Privacy Policy vip123 —
Data Security for Malaysia Members

Vip123 collects your personal information through several means depending on the type of interaction you have with our platform. The following are the categories of information we collect:

Information You Provide Directly:

• Full name as shown on official identification documents.
• Date of birth for age verification purposes (members must be 18 years of age or older).
• An active mobile phone number and a valid email address.
• Bank account or digital wallet details for processing deposits and withdrawals.
• Copies of identification documents (identity card, passport) collected during the KYC process.
• Additional information you provide when contacting our customer support.

Automatically Collected Information:

• IP address, device type, operating system, and web browser used.
• In-platform activity data including wagering history, login records, and transactions.
• General location information based on IP address (not precise GPS location).
• Session data and interaction logs for security and fraud prevention purposes.

The information we collect is used solely for the operation and improvement of the vip123 platform. Below is a detailed breakdown of data usage by category:

Vip123 does not use your personal data for third-party advertising or commercial profiling without your consent. Every use of data is directly related to platform operations and member security.

Vip123 processes members' personal data on valid legal bases under Malaysia's Personal Data Protection Act 2010 (PDPA). The processing bases we apply are as follows:

• Contract Performance: Data processing required to provide vip123 services to you once you have registered and agreed to our Terms and Conditions.
• Legitimate Interest: Processing for platform security, fraud prevention, and user experience improvement that does not affect your fundamental privacy rights.
• Legal Obligation: Processing required to meet regulatory requirements, anti-money laundering (AML) compliance, and authority directives.
• Consent: For optional activities such as sending marketing materials and the use of non-essential cookies, we obtain your explicit consent and you may withdraw that consent at any time.

Vip123 does not sell, transfer or disclose members' personal information to third parties except in the following limited and controlled circumstances:

• Payment Service Providers: Only the minimum necessary transaction details are shared with trusted payment processors such as banks and digital wallet providers to facilitate secure deposits and withdrawals. All such providers are bound by strict confidentiality agreements.
• Third-Party Game Providers: Member identifiers (not full identification details) are shared with game providers integrated with the vip123 platform solely for session management purposes.
• Legal Authority: vip123 will disclose members' personal information to law enforcement agencies or regulatory bodies when required by law or a valid court order.
• Fraud Investigation: In cases of suspected fraud or illegal activity, relevant information may be shared with the appropriate authorities for investigation purposes.

In all of the data sharing cases above, vip123 ensures that receiving parties are bound by confidentiality and data protection obligations equivalent to our own standards.

Vip123 implements a comprehensive range of technical and organisational security measures to protect members' personal data from unauthorised access, disclosure, alteration or destruction:

• Data Encryption: All sensitive data is encrypted using AES-256 standards at rest and SSL/TLS 1.3 in transit. Passwords are stored in hashed format using the bcrypt algorithm and cannot be read even by vip123 staff.
• Secure Infrastructure: vip123 servers are hosted in ISO 27001-certified data centres with multi-layered physical security, cooling systems, and redundant power supplies to ensure service continuity.
• Two-Factor Authentication (2FA): All internal access to systems containing member data requires two-factor authentication. Members are also encouraged to enable 2FA on their accounts.
• Continuous Monitoring: Threat detection and anomaly monitoring systems operate 24 hours a day to identify and respond to any suspicious activity promptly.
• Regular Security Audits: vip123 undergoes periodic independent penetration testing and security audits to identify and remediate any potential vulnerabilities.

Vip123 retains members' personal data for as long as it is needed for the purposes stated in this Privacy Policy. Specific retention periods by data category are as follows:

• Active Account Data: Retained for as long as your account remains active on the vip123 platform. This is necessary to provide you with uninterrupted service.
• Financial Transaction Data: Retained for seven (7) years after a transaction occurs, in line with applicable Malaysian financial and tax legislation.
• KYC Documents: Retained for five (5) years after account closure, in accordance with anti-money laundering (AML) compliance requirements.
• Communication Logs: Communication records with customer support are retained for two (2) years for quality control and dispute resolution purposes.
• Marketing Data: Retained until you withdraw consent or request deletion. Once consent is withdrawn, this data will be deleted within 30 days.

Once the retention period expires, your personal data will be securely deleted or anonymised so that it can no longer be linked to your identity.

The vip123 platform uses cookies and similar tracking technologies to enhance user experience and ensure the platform functions smoothly. The following are the types of cookies we use:

• Essential Cookies: Required for core platform operations such as login authentication, session management, and account security. These cookies cannot be disabled as they are essential for the platform to function.
• Functional Cookies: Saving your preferences such as language, display settings, and saved login details for a more convenient experience on future visits.
• Analytics Cookies: Helping us understand how members use the vip123 platform so we can make continuous improvements. This data is collected in aggregate and anonymised form.
• Marketing Cookies: Used to display more relevant vip123 promotions and offers to you. These cookies are only activated with your consent.

You can manage cookie usage through your web browser settings. However, disabling essential cookies may affect the functionality of the vip123 platform. More information on managing cookies is available in your account settings.

As a vip123 member, you have the following rights regarding your personal data under Malaysia's PDPA:

Vip123 takes child protection very seriously. The vip123 platform is exclusively for individuals aged 18 and above and we do not intentionally collect or process personal data from minors.

All new registrants are required to confirm that they are at least 18 years of age during the registration process. Our KYC (Know Your Customer) process further verifies each member's actual age through official identification document checks.

Vip123 reserves the right to amend or update this Privacy Policy at any time to reflect changes in our practices, legal requirements or platform improvements. When significant changes are made, we will:

• Displaying a clear notice on the vip123 platform home page for at least 14 days before any changes take effect.
• Sending notifications to members via their registered email or in-app notifications for amendments that materially affect member privacy rights.
• Updating the "Last Updated" date at the top of this document.

Your continued use of the vip123 platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed.

If you have any questions, concerns or wish to exercise your privacy rights, please contact the vip123 privacy team through the following channels:

• Privacy Email: [email protected] (with the subject line "Data Privacy Request")
• Live Chat: Available 24 hours a day, 7 days a week via the chat icon on the vip123 platform.
• Response Time: We are committed to responding to all privacy-related enquiries within 3 business days and resolving requests within 14 business days.

Vip123 values your trust and is always committed to ensuring your privacy and data security are maintained at all times. Thank you for choosing vip123 as your online entertainment platform.