Privacy Policy — ptn77

1 Introduction

ptn77 is committed to protecting the privacy and personal data of every individual who interacts with our platform — whether as a registered Account holder, a visitor browsing the website, or a contact engaging with our support team. This Privacy Policy explains what personal data we collect, the purposes for which it is collected, the legal basis upon which we process it, and the rights available to you in relation to your data.

By registering an Account on ptn77 or using any of our services, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection, use, and processing of your personal data in the manner described herein. If you do not agree with any part of this policy, you must cease use of the platform.

This Policy should be read alongside ptn77's Terms & Conditions and our Responsible Gambling Policy. Together, these three documents form the complete framework governing your relationship with ptn77.

2 Definitions

The following terms, when used in this Privacy Policy, shall 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, financial details, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, retrieval, alteration, and deletion.
• "Data Controller" means ptn77, the entity that determines the purposes and means by which Personal Data is processed.
• "Data Subject" means you — the individual whose Personal Data is being processed under this Policy.
• "Third Party" means any individual, organisation, or entity other than ptn77 and the Data Subject who is involved in data processing activities, such as payment processors, identity verification providers, and technical service providers.
• "Cookie" means a small text file placed on your device by our website to store session information, preferences, and analytics data.
• "KYC" means Know Your Customer — the identity and document verification process mandated under our licensing obligations.

3 Data We Collect

ptn77 collects the following categories of Personal Data, limited strictly to what is necessary for the purposes described in Section 5:

1. Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (Malaysian MyKad number or passport number) collected during registration and KYC verification.
2. Contact Data: Email address, Malaysian mobile phone number, and residential address in Malaysia (including city references such as Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, or Shah Alam).
3. Financial Data: Bank account numbers, registered bank names (Maybank, CIMB, Public Bank, Hong Leong, and others), e-wallet identifiers (Touch 'n Go eWallet, Boost, GrabPay), DuitNow proxies, transaction amounts, and transaction timestamps.
4. Account Data: Username, encrypted password, account status, deposit history, withdrawal history, bonus usage records, and responsible gambling tool settings.
5. Usage and Behavioural Data: Pages visited, games accessed, bets placed (including sports markets such as Liga Super Malaysia and EPL), session duration, and in-platform navigation patterns.
6. Technical and Device Data: IP address, device type, browser type and version, operating system, screen resolution, access timestamps, and geolocation data (country level only, where relevant to platform access).
7. Communications Data: Transcripts and records of live chat conversations, email correspondence, and support ticket content between you and the ptn77 support team.

We do not collect sensitive personal data categories — such as racial or ethnic origin, religious beliefs, health records, or biometric data — unless required by law or expressly consented to by you for specific purposes.

4 How We Collect Your Data

ptn77 collects Personal Data through the following channels:

• Direct collection: Information you provide during account registration, KYC document submission, deposit or withdrawal requests, and support interactions.
• Automated technical collection: Data gathered automatically when you access the ptn77 platform, including device data, IP address, and usage behaviour captured through cookies and server logs.
• Third-party sources: Identity and age verification data obtained from accredited KYC service providers during the account verification process. Financial transaction data passed to us from payment processors (FPX, DuitNow, e-wallet providers) to confirm deposit and withdrawal status.
• Fraud prevention tools: Risk signals and flags generated by third-party fraud detection systems that process transactional and behavioural data to identify suspicious activity.

5 Data Processing & Use

ptn77 processes your Personal Data for the following specific purposes:

• Account management: Creating, maintaining, and managing your Account on the ptn77 platform, including authentication, password management, and account security.
• Identity and age verification: Verifying that you are who you claim to be and that you meet the minimum age requirement of 21 years to use ptn77's services.
• Payment processing: Executing deposit and withdrawal transactions through approved Malaysian payment methods, including Maybank2u, CIMB Clicks, DuitNow, FPX, and e-wallets.
• Regulatory and legal compliance: Fulfilling obligations under our international gaming licence, including anti-money laundering (AML) screening, sanctions screening, and fraud monitoring.
• Responsible gambling: Monitoring for indicators of problem gambling behaviour, applying self-imposed limits, and enabling self-exclusion as requested by players.
• Customer support: Responding to queries, investigating complaints, and resolving disputes submitted via live chat or email.
• Platform improvement: Analysing aggregated, anonymised usage data to improve game selection, interface design, and platform performance.
• Marketing communications: Sending promotional offers, bonus notifications, and newsletters to Account holders who have opted in to receive such communications. You may opt out at any time.

6 Legal Basis for Processing

ptn77 processes your Personal Data on one or more of the following legal grounds:

• Contractual necessity: Processing required to fulfil the contract between you and ptn77 as set out in the Terms & Conditions — including account creation, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws, regulations, and our international gaming licensing requirements — including KYC, AML, and sanctions compliance.
• Legitimate interests: Processing carried out in the legitimate interests of ptn77 or third parties — such as fraud prevention, platform security monitoring, and aggregated analytics — provided such interests are not overridden by your rights.
• Consent: Processing carried out based on your freely given, specific, informed consent — including marketing communications and certain cookie categories. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Third-Party Sharing

ptn77 may share your Personal Data with carefully selected third-party service providers who operate strictly as data processors on our behalf — subject to contractual obligations ensuring they process your data only as instructed and in accordance with applicable data protection standards. Categories of such third parties include:

• Identity verification providers: Third-party KYC service providers engaged to verify identity documents and age, operating under strict data processing agreements with ptn77.
• Payment processors: Financial service providers facilitating MYR transactions through FPX, DuitNow, and e-wallet platforms. These providers receive only the transaction data required to process your specific request.
• Fraud detection and AML services: Risk intelligence platforms that screen transactions and account activity against sanctions lists and known fraud patterns.
• Technical infrastructure providers: Cloud hosting, server management, and cybersecurity service providers who maintain the technical environment in which ptn77 operates.
• Regulatory and law enforcement authorities: Where ptn77 is legally required to disclose Personal Data in response to a lawful order, court direction, or regulatory request.

8 International Data Transfers

As an internationally operated platform, ptn77 may transfer Personal Data to servers and third-party service providers located outside of Malaysia. Where such transfers occur, ptn77 ensures that appropriate safeguards are in place to protect your Personal Data to a standard no less rigorous than that described in this Policy.

Safeguards for international data transfers may include standard contractual clauses, binding corporate rules, or transfers to jurisdictions recognised as providing adequate levels of data protection. If you require further information about the specific mechanisms used for any international transfer, you may contact our data team using the details in Section 15.

9 Data Retention

ptn77 retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected or as required by our licensing obligations and applicable legal requirements. Specific retention guidelines include:

• Active Account holders: Personal Data is retained for the duration of the Account relationship plus a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping obligations.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Support communications: Live chat transcripts and email correspondence are retained for a period of three (3) years from the date of the interaction.
• Marketing data: Data collected on the basis of consent for marketing purposes is retained until you withdraw consent or request deletion — whichever is earlier.
• Technical and log data: Server logs and IP address records are retained for a rolling period of ninety (90) days unless a security incident requires extended retention for investigation purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that renders it impossible to associate with any individual.

10 Cookies & Tracking Technologies

ptn77 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small files stored on your browser or device that enable us to recognise you across sessions and provide a more personalised experience.

We use the following categories of cookies:

• Strictly necessary cookies: Required for core platform functionality — including session authentication, security tokens, and load balancing. These cannot be disabled without impairing platform operation.
• Functional cookies: Store your preferences such as language settings, preferred payment method, and display settings to improve your experience on return visits.
• Analytics cookies: Collect anonymised, aggregated data on how players navigate and use the ptn77 platform — used to improve usability and performance. These are subject to your consent.
• Security cookies: Used to detect and prevent fraudulent activity, bot interactions, and account takeover attempts by monitoring unusual access patterns.

You may manage your cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from using core ptn77 functionality, though some personalisation features may be unavailable.

11 Your Rights as a Data Subject

As an individual whose Personal Data is processed by ptn77, you hold the following rights, which you may exercise at any time by contacting us using the details in Section 15:

To exercise any of the above rights, please contact ptn77 using the contact details in Section 15. We may require identity verification before processing a data rights request. All requests will be acknowledged within five (5) business days and actioned within thirty (30) calendar days.

12 Data Security

ptn77 takes the security of your Personal Data seriously and has implemented a range of technical and organisational measures to protect it against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your browser or device and the ptn77 platform.
• Encryption of sensitive data fields — including passwords and financial identifiers — at rest using industry-standard cryptographic algorithms.
• Role-based access controls ensuring that ptn77 staff can only access Personal Data necessary for their specific job function.
• Regular internal and third-party security assessments, penetration testing, and vulnerability scanning.
• Two-factor authentication (2FA) options available for Account holders to further secure access to their Accounts.
• Incident response procedures governing how ptn77 detects, contains, and notifies affected parties in the event of a data security breach.

While ptn77 takes all reasonable precautions to safeguard your data, no platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials and for notifying us immediately if you suspect unauthorised access.

13 Children and Minors

If we become aware that Personal Data has been collected from an individual under the minimum age of 21, we will take immediate steps to delete that data and close the associated Account. All collected data will be purged without delay.

If you believe that ptn77 may have inadvertently collected data from a minor, please contact us immediately using the contact details in Section 15 so that we may investigate and take the necessary corrective action.

14 Changes to This Privacy Policy

ptn77 reserves the right to amend this Privacy Policy at any time. Where changes are material — for example, changes to how we use your Personal Data, new data sharing arrangements, or significant changes to your rights — we will notify registered Account holders by email and via a prominent in-platform notice at least seven (7) days before the changes take effect.

The "Last Updated" date displayed at the top of this Policy will be revised upon each amendment. Minor or clarificatory changes (such as corrections to grammar or formatting that do not alter the substance of the Policy) may be implemented without notice.

Your continued use of the ptn77 platform after any amendments to this Policy have come into effect constitutes your acceptance of the revised terms. If you do not agree with any updated provision, you must cease using the platform and may request account closure and data deletion as described in Section 11.

15 Contact Us

For all privacy-related enquiries, data rights requests, or concerns regarding the handling of your Personal Data, please contact ptn77 through the following channels:

• Email: [email protected] — please include "Privacy Request" in your subject line. Monitored daily from 9:00 AM to 11:00 PM (MYT). All formal data requests are acknowledged within five (5) business days.
• Live Chat: Available 24 hours a day, 7 days a week via the ptn77 platform. For general privacy queries, our support agents can assist directly or escalate to our data team as appropriate.

When submitting a data rights request, please provide your full registered name, Account email address, and a clear description of the request you are making. ptn77 may require identity verification before processing any request that involves access to, modification of, or deletion of Personal Data.

ptn77 is committed to resolving all privacy-related concerns promptly and fairly. If you believe your concern has not been addressed to your satisfaction, you retain the right to escalate the matter to the relevant data protection authority or regulatory body in the jurisdiction applicable to your situation.