Privacy Policy Club 77

1Introduction & Scope of Privacy Policy

Welcome to the Privacy Policy page Club 77. We, Club 77, operate an online gaming platform based in Malaysia and are fully committed to protecting the privacy and personal data of every member. This Privacy Policy document sets out clearly and transparently how Club 77 collects, processes, stores, shares and protects your personal information when you use our platform.

This Privacy Policy applies to all users who access the Club 77 website, register as members, use our mobile app, or interact with any Club 77 service. By continuing to use our platform, you agree to the terms set out in this Privacy Policy.

We encourage you to read this Privacy Policy carefully before registering an account or using Club 77's services. If you do not agree with any part of this policy, please discontinue use of our platform and contact our support team to close your account.

2Personal Data We Collect

Club 77 collects various categories of personal data from members for legitimate platform operations, legal compliance, and user experience improvement. Below is a full list of the data types we collect:

Data You Provide Directly

• Identity Information: Full name, identity card number (MyKad), date of birth, and gender.
• Contact Information: Email address, mobile number, and residential address.
• Financial Information: Bank account number, bank name, and e-wallet number (Touch 'n Go, GrabPay, Boost, ShopeePay) for deposit and withdrawal purposes.
• Account Information: Username, password (stored in encrypted format), and security questions.
• Verification Documents: MyKad copy, bank statements, or other documents required for the KYC (Know Your Customer) process.

Automatically Collected Data

• Technical Data: IP address, device type, operating system, browser type and version.
• Usage Data: Pages visited, session duration, buttons clicked, games played, and bets placed.
• Location Data: Country- and state-level geographic location based on your IP address for legal compliance purposes.
• Cookie Data: Preference data, login sessions and analytics data collected via cookies and similar technologies.

3How Club 77 Uses Your Data

Club 77 uses your personal data only for legitimate purposes directly related to the operation of the platform. The following are the primary purposes for which Club 77 uses your personal data:

Platform Operations & Services

• Processing new account registrations and verifying member identities through the KYC process.
• Processing deposits and fund withdrawals via local Malaysian payment methods including DuitNow, FPX, Touch 'n Go eWallet and GrabPay.
• Providing access to games and betting on the Club 77 platform, including slots, baccarat, football betting, and sports.
• Managing the programme VIP Rewards and calculating member reward points.
• Providing customer support and resolving complaints or disputes.

Security & Compliance

• Detecting and preventing fraud, money laundering, and other illegal activities.
• Fulfilling legal compliance obligations, including Malaysia's PDPA requirements and AML regulations.
• Verifying users' ages to ensure no individual under 18 years old accesses the platform.
• Maintaining audit records for regulatory purposes and investigations where required.

Communication & Marketing

• Sending important notifications related to your account, transactions, and policy changes.
• Keeping you informed about Club 77's latest promotions, bonuses, and offers (subject to your communication preferences).
• Conducting customer satisfaction surveys to improve service quality.

4Data Sharing with Third Parties

Club 77 does not sell, rent or trade your personal data to third parties for their marketing purposes. There are, however, certain circumstances where Club 77 needs to share your data with trusted third parties. Such sharing is done strictly on a need-to-know basis and with appropriate safeguards in place:

Trusted Service Providers

• Payment Processors: Payment service providers such as DuitNow, FPX, and e-wallet operators receive the information necessary to process your financial transactions.
• Game Providers: Gaming software providers that supply game content to the Club 77 platform may receive the necessary gaming data.
• Cloud Services: Cloud server infrastructure and data storage provider used by Club 77.
• Analytics Services: Analytics tools used to understand usage patterns and improve the platform.

Authorities & Regulatory Bodies

• Club 77 may disclose personal data to Malaysian authorities when required by law, court order, or regulatory directive.
• In cases involving fraud or money laundering investigations, Club 77 will cooperate fully with the Royal Malaysia Police (PDRM) and relevant agencies.

5Personal Data Security

Club 77 invests heavily in cybersecurity infrastructure to ensure your personal data is always protected. Our security measures span multiple technical layers and strict operational procedures:

Technical Security Measures

• 256-bit SSL/TLS Encryption: All data transmitted between your device and Club 77's servers is fully encrypted.
• Data-at-Rest Encryption: Sensitive data stored in Club 77's database is encrypted using the AES-256 algorithm.
• Two-Factor Authentication (2FA): An additional security option for logging into your Club 77 account.
• 24/7 Monitoring: A threat detection and suspicious activity monitoring system that operates around the clock.
• Multi-Layered Firewall: Network- and application-level protection to prevent unauthorised access.

Internal Security Procedures

• Access to members' personal data is restricted solely to Club 77 staff with a legitimate operational need.
• All Club 77 staff undergo regular data security training.
• Regular internal and external security audits are conducted to identify and address vulnerabilities.
• A defined incident response procedure to address any data breach promptly.

6Cookies & Tracking Technologies

Club 77 uses cookies and similar tracking technologies to enhance the user experience, analyse platform performance, and deliver relevant content. Below is a detailed breakdown of the types of cookies we use:

Types of Cookies Used

You can manage your cookie settings through your web browser at any time. Please note that deleting or blocking essential cookies may affect the functionality of the Club 77 platform. For more information on managing cookies, refer to your web browser's help section.

7Your Personal Data Rights

As a data subject under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data held by Club 77:

To exercise any of the rights above, please contact the Club 77 privacy team at support@club77.my with the email subject line "Privacy Rights Request". We will process your request within 30 days of receipt. In complex cases, this period may be extended to up to 60 days, with notification provided to you.

8Data Retention Period

Club 77 retains your personal data only for as long as necessary to fulfil the purpose for which it was collected or to comply with applicable legal requirements. Below is a guide to our retention periods:

• Active Account Data: Retained for the duration your account is active and up to 7 years after account closure for legal compliance purposes.
• Financial Transaction Records: Retained for 7 years in accordance with Malaysian financial and tax legal requirements.
• KYC Documents: Retained for 5 years from the date of the last verification or account closure, whichever is later.
• Communication & Support Logs: Retained for 3 years from the date of last interaction.
• Analytics Data & Cookies: Retained for between 30 days and 2 years depending on the data type.

When your personal data is no longer needed, Club 77 will securely delete it using methods that ensure the data cannot be recovered.

9International Data Transfers

In the course of global operations, some of your personal data may be transferred to and processed outside Malaysia by our third-party service providers. Club 77 ensures that any such data transfers are carried out with adequate safeguards:

• Data transfers are only carried out to countries or entities that maintain data protection standards equivalent to or higher than Malaysia's.
• All overseas data recipients are bound by data processing agreements that comply with international standards.
• Club 77 conducts a Data Protection Impact Assessment (DPIA) before initiating any new data transfer outside Malaysia.

10Children's Privacy

The Club 77 platform is strictly for adults aged 18 and above. We do not knowingly collect personal data from individuals under 18. Should we discover that data from an underage individual has been collected, we will take immediate steps to delete that data and close the account in question.

Parents or guardians who have reason to believe their child has registered a Club 77 account are urged to contact us immediately at support@club77.my so that action can be taken.

11Privacy Policy Amendments

Club 77 reserves the right to amend this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements or service improvements. Where material amendments are made, we will:

• Updating the "Last Updated" date at the top of this document.
• Sending a notification to your registered email address at least 14 days before the amendments take effect.
• Displaying a clear notice on the Club 77 platform's homepage.

Your continued use of the Club 77 platform after any amendments take effect will be considered your acceptance of the revised Privacy Policy. If you do not agree with the changes made, you have the right to close your account and stop using our platform.

12Contact Us – Privacy Enquiries

If you have any questions, concerns, or complaints regarding Club 77's Privacy Policy or how we handle your personal data, please contact our Data Protection Officer at:

• Email: support@club77.my (subject: "Privacy Enquiry")
• Live Chat: Available directly on the Club 77 platform (24 hours, 7 days a week)
• Frequently Asked Questions: Visit the page FAQ us

We are committed to responding to all privacy enquiries within 14 business days of receipt.