawals.
• Fraud Prevention & Risk Management Services: Third-party platforms that assist Semutwin in detecting and preventing fraudulent or suspicious activity.
• Cloud Infrastructure & Hosting Providers: Service providers that host the Semutwin platform and associated data infrastructure under strict data processing agreements.
• Regulatory & Law Enforcement Authorities: Where Semutwin is required by law, court order, or regulatory directive to disclose Personal Data.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

Semutwin retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, and in any event for no longer than is required by applicable law or regulation. The following general retention periods apply:

• Account and Identity Data: Retained for a minimum of five (5) years following permanent account closure, in line with anti-money-laundering record-keeping obligations.
• Financial and Transaction Data: Retained for a minimum of seven (7) years from the date of the relevant transaction, as required by applicable financial regulations.
• KYC Documentation: Retained for a minimum of five (5) years post-accountclosure or longer if required by a regulatory authority.
• Customer Support Records: Retained for a period of three (3) years from the date of the last support interaction, unless a longer period is required in connection with an ongoing dispute or investigation.
• Marketing Consent Records: Retained for the duration of your Account relationship and for three (3) years post-closure as evidence of consent or withdrawal of consent.

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

Semutwin implements a comprehensive suite of technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers;
• Encryption of sensitive data fields (including payment details and identity documents) at rest;
• Role-based access controls, ensuring that only authorised personnel with a legitimate business need can access Personal Data;
• Regular security audits and penetration testing of platform infrastructure;
• Multi-factor authentication for all internal system access;
• Comprehensive intrusion detection and monitoring systems; and
• Staff training on data protection and information security best practices.

Semutwin uses cookies and similar tracking technologies on its website. Cookies are small text files stored on your device that help us deliver a functional and personalised experience. We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the website to function properly. These include session authentication cookies, load-balancing cookies, and security tokens. These cookies cannot be disabled without rendering the platform non-functional.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised data about how visitors interact with the Semutwin website — for example, which pages are visited most frequently and how long sessions last. This data is used solely to improve platform performance.
• Functional Cookies: Allow the platform to remember your preferences, such as language settings, currency display, and interface customisations, to enhance your experience across sessions.

Semutwin does not use third-party advertising cookies or tracking pixels that share your browsing activity with external advertising networks. You may manage cookie preferences via your browser settings; however, disabling strictly necessary cookies will impair your ability to use the platform.

Subject to applicable data protection law and certain legal limitations, you have the following rights in respect of your Personal Data held by Semutwin:

1. Right of Access: You may request a copy of the Personal Data Semutwin holds about you, together with information about how it is being processed.
2. Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. Account details can be updated directly through your account settings for most fields.
3. Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where processing is unlawful. Note that Semutwin may be required to retain certain data to comply with legal obligations, even following an erasure request.
4. Right to Restriction: You may request that Semutwin restrict the processing of your Personal Data in certain circumstances, for example while the accuracy of the data is being verified.
5. Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request that your Personal Data be provided to you in a structured, commonly used, machine-readable format.
6. Right to Object: You may object to processing based on legitimate interests at any time. You have an absolute right to object to processing for direct marketing purposes.
7. Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact our support team using the details in Section 16. We will respond to all valid requests within 30 days. Where a request is complex or numerous, we may extend this period by a further two months, in which case we will notify you of the extension and the reasons for it.

If you are the parent or guardian of a minor and believe that your child has provided Personal Data to Semutwin, please contact us immediately at [email protected] and we will act promptly to investigate and remove the data. Semutwin employs age-verification controls during the account registration and KYC processes to prevent underage access to the platform.

In the course of providing the Services and operating its infrastructure, Semutwin may transfer Personal Data to countries outside of Malaysia. Where such transfers occur, Semutwin ensures that appropriate safeguards are in place to protect the Personal Data, including:

• Transfering only to countries that provide an adequate level of data protection as determined by applicable law;
• Implementing standard contractual clauses or equivalent contractual mechanisms with data recipients in third countries; and
• Conducting transfer impact assessments where required to identify and mitigate risks to the rights and freedoms of data subjects.

Semutwin may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or platform features. The most current version of this Policy will always be accessible on this page, with the "Last Updated" date revised accordingly.

Where changes are material, Semutwin will use reasonable efforts to notify registered players by email or via an on-site notification prior to the changes taking effect. Your continued use of the Services following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not accept the updated Policy, you should cease using the Services and close your Account.

If you have any questions, concerns, or requests relating to this Privacy Policy or the manner in which Semutwin processes your Personal Data, please contact us through the following channels:

• 24/7 Live Chat: Available directly on the Semutwin website — the fastest channel for most enquiries.
• Email: [email protected] — for data subject rights requests, privacy concerns, and data breach notifications. We aim to respond within 1 business hour for general enquiries, and within 30 days for formal data subject rights requests.

For formal data subject rights requests (access, erasure, portability, rectification, etc.), please include your full name, registered email address, and a clear description of your request. We may ask for additional information to verify your identity before processing the request, in order to protect the security of your Personal Data.