77win Privacy Policy – Personal Data Protection in Malaysia

1. Introduction & Scope of This Privacy Policy

This Privacy Policy is issued by 77win ("we", "Platform") and applies to all individuals who access or use the 77win platform, including the website, mobile services, games, Sports Betting, lottery, slots, live blackjack, and all other products made available through 77win-app.com ("Services").

We understand that your trust in us depends greatly on how we handle your personal information. That is why we have written this policy in clear, plain language — not in convoluted legal jargon that leaves most users confused. Our goal is for you to genuinely understand what happens to your data when you use 77win.

By registering an account or using any 77win service, you acknowledge that you have read and understood this Privacy Policy. If you disagree with any part of this policy, please discontinue use of the platform and contact us to close your account.

2. Personal Data We Collect

77win collects several categories of personal data from you when you register and use our platform. Below are the categories of data we collect, along with how each is obtained:

Data You Provide Directly:

• Registration Information: Your full name, active Malaysian phone number, email address, date of birth, and the username you chose when registering your 77win account.
• Identity Verification (KYC) Information: Copies of your MyKad or passport, verification selfie, and proof of address (such as a Tenaga Nasional or Indah Water utility bill) submitted during the KYC process.
• Communication Information: The content of your correspondence with the 77win support team via live chat, email at support@77win-app.com, or any other channel.
• Feedback & Surveys: Your responses to customer satisfaction surveys or any feedback you submit to us.

Automatically Collected Data:

• Platform Usage Data: Login records, game history, betting history, deposit and withdrawal history, account settings preferences, and other in-platform activity.
• Technical Data: Your device's IP address, browser type, operating system, screen resolution, device language, and other technical information automatically transmitted by your device to our servers.
• Location Data: Approximate location information based on your IP address, used for security and access verification purposes. We do not track your device's GPS location.
• Cookie Data: Information stored via cookies and similar tracking technologies to enhance your experience on the 77win platform. See Section 6 for full details.

3. Purpose of Data Collection & Processing

77win collects and processes your personal data solely for legitimate purposes that are directly related to delivering our platform services to you. The key purposes are outlined below:

• Account Management: To create, verify, manage and secure your 77win account. This covers the login process, identity verification, security settings and VIP membership management.
• Service Provision: To give you access to all games, place sports bets on Malaysia Super League and EPL matches, play slots, live blackjack, lottery, and all other services we offer.
• Financial Transaction Processing: To process deposits via Touch 'n Go eWallet, GrabPay, DuitNow, Boost, ShopeePay and FPX, and to facilitate winnings withdrawals to your chosen payment method in Malaysian Ringgit (RM).
• Security & Fraud Prevention: To identify, prevent, and investigate any suspicious activity, fraud, money laundering, or breaches of the terms of service that could compromise the security of the platform and its members.
• Customer Support: To enable the 77win support team to understand your issue, locate relevant transaction records, and resolve any problems you encounter quickly and accurately.
• Service Communications: To send you important notifications about your account, changes to our terms, bonus promotions you are eligible for, and information related to responsible gambling.
• Platform Improvements: To analyse usage patterns on an aggregate (not individual) basis, with the aim of improving platform performance, introducing new features and delivering a better user experience.
• Regulatory Compliance: To comply with applicable legal requirements, including Malaysia's Personal Data Protection Act 2010 (PDPA) and reporting obligations mandated by the relevant authorities.

4. Sharing Data with Third Parties

77win does not sell, rent, or trade your personal data to any third party for marketing purposes or commercial gain. However, in the course of operating the platform, there are limited situations where we may need to share your data with certain parties:

Contracted Service Providers:

• Payment Processors: Required transaction information is shared with PCI DSS-certified payment processors to enable your deposits and withdrawals to be handled securely via Touch 'n Go, GrabPay, DuitNow, Boost, ShopeePay and FPX.
• KYC Service Provider: Your identity verification documents may be processed by a third-party identity verification service provider that holds the relevant certifications and is bound by strict confidentiality agreements.
• Game Providers: Third-party game software providers may receive the minimum technical data required to ensure games function properly. They do not receive any personal information that could directly identify you.
• Analytics Services: Anonymised and aggregated usage data (not individual-level data) may be shared with analytics platforms for the purpose of understanding general usage patterns.

Legally Mandated Disclosure:

77win may be required to disclose your personal data to the relevant authorities if compelled by a court order, direction from a law enforcement body, or a valid legal reporting obligation. In such situations, we will endeavour to notify you in advance where permitted by law.

All third parties we engage are bound by data processing agreements that require them to handle your data in accordance with appropriate protection standards and solely for the purposes specified by 77win. They are not permitted to use your data for any other purpose.

5. Data Retention & Security Measures

77win invests seriously in security infrastructure to ensure your data is protected at all times. The following are the key security measures we have in place:

• Data Encryption in Transit: All communication between your device and 77win's servers is encrypted using TLS 1.3 with a 256-bit SSL certificate. This ensures that any data transmitted cannot be read by anyone attempting to intercept the communication.
• Data Encryption at Rest: Sensitive data stored in our database is encrypted using strong encryption standards. Your account password is stored in a hashed format that cannot be decrypted — not even by 77win staff.
• Internal Access Controls: Access to members' personal data within 77win's systems is granted only to staff who genuinely require it to carry out their duties. All access is recorded in an audit log that is reviewed on a regular basis.
• 24/7 Security Monitoring: Our security systems are continuously monitored to detect any suspicious activity, intrusion attempts, or anomalies that may indicate a security threat.
• Regular Penetration Testing: 77win conducts regular independent penetration testing to identify and address any vulnerabilities in our systems before they can be exploited.

Data Retention Period:

77win retains your personal data for as long as necessary to fulfil the purposes outlined in this policy and to meet our legal obligations. As a general guide:

• Active account data is retained for the duration of your membership.
• Financial transaction records are retained for a minimum of 7 years in accordance with legal requirements.
• Technical log data is retained for a maximum of 12 months.
• Following account closure, your personal data will be anonymised or deleted within 90 days, unless a longer retention period is required by law.

6. Cookies & Tracking Technologies

77win uses cookies and similar technologies to enhance your experience on our platform. Cookies are small data files stored in your browser or device when you visit the 77win platform.

We use several types of cookies for different purposes:

• Essential Cookies: Required for core platform functions such as maintaining your login session, remembering your language preference, and keeping your account secure. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collects information about how you use the 77win platform — which pages you visit, how long you spend in each section, and where you encounter issues. This data helps us improve platform performance.
• Functional Cookies: Allows the platform to remember your preferences — such as your preferred odds format (Decimal, Malay, or HK), display settings, and other choices — so you do not need to reconfigure them each time you log in.
• Analytics Cookies: Collects anonymised and aggregated usage data to help us understand general usage patterns and make better-informed improvement decisions. This data cannot be used to identify you as an individual.

You can manage your cookie settings through your browser settings at any time. However, disabling essential cookies may affect the functionality and security of the 77win platform. For more information on managing cookies in your browser, please refer to your browser's help documentation.

7. Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and the data protection principles we adhere to, you have the following rights regarding your personal data held by 77win:

• Right of Access: You have the right to request and receive a copy of the personal data we hold about you. We will provide this information within 30 days of receiving your request.
• Right to Rectification: If the personal data we hold about you is inaccurate or outdated, you have the right to request a correction. You can update basic information such as your phone number and email address directly through your account panel.
• Right to Erasure: Under certain circumstances, you have the right to request the deletion of your personal data from our systems. Such requests are subject to data retention obligations under applicable law, which may require us to retain certain data for a specified period.
• Right to Restrict Processing: You have the right to object to or request that we restrict the processing of your data in certain situations — for example, if you believe the processing lacks a valid legal basis.
• Right to Data Portability: You have the right to request a copy of your personal data in a machine-readable format (such as CSV or JSON) so that you can transfer it to another service if needed.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the validity of any processing that took place prior to the withdrawal.

To exercise any of the above rights, please contact the 77win support team via live chat or submit a written request to support@77win-app.com with the subject line "Personal Data Rights Request". Include your account number and a clear description of your request. We will process and respond within the timeframe required by applicable law.

8. Protection of Children's Data

The 77win platform is a service intended exclusively for individuals aged 18 and above. We strictly do not knowingly collect, process, or store personal data from individuals under the age of 18.

During the registration process, all applicants are required to confirm that they are 18 years of age or older. We employ verification measures including a KYC (Know Your Customer) process to verify members' ages and prevent access by underage individuals.

If we discover or are made aware that we have collected data from an individual under the age of 18, we will take immediate action to:

• Closing the account in question immediately.
• Delete all personal data belonging to that individual from our systems.
• Any remaining balance will be returned to the original deposit method in accordance with the applicable procedures.

9. Changes to This Privacy Policy

77win reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data handling practices, technological developments, legal requirements, or member feedback. Any changes we make are intended to strengthen your privacy protection or to ensure compliance with the latest legal obligations.

When we make material changes to this policy, we will notify you through the following means:

• An email notification will be sent to the address registered to your account at least 14 days before any significant amendment takes effect.
• A clear notice on the 77win platform's main page on the date the changes are announced.
• Updating the "Last Updated" date at the top of this Privacy Policy page.

We encourage you to review this Privacy Policy page periodically to stay informed about how we protect your information. Your continued use of the 77win platform after any amendments take effect constitutes your acceptance of the updated policy.

10. Contact Us About Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, we encourage you to get in touch. Our team is ready to assist you with full confidentiality and in Bahasa Melayu.

You can reach us through the following channels:

• Email: support@77win-app.com – include "Privacy Enquiry" in the subject line to help us respond faster.
• Live Chat: Available 24 hours a day, 7 days a week via the chat icon in the bottom-right corner of the 77win platform.
• Response Time: We aim to respond to all privacy-related enquiries within 3 business days. For more complex cases, we will keep you informed of the estimated timeframe required.

We value every piece of feedback from our members on how we handle their privacy. Your input helps us continually improve data protection practices at 77win for the benefit of all platform members.