Privacy Policy

This Privacy Policy (hereinafter "Policy") issued by Scrply (hereinafter "Scrply", "we", "us", "our") and applies to all personal data collected from individuals who access or use the website located at scrply.cam, create an account, make deposit, participate in games or promotional activities, or otherwise interact with the Scrply platform and its associated services.

Scrply operates an online casino and sports betting platform primarily serving players in Malaysia. We are committed to handling your personal data with transparency, integrity, and care. This Policy describes our data practices in plain, accessible language while maintaining the formal legal standard required for a comprehensive privacy disclosure.

By accessing the Platform, registering an account, or providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not consent to these practices, you must not use the Platform.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or in combination with other data, including but not limited to name, email address, date of birth, national identification number, IP address, and payment details.
• "Data Controller" means Scrply, as the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third-party service provider that processes personal data on behalf of Scrply pursuant to a written data processing agreement.
• "Processing" means any operation performed on personal data, including collection, storage, retrieval, use, disclosure, combination, restriction, erasure, or destruction.
• "User" / "Player" means any natural person who has registered an account or otherwise interacts with the Scrply platform.
• "KYC Data" means identity verification documents and information collected for Know Your Customer compliance purposes.
• "Sensitive Data" means personal data that by its nature requires heightened protection, including financial data, identity document numbers, and data relating to responsible gambling assessments.
• "Cookies" means small text files placed on a User's device by the Platform's web server to enable session management, preference storage, and analytics.

Scrply collects personal data across three principal categories: data you provide directly, data generated by your use of the Platform, and data received from third-party sources.

• Registration data: Full legal name, date of birth, email address, mobile phone number, and residential address.
• KYC verification data: Government-issued identity documents (Malaysian MyKad, passport, or driving licence), proof of address documents, and payment method verification materials.
• Financial data: Payment method identifiers (e-wallet account references, bank account numbers for FPX/DuitNow transactions), deposit and withdrawal transaction history.
• Communication data: Messages sent to our customer support team via live chat or email, including the content of complaints, queries, and dispute submissions.
• Responsible gambling data: Self-declared responsible gambling preferences, deposit and loss limit settings, self-exclusion requests, and any responsible gambling assessment responses.

• Technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Gameplay data: Game session records, wager amounts, game outcomes, bet history, bonus activity, and account balance history.
• Behavioural data: Pages visited, navigation patterns, session duration, click-stream data, and feature interaction logs.
• Location data: General geographic location inferred from IP address. We do not collect precise GPS coordinates.

• Identity verification providers: Results of automated identity and age verification checks conducted by accredited third-party KYC service providers.
• Payment processors: Transaction confirmation data and payment status updates from payment service providers including those handling DuitNow, FPX, Touch'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank, Hong Leong Connect, and cryptocurrency networks.
• Fraud prevention services: Risk scores, device fingerprints, and alerts generated by anti-fraud monitoring services.

Scrply collects personal data through the following mechanisms:

• Account registration forms: Information entered when you create a Scrply account.
• KYC document upload: Documents submitted through the secure document upload function within the account verification section.
• Deposit and withdrawal processes: Data exchanged with our payment processing infrastructure when you initiate financial transactions.
• Platform cookies and tracking technologies: Automated data collection tools that operate when you access the scrply.cam website (see Section 10 for full details).
• Live chat and email communications: Any information you voluntarily provide when contacting our support team.
• Third-party integrations: Data received from KYC verification providers, fraud screening tools, and payment processors as part of routine compliance and transaction processing operations.

Scrply processes your personal data for the following specific purposes:

Scrply does not use your personal data for automated decision-making processes that produce legally significant effects without human review, except where required for fraud detection and AML screening, in which case flaged cases are reviewed by our compliance team before any action is taken on your account.

Scrply relies on the following legal grounds for processing personal data:

• Contractual necessity: Processing required to perform the contract with you (i.e., providing access to the Platform, processing deposits and withdrawals, managing your account).
• Legal obligation: Processing required to comply with our licensing obligations, including KYC verification, AML monitoring, responsible gambling requirements, and record-keeping obligations.
• Legitimate interests: Processing carried out for fraud prevention, platform security, analytics, and service improvement, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing and promotional communications, which is carried out only where you have provided explicit opt-in consent at the time of registration or subsequently through your account settings. Consent may be withdrawn at any time.

Scrply does not sell, rent, or commercially distribute your personal data to any third party. We share your data only in the following limited and necessary circumstances:

• Payment service providers: Financial data is shared with the relevant payment processor (DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect, or cryptocurrency network nodes) solely to process your requested transaction. These providers operate under their own privacy policies and data security standards.
• KYC and identity verification providers: Identity document data and personal details are shared with accredited third-party verification services for the purpose of age and identity authentication as required by our licensing conditions.
• Fraud prevention and AML services: Technical and financial data may be shared with third-party fraud screening and anti-money laundering monitoring services. These processors are bound by contractual data processing agreements with Scrply.
• Game content providers: Aggregated or pseudonymised gameplay data may be shared with licensed game studios for the purpose of RNG certification, fault investigation, and game performance analysis. Individually identifiable player data is not shared for these purposes.
• Legal authorities: Personal data will be disclosed to law enforcement agencies, regulatory bodies, or courts where Scrply is compelled to do so by a valid legal order, court judgment, or applicable law. We will notify you of such disclosure where permitted to do so.
• Professional advisers: Legal, accounting, and auditing professionals acting on behalf of Scrply may access personal data where strictly necessary for the provision of their professional services, subject to appropriate confidentiality obligations.

Scrply retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law and our licensing obligations. The following general retention periods apply:

• Account and registration data: Retained for the duration of your active account plus minimum of 5 years following account closure, as required by AML and record-keeping obligations.
• KYC documentation: Retained for a minimum of 5 years from the date of collection or account closure, whichever is later, in accordance with standard AML compliance requirements.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction.
• Customer support communications: Retained for 3 years following the resolution of the relevant interaction, unless the matter relates to an ongoing dispute, in which case data is retained until the dispute is fully resolved.
• Gameplay records: Retained for a minimum of 3 years from the date of each session.
• Responsible gambling records: Retained for the duration required by our licensing conditions, including self-exclusion records which are retained permanently to prevent re-registration during an active exclusion period.
• Marketing consent records: Retained for the duration of your consent and for a period of 2 years following withdrawal of consent as evidence of the prior consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in manner that renders it incapable of re-identification.

Scrply implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Scrply platform.
• Encrypted data storage for sensitive personal data and financial records at rest.
• Role-based access controls ensuring that only authorised personnel with a legitimate business need can access personal data.
• Regular security assessments including penetration testing and vulnerability scanning of our platform infrastructure.
• Multi-factor authentication for internal systems access by Scrply personnel.
• Data breach response procedures ensuring prompt detection, containment, and notification of any security incident that affects personal data.

The Scrply platform uses cookies and similar tracking technologies to deliver core functionality, remember your preferences, and analyse platform usage. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management, login state, and security tokens. These cannot be disabled without impairing core platform functionality.
• Functional cookies: Used to remember your preferences, such as display language, responsible gambling limit settings, and game category preferences. These improve your experience but are not strictly required.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, including pages visited, session duration, and feature usage. This data helps us improve the Platform. These cookies are only placed with your consent.
• Security cookies: Used to detect fraudulent login attempts, bot activity, and unusual account behaviour. These operate silently and are essential to Platform security.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair your ability to use the Platform. Disabling analytics cookies will not affect your ability to access games or make transactions. Note that clearing cookies will log you out of your active session.

Subject to the applicable data protection framework governing our operations and certain limitations arising from our legal obligations (including AML and KYC record-keeping requirements), you have the following rights in relation to your personal data held by Scrply: