866 Privacy Policy — Malaysian User Personal Data Protection

1 Introduction

866 ("we", "our platform") is an online entertainment platform operating under a recognised licence and committed to protecting the privacy of every user. This Privacy Policy explains in detail how we collect, process, store, and safeguard your personal data in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA).

When you register an account, make a deposit, play games, or simply browse the 866 platform, you may be providing us with personal information. This Policy is intended to ensure you fully understand your rights and how we handle that information responsibly.

This Privacy Policy applies to all services offered by 866, including our website, mobile app, and all official communication channels. By continuing to use the 866 platform, you confirm that you have read and understood this Privacy Policy.

2 Personal Data We Collect

We collect various types of information depending on how you interact with the 866 platform. The types of data we collect are as follows:

a) Information You Provide Directly

• Full name as stated on your national ID or passport.
• Date of birth and identification number (MyKad or passport).
• Email address and mobile phone number.
• Current residential address.
• Bank account or e-wallet information for payment processing.
• Identity verification documents (KYC) such as a copy of your national ID or passport.
• Information you share when contacting customer support.

b) Information Collected Automatically

• IP address and information about the device you use.
• Web browser type, operating system, and screen resolution.
• Activity log data including pages visited and access times.
• General geolocation information based on IP address.
• Cookies and similar tracking technology data.
• Transaction records and game history.

3 How We Use Your Data

The personal data we collect is used solely for legitimate purposes related to the operation of the 866 platform. The following are the primary purposes for which your data is used:

• Account Management: To create, verify, and manage your account on the 866 platform.
• Identity Verification (KYC): To fulfil anti-money laundering (AML) legal requirements and age verification.
• Transaction Processing: To process deposits, withdrawals, and bonus payments securely and accurately.
• Customer Support: To understand and resolve any issues or enquiries you raise with our team.
• Platform Security: To detect and prevent fraud, suspicious activity, or unauthorised use of the platform.
• Service Improvement: To analyse usage patterns and improve the overall user experience.
• Marketing Communications: To send promotional offers and platform updates — only if you have opted in to receive them.
• Legal Compliance: To meet the legal and regulatory obligations applicable to our platform's operations.

4 Legal Basis for Data Processing

866 processes your personal data on the following grounds recognised under data protection law:

• Consent: When you have explicitly consented to receive marketing communications or to certain data processing.
• Contract Performance: When processing is necessary to provide the services you have requested, including account management and transaction processing.
• Legal Obligation: When processing is required to comply with applicable laws and regulations, including AML and KYC requirements.
• Legitimate Interest: When processing is necessary for our legitimate interests, such as fraud prevention and platform security, subject to your interests and fundamental rights.

5 Data Sharing & Disclosure

866 does not sell or rent your personal data to any third party. However, we may share your information in limited circumstances as follows:

• Service Providers: Payment processing companies, KYC service providers, and technology infrastructure providers that help us operate the platform — all bound by strict confidentiality agreements.
• Game Providers: Third-party game software providers that require access to minimum necessary data to deliver a seamless gaming experience.
• Competent Authorities: Law enforcement agencies, regulatory bodies, or judicial authorities when required by law or a valid court order.
• Business Transfers: In the event of a merger, acquisition, or asset sale, user data may be transferred as part of the business assets — with appropriate notice given to users.

6 Data Security

866 invests seriously in security infrastructure to ensure your personal data is always protected. The security measures we employ include:

• Data encrypted in transit using TLS 1.3 protocol and 256-bit SSL encryption.
• Encryption at rest for all sensitive information.
• Multi-factor authentication (MFA) for both user account and internal staff access.
• 24/7 security monitoring by a dedicated cybersecurity team.
• Regular security audits conducted by qualified, independent third parties.
• Strict role-based access controls for internal staff.
• Secure data backup systems and tested disaster recovery procedures.

7 Data Retention Period

866 retains your personal data only for as long as necessary to fulfil the purposes set out in this Privacy Policy, or as required by law. General data retention guidelines are as follows:

Once the retention period expires, your data will be securely deleted or anonymised in accordance with our standard procedures.

8 Your Rights

Under applicable data protection laws, you have the following rights regarding your personal data that we hold:

• Right to Access: You may request a copy of the personal data we hold about you at any time.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete data.
• Right to Erasure: In certain circumstances, you may request that we delete your personal data ("right to be forgotten"), subject to our legal obligations.
• Right to Restrict Processing: You may request that we restrict how we process your data in certain circumstances.
• Right to Withdraw Consent: If processing is based on your consent, you may withdraw that consent at any time without affecting the validity of processing carried out prior to withdrawal.
• Right to Object: You may object to the processing of your data for direct marketing purposes at any time.

To exercise any of the above rights, please contact our privacy team by email at [email protected]. We will respond to your request within 30 business days.

9 Cookies and Tracking Technologies

The 866 platform uses cookies and similar technologies to enhance your experience. Cookies are small text files stored on your device when you visit our platform. We use the following types of cookies:

• Essential Cookies: Required for core platform functions such as login session management and security. These cookies cannot be disabled.
• Performance Cookies: Collects information on how you use the platform to help us improve performance and user experience.
• Functionality Cookies: Allows the platform to remember your preferences such as language and display settings for a more personalised experience.
• Analytics Cookies: Helps us understand platform usage patterns in aggregate and anonymised form for statistical purposes.

You can control and manage cookies through your web browser settings. However, disabling certain cookies may affect the functionality of the 866 platform.

10 International Data Transfers

In operating our platform, your personal data may be transferred to and stored on servers located outside Malaysia. When this occurs, we ensure that such transfers are carried out with appropriate safeguards, including:

• Use of standard contractual clauses approved by the relevant data protection authorities.
• Transfers only to countries with adequate or equivalent data protection standards.
• Binding data processing agreements with all third-party service providers involved.
• All transfers are secured with appropriate end-to-end encryption.

11 Children's Privacy

The 866 platform is strictly for individuals aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. Should we discover that we have collected personal data from a person under 18, we will promptly delete that data and close the relevant account.

12 Changes to This Privacy Policy

866 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service improvements. You will be notified of any material changes through:

• Clear notice on the home page or your account dashboard.
• Notification email sent to the address registered in your account.
• Update the "Last updated" date at the top of this document.

Your continued use of the 866 platform after any policy changes take effect constitutes acceptance of the updated Privacy Policy. If you disagree with the changes, you have the right to close your account and stop using the platform.

For any questions, concerns, or requests regarding this Privacy Policy, the 866 support team is available every day through our official communication channels.