Mitr77 Privacy Policy – Malaysia Member Personal Data Protection

1. Introduction and Scope of This Policy

Mitr77 ("we", "the Company", or "the platform") is fully committed to protecting the privacy and personal data of every member who uses our platform. This Privacy Policy is drawn up in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and applicable international data protection standards.

This document details the types of personal data we collect, the purposes of collection, how we protect that data, and your rights as the data owner. We believe that transparency is the foundation of trust, and trust is the foundation of a healthy, long-term relationship between mitr77 and its members.

This Privacy Policy applies to all services offered by mitr77, including Sports Betting, online casino, slots, poker, e-sports, the mobile app, and all official mitr77 communication channels such as Live Chat, support email, and official social media.

2. Types of Personal Data We Collect

2.1 Data You Provide Directly

When you register a mitr77 account, make a deposit or withdrawal, or contact our support team, you provide the following personal data:

• 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, account holder name, and registered digital wallet details for deposit and withdrawal purposes.
• Verification Documents (KYC): A copy of your MyKad or passport, a recent bank statement, and proof of address such as a utility bill.
• Account Information: Username, password (stored in hashed form — not plain text), and security questions.

2.2 Automatically Collected Data

While you use the mitr77 platform, our systems automatically collect technical data for security, performance, and user experience improvement purposes:

• Device & Technical Data: IP address, browser type, operating system, screen resolution, and unique device identifier.
• Platform Activity Data: Pages visited, visit duration, games played, bets placed, total deposits and withdrawals, and general usage patterns.
• Location Data: General geographic location based on IP address, for regional verification and regulatory compliance purposes.
• Session Data: Login details, active session duration, and account activity records for security purposes.

Data Category	Example	Primary Purpose
Identity Verification	Name, MyKad, date of birth	Identity verification (KYC), legal compliance
Contact Information	Email, phone number	Account communications, security notifications
Financial Data	Bank account number	Deposit & withdrawal processing
Technical Data	IP address, device type	Security, fraud detection
Activity Data	Betting records, games played	Responsible wagering, service improvement

3. How We Use Your Personal Data

Mitr77 uses the personal data collected solely for lawful purposes directly related to the provision of platform services. The specific purposes for which your data is used are as follows:

• Account Management: Creating, verifying, and managing your member account securely.
• Transaction Processing: Processing deposits, withdrawals, and bonus payments accurately and promptly.
• Identity Verification (KYC): Fulfilling legal compliance obligations related to age verification and anti-money laundering (AML).
• Platform Security: Detecting and preventing fraudulent activity, unauthorised access, and platform abuse.
• Customer Support: Handling inquiries, complaints, and assistance requests effectively.
• Service Communications: Sending important notifications related to your account, transactions, and policy changes.
• Marketing & Promotions: Sending relevant promotional information and offers — only if you have given your consent to receive them.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and offer appropriate assistance.
• Analytics & Improvement: Analysing usage patterns to enhance the user experience, platform performance, and development of new features.
• Legal Compliance: Complying with all applicable legal obligations, regulations, and directives from relevant authorities.

4. Sharing Data with Third Parties

Mitr77 does not sell, rent, or disclose your personal data to any third party for marketing purposes without your explicit consent. However, in certain limited situations, we may share your data with the following parties:

4.1 Payment Service Providers

To process your deposits and withdrawals, we are required to share the necessary transaction information with payment gateway providers, banks, and the digital wallet platforms you use. This sharing is kept to a minimum and is limited solely to the information required to complete the transaction.

4.2 Game Software Providers

The mitr77 platform uses gaming software from internationally licensed providers. Play data shared with these providers is limited strictly to what is necessary to operate the games correctly and does not include personal financial information.

4.3 Legal Compliance and Authorities

Mitr77 is legally required to disclose personal data when mandated by law, court order, or official directive from a relevant authority. This includes requests from law enforcement agencies in legitimate investigations related to financial crime or money laundering.

5. Data Security and Protection

Mitr77 continually invests in security infrastructure to ensure your personal data is protected to the highest standard. The technical and organisational security measures we implement include:

• 256-bit SSL Encryption: All data transmitted between your browser or app and mitr77 servers is protected with industry-grade SSL encryption. No sensitive data is transmitted in plain text.
• Data-at-Rest Encryption: Sensitive information such as passwords is stored in hashed form using modern cryptographic algorithms. Your actual password is never stored in our system.
• Strict Access Control: Only mitr77 staff with a legitimate business need are permitted to access members' personal data, and every access is recorded in an audit log.
• 24/7 Security Monitoring: Our systems are continuously monitored by a cybersecurity team to detect any suspicious activity or intrusion attempts.
• Two-Factor Authentication (2FA): Members are encouraged to enable 2FA on their accounts as an additional layer of protection against unauthorised access.
• Data Segregation: Member data is stored in isolated server environments secured by multi-layered firewalls.
• Regular Security Testing: mitr77 conducts regular penetration testing and security audits by independent parties to identify and remediate any system vulnerabilities.

6. Cookies and Tracking Technologies

Mitr77 uses cookies and similar tracking technologies to enhance your experience on our platform. The types of cookies we use are as follows:

6.1 Essential Cookies

These cookies are required for the platform's core functions, including login session management, security, and language preferences. The platform cannot function properly without them and they cannot be disabled.

6.2 Performance & Analytics Cookies

These cookies help us understand how members interact with the platform — which pages are visited most frequently, where users encounter issues, and how long they spend in each section. This information is used solely to improve the platform's design and functionality.

6.3 Functional Cookies

These cookies store your preferences such as selected language, preferred display format, and specific account settings, so you don't have to reconfigure them every time you log in.

You can manage or block cookies through your browser settings at any time. Please note that blocking essential cookies may affect certain features of the mitr77 platform.

7. International Data Transfers

As a global online platform, some of your personal data may be stored or processed on servers located outside Malaysia. mitr77 ensures that any international data transfer occurs only to countries or entities with equivalent or higher data protection standards.

In all cases of cross-border data transfers, mitr77 ensures that appropriate data processing agreements are in place with all receiving parties, obligating them to protect your data in accordance with the standards set by Malaysia's PDPA.

8. Data Retention Period

Mitr77 retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by law. General data retention guidelines are as follows:

• Active Account Data: Retained for the entire duration that your mitr77 account remains active on the platform.
• Financial Transaction Data: Retained for a minimum of 7 years after the transaction date, in accordance with Malaysia's financial regulatory requirements.
• KYC Records: Retained for 5 years after account closure in line with AML compliance requirements.
• Security Logs: Retained for 2 years for security incident investigation purposes where necessary.
• Closed Account Data: Basic information is retained for 5 years after account closure before being permanently deleted.

9. Your 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 mitr77:

10. Children's Privacy

Mitr77 services are exclusively for individuals aged 18 and above. mitr77 does not intentionally collect personal data from minors. Should we discover that a child's personal data has been collected without our knowledge, such data will be deleted immediately and the associated account will be closed.

If you believe your child or a minor you know has registered an account on mitr77, please contact our support team immediately so that appropriate action can be taken without delay.

11. Links to Third-Party Platforms

The mitr77 platform may contain links to third-party websites or applications, such as gaming software providers or our official social media channels. This Privacy Policy applies solely to the mitr77 platform and does not cover the privacy practices of any such third parties.

Mitr77 is not responsible for the privacy policies or content of third-party platforms. We encourage you to read the privacy policy of each platform you visit independently.

12. Amendments to This Privacy Policy

Mitr77 reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, new technologies, or updated legal requirements. Whenever this Privacy Policy is updated, the "Last Updated" date at the top of this document will be revised accordingly.

For material amendments — that is, changes that significantly affect how we use your personal data — mitr77 will notify you via an in-platform notification or by email to the address registered to your account, at least 14 days before the amendment takes effect.

13. Contact Our Privacy Officer

If you have any questions, concerns, or wish to exercise your personal data rights, please contact the mitr77 Privacy & Data Protection team through the following channels:

• Privacy Email: [email protected]
• Live Chat: Available 24/7 on the mitr77 platform — state "Data Privacy Inquiry" to the support agent
• Response Time: All privacy inquiries will be responded to within 5 business days

We are committed to handling every privacy inquiry with seriousness, professionalism, and within the stipulated timeframe. Your trust is our most valuable asset.