Privacy Policy

1. Introduction

sm605 (referred to herein as "we", "us", "our", or "the Platform") operates the website located at https://sm605.click and all associated services. We take the privacy and security of your personal data seriously and are committed to handling it with transparency, care, and in full compliance with applicable data protection laws.

This Privacy Policy (the "Policy") describes the types of personal data we collect from players and visitors to the Platform, the purposes for which that data is processed, the legal bases upon which we rely, and the rights available to you as a data subject. This Policy applies to all individuals who access or use the sm605 Platform, whether as registered players, visitors, or prospective players.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference. By accessing the Platform or creating an account, you acknowledge that you have read, understood, and consent to the practices described in this Policy.

2. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, identification number, IP address, and financial information.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, alteration, restriction, or deletion.
• "Data Controller" means sm605, which determines the purposes and means of processing Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of sm605 under a contractual agreement, such as a payment service provider or identity verification provider.
• "Data Subject" means the natural person whose Personal Data is being processed — in this context, the Player or Platform visitor.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the processing of their Personal Data for one or more specified purposes.
• "Cookies" means small text files placed on a user's device by a website, used to remember user preferences, session state, and browsing behaviour.
• "KYC" (Know Your Customer) means the identity verification process required to comply with anti-money laundering and responsible gambling obligations.

3. Personal Data We Collect

3.1 Registration & Account Data

When you create an account on sm605, we collect the following information:

• Full legal name
• Date of birth (to verify you are aged 21 or above)
• Email address
• Mobile phone number
• Residential address (including city, state, and postcode)
• Preferred currency (Malaysian Ringgit / MYR by default)
• Username and hashed password

3.2 Identity Verification (KYC) Data

To comply with our legal obligations and responsible gambling commitments, we may request:

• Copy of government-issued identification (e.g., MyKad, passport)
• Proof of address (e.g., utility bill, bank statement issued within 3 months)
• Source of funds documentation
• Selfie or liveness check for identity verification purposes

3.3 Financial Transaction Data

When you make deposits or withdrawals on the Platform, we collect relevant transaction details including payment method type, transaction amount in MYR, transaction date and time, and reference identifiers from payment processors such as DuitNow, Touch 'n Go eWallet, Boost, Maybank, CIMB, Public Bank, GrabPay, FPX, Visa, Mastercard, and cryptocurrency wallet addresses where applicable.

3.4 Gameplay & Behavioural Data

We collect data about how you interact with the Platform, including:

• Games played, bet amounts, win/loss records
• Session duration and frequency of play
• Responsible gambling tool usage
• Bonus claims and wagering progress

3.5 Technical & Device Data

We automatically collect certain technical data when you access the Platform:

Data Type	Examples	Purpose
IP Address	Your network IP at login	Fraud prevention, geolocation, security logging
Device Information	Browser type, OS, screen resolution	Platform optimisation, fraud detection
Cookies & Session Tokens	Session ID, preference cookies	Authentication, user experience
Access Logs	Pages visited, timestamps	Security monitoring, platform improvement
Referral Source	Referring URL or affiliate code	Marketing attribution

3.6 Communications Data

If you contact our customer support team via live chat or email, we retain records of those communications to help resolve disputes, train our support staff, and improve service quality. Support interactions from players in Kuala Lumpur, Penang, Johor Bahru, and elsewhere are handled with the same standard of care.

4. Lawful Basis for Processing

sm605 processes your Personal Data on the following legal bases, depending on the specific processing activity:

1. Performance of a Contract: Processing necessary to provide you with the services described in our Terms & Conditions, including account management, transaction processing, and game access.
2. Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, responsible gambling rules, and KYC verification requirements.
3. Legitimate Interests: Processing carried out in pursuit of sm605's legitimate business interests, such as fraud prevention, platform security, service improvement, and internal analytics — provided those interests are not overridden by your fundamental rights.
4. Consent: Processing for which you have provided freely given, specific, and informed consent — such as receiving promotional emails or participating in opt-in data analytics programmes. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. How We Use Your Personal Data

sm605 uses the Personal Data we collect for the following purposes:

• To create, verify, and manage your player account
• To process deposits and withdrawals via Malaysian payment methods and international channels
• To verify your identity and age (21+) in accordance with KYC obligations
• To detect and prevent fraud, money laundering, collusion, and other prohibited activities
• To administer and settle bets, casino game rounds, and other Platform transactions
• To apply responsible gambling tools including deposit limits, session timers, and self-exclusion
• To provide customer support and respond to queries, complaints, and disputes
• To send transactional communications such as account confirmations, withdrawal notifications, and security alerts
• To send promotional communications where you have opted in to receive them
• To improve the Platform's user interface, game offering, and overall performance
• To comply with legal and regulatory obligations applicable to the Platform's operation
• To conduct internal risk analysis and anti-fraud modelling

6. Sharing Your Personal Data

6.1 Service Providers (Data Processors)

We share Personal Data with carefully vetted third-party service providers who process data on our behalf under binding data processing agreements. These include payment processors (including providers of Touch 'n Go eWallet, DuitNow, FPX, and banking integrations with Maybank, CIMB, and Public Bank), KYC and identity verification providers, fraud detection and anti-money laundering screening services, customer support software providers, cloud hosting and infrastructure providers, and email and communication platforms.

All Data Processors are contractually required to implement appropriate technical and organisational security measures and to process data only on documented instructions from sm605.

6.2 Legal and Regulatory Disclosure

sm605 may disclose Personal Data to competent authorities, regulators, law enforcement agencies, or courts where required to do so by applicable law, court order, or binding regulatory direction. Such disclosures will be limited to the minimum data necessary to comply with the relevant legal obligation.

6.3 Business Transactions

In the event of a merger, acquisition, corporate restructuring, or sale of all or part of the sm605 business, Personal Data held by the Platform may be transferred to the relevant successor entity, subject to that entity honouring the commitments in this Privacy Policy or providing equivalent protections.

6.4 No Sale of Data

sm605 does not sell, rent, lease, or otherwise transfer your Personal Data to any third party for that party's own independent marketing or commercial purposes. Any sharing described in this Section 6 is solely for the purpose of enabling the Platform to operate, comply with legal obligations, or protect the rights of sm605 and its players.

7. Data Retention

sm605 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law. The following general retention periods apply:

Data Category	Retention Period	Basis
Account registration data	Duration of account + 7 years post-closure	Legal / AML obligation
KYC verification documents	5 years from last transaction	Regulatory requirement
Financial transaction records	7 years from transaction date	Legal / AML obligation
Gameplay and betting history	Duration of account + 5 years	Dispute resolution / Legitimate interest
Customer support communications	3 years from last interaction	Legitimate interest
Marketing preference records	Until opt-out + 2 years	Consent / Legal compliance
Technical access logs	12 months	Security / Legitimate interest

Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised. Anonymised data may be retained indefinitely for statistical and analytical purposes.

8. Security Measures

sm605 implements a comprehensive set of technical and organisational security controls designed to protect your Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit TLS/SSL encryption for all data transmitted between your device and the Platform.
• AES-256 encryption for sensitive data stored at rest, including payment credentials and identification documents.
• Role-based access controls (RBAC) limiting internal access to Personal Data to personnel who require it to perform their specific job functions.
• Multi-factor authentication (MFA) for all internal administrative systems and player-facing account access.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Audit logging of all internal access to and modifications of Personal Data.
• Incident response procedures to detect, contain, and report data breaches within required notification timeframes.

While sm605 takes all reasonable precautions to protect your data, no online system can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account password and for notifying us immediately if you suspect any unauthorised access.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. sm605 uses cookies and similar tracking technologies (including local storage and session tokens) to operate essential platform functions, remember your preferences, and improve your overall experience.

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled without breaking core functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and recently visited game categories to provide a more personalised experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players interact with the Platform — such as which pages are visited most frequently and how long players spend on certain sections. This data helps us improve the Platform.
• Security Cookies: Help detect fraudulent activity, bot behaviour, and suspicious login patterns in real time.

9.3 Managing Cookies

You may manage or disable non-essential cookies through your browser's built-in settings. Please note that disabling certain categories of cookies may affect the functionality and user experience of the Platform. Strictly necessary cookies cannot be disabled via browser controls and are required for the Platform to function.

10. International Data Transfers

sm605 operates internationally and may transfer your Personal Data to servers or service providers located in countries outside of Malaysia. Where such transfers occur, we implement appropriate safeguards to ensure that your data receives a level of protection equivalent to that provided under applicable Malaysian data protection standards and international best practices.

Appropriate safeguards may include contractual clauses binding the recipient to process your data in accordance with applicable law, or transfer to jurisdictions that have been assessed as providing adequate data protection standards.

11. Your Privacy Rights

As a Data Subject, you hold the following rights in relation to your Personal Data processed by sm605. To exercise any of these rights, contact our Data Protection contact via the details in Section 15.

We will respond to all valid data subject requests within 30 calendar days. In complex cases, this period may be extended by a further 60 days with prior notification. We reserve the right to verify your identity before processing any rights request.

12. Minors and Age Restriction

The sm605 Platform is strictly for individuals aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. If we become aware that a player account has been created by a person under the minimum age, we will immediately suspend that account, delete associated Personal Data to the extent permitted by legal obligations, and report the matter to relevant regulatory authorities where required.

Parents and guardians who become aware that a minor may have accessed or registered on the Platform are encouraged to contact our support team immediately via live chat or the support email address listed in Section 15.

13. Third-Party Links and Services

The sm605 Platform may from time to time contain references or informational mentions of third-party services, payment providers, or regulatory bodies. This Privacy Policy applies solely to the sm605 Platform and does not govern the data practices of any third-party service, payment processor, or external website. sm605 is not responsible for the privacy practices or content of any third-party services accessed through or referenced on the Platform.

Players are encouraged to review the privacy policies of all third-party services they interact with — including payment providers such as Touch 'n Go eWallet, DuitNow, Maybank, and GrabPay — to understand how those parties process their data.

14. Changes to This Privacy Policy

sm605 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or Platform features. Material changes — those that significantly affect your rights or the way we use your data — will be communicated to registered players via email notification and/or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The effective date at the top of this Policy reflects when the current version was last updated. Continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of and agreement to the updated Policy. If you do not agree to material changes, you may request account closure in accordance with the Terms & Conditions.

We recommend reviewing this Policy periodically so that you remain informed about how sm605 protects your personal information.

15. Contact Us & Data Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by sm605, please contact our Customer Support and Data Protection team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week directly on the Platform. For data subject requests, please clearly state that your query is a privacy or data protection matter so it can be directed to the appropriate team.
• Support Email: [email protected] (plain text — not a clickable link). When submitting a privacy request by email, please include your full name, registered email address, and a clear description of your request or concern.

All privacy-related requests will be acknowledged within two (2) business days and resolved within the timeframes described in Section 11. We are committed to resolving data protection concerns promptly and professionally. If you are not satisfied with our response, you retain the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction.