Privacy Policy r77 — Personal Data Protection for Malaysia Members

This Privacy Policy is published by r77 ("we", "Company", "Platform") and applies to all users and members who access or use the r77 platform via the website r77.cx and any related mobile applications or services.

R77 operates as an online entertainment platform providing gaming services including slots, Live Casino, bingo, sports betting, and table games. In delivering these services, r77 needs to collect and process certain personal information from our members.

We are committed to processing all personal data transparently, responsibly and securely. This policy explains exactly what information we collect, why we need it, how we use it, and the rights you hold over your personal data. If you are under 18 years of age, please do not use the r77 platform and do not provide us with any personal information.

R77 collects various categories of personal information to provide safe and quality services. Below is a summary of the data categories we collect:

R77 only collects information that is genuinely necessary for the stated purposes. We do not collect sensitive data such as medical information, religious beliefs, or political views unless required by specific legal obligations.

The data we collect is used solely for legitimate purposes directly related to delivering r77's services. The primary uses of your data are as follows:

• Account Management: Creating, verifying and maintaining your member account, including secure login processing.
• Transaction Processing: Processing all deposits and withdrawals accurately and securely through your chosen payment method.
• Legal Compliance: Meeting KYC and AML obligations as required by applicable laws and regulatory bodies.
• Platform Security: Identifying and preventing fraudulent activity, account abuse and cybersecurity threats.
• Customer Support: Providing support and resolving queries or complaints submitted by members.
• Service Communications: Sending important notices related to your account, promotions you have joined and service updates.
• Platform Improvement: Analyzing usage patterns to enhance the user experience and improve platform features.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and provide appropriate support.

R77 will not use your data for purposes beyond those stated above without first obtaining your explicit consent.

R77 only processes your personal data where there is a valid legal basis to do so. The primary bases we rely on are:

• Contract Performance: Processing of data required to provide r77 services to you as requested at the time of registration.
• Legal Obligation: Processing required to comply with applicable laws including KYC, AML and financial reporting requirements.
• Legitimate Interest: Processing for platform security, fraud prevention and service improvement purposes that does not affect your fundamental rights.
• Consent: For certain types of processing such as direct marketing and preference-based communications, we will obtain your explicit consent beforehand, and you may withdraw that consent at any time.

R77 does not sell, rent, or trade members' personal data to any third party for commercial purposes. However, within the context of platform operations, there are limited situations where your data may be shared:

• Trusted Service Providers: Companies that assist r77 in delivering services — such as payment processors, cloud service providers, and game providers — are all bound by strict confidentiality agreements.
• Legal Requirement: When r77 is required by a court, regulatory body, or legitimate law enforcement agency to disclose specific information.
• Fraud Prevention: Sharing information with trusted partners for the purpose of identifying and preventing fraudulent activity that may compromise member security.
• Business Transfers: In the event of a merger, acquisition, or sale of r77 assets, personal data may be transferred to the new entity subject to prior notice to members.

In all data sharing instances, r77 ensures that receiving parties comply with data protection standards equivalent to or stricter than those we apply ourselves.

The security of member personal data is among r77's highest priorities. We use multiple layers of technical security and procedures to protect your data from unauthorized access, loss or misuse:

• Data in Transit Encryption: All communication between your browser and r77 servers is protected with 256-bit SSL/TLS encryption — the same standard used by major banking institutions.
• Stored Data Encryption: Sensitive data such as financial information and identity documents is stored in encrypted form within r77's database.
• Internal Access Controls: Access to members' personal data within r77 is restricted to authorised staff who require it solely for their designated responsibilities.
• Two-Factor Authentication: r77 provides and encourages the use of two-factor authentication to protect member accounts from unauthorised access.
• Continuous Monitoring: The r77 security team monitors the platform 24/7 to detect any suspicious activity or attempted security breaches.
• Periodic Audits: r77 conducts regular security audits by independent experts to identify and address any vulnerabilities.

R77 does not retain your personal data longer than is necessary for the stated purposes or as required by law. Our general data retention guidelines are as follows:

• Active Account Data: Retained for as long as your account remains active on the r77 platform.
• Closed Account Data: Closed account information is retained for a minimum of 5 years after the closing date for AML legal compliance and financial reporting requirements.
• Transaction Records: All financial transaction records are retained for a minimum of 7 years in line with applicable financial legal requirements.
• Communication Logs: Customer support communication records are retained for 3 years for reference and dispute resolution purposes.
• Technical Data: Access logs and technical data are retained for 12 months for security and investigation purposes.

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

R77 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored in your web browser when you visit the r77 site.

R77 uses several types of cookies:

• Essential Cookies: Required for core platform functions such as login verification, game session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collecting anonymous information about how visitors use the platform to help us identify areas for improvement.
• Functional Cookies: Remembering your preferences such as language, region and display settings to deliver a more personalized experience.
• Analytics Cookies: Helping r77 understand platform usage patterns in aggregate for product improvement purposes.

You can control or disable cookies through your web browser settings. However, disabling certain cookies may affect the functionality or performance of some parts of the r77 platform.

As an r77 member, you have several important rights regarding the personal data we hold about you. These rights can be exercised by contacting the r77 customer support team:

As a responsible financial platform, r77 is legally required to carry out Know Your Customer (KYC) procedures and comply with Anti-Money Laundering (AML) laws.

The r77 KYC process involves collecting and verifying identity documents including:

• A valid government-issued identity document such as a national ID or passport.
• Recent proof of residential address, such as a utility bill or bank statement.
• In certain cases, source of funds documentation for large withdrawal amounts.

All documents submitted for KYC are stored securely with full encryption and are only accessible by authorised r77 verification staff. r77 will not use KYC documents for any purpose other than identity verification and applicable legal compliance.

Should any concerns arise regarding money laundering or terrorism financing activities, r77 is required to report to the relevant authorities without notifying you in advance (as mandated by law).

R77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, new legal requirements, or added platform features. Members will be notified of any material amendments via:

• In-platform notices on r77 that appear when you log in.
• Email to your registered address for significant amendments.
• Update the "Last Updated" date at the top of this document.

Continued use of the r77 platform after any amendments to the Privacy Policy take effect means you accept the updated version. If you do not agree with the amendments, you have the right to close your account and request data deletion in accordance with the procedure set out in Section 9.

If you have any questions, concerns, or wish to exercise any of your rights regarding personal data, you can contact the r77 Privacy team through the following:

• Live Chat: The live chat function available within the r77 platform — the fastest way to get an immediate response.
• Support Email: Send your privacy-related enquiries to [email protected] with the subject line "Privacy Enquiry".
• FAQ Section: Check FAQ page for answers to the most frequently asked questions about data privacy and security.

R77 is committed to addressing all privacy-related enquiries seriously and within a reasonable timeframe. We welcome your feedback as it helps us continuously improve our privacy practices.