Privacy Policy 711cu – Member Personal Data Protection

This Privacy Policy is issued by 711cu ("we", "our platform") and applies to all individuals who register, browse, or use the services provided through the 711cu website and mobile app. By using our platform, you acknowledge that you have read, understood, and agreed to the terms set out in this policy.

As an online sports betting and casino platform operating in Malaysia, 711cu is bound by legal obligations under Personal Data Protection Act 2010 (PDPA) Malaysia. We take this responsibility very seriously and strive to go beyond the minimum requirements set by law.

This policy details:

• Types of personal data we collect from you
• Why and how we use your data
• Who may have access to your data
• How long we retain your data
• Your rights regarding your personal data
• How to contact us for questions or concerns

711cu collects various categories of personal data depending on how you interact with our platform. Below is a full description of the types of data we process:

We do not collect sensitive personal data such as health information, religious beliefs, political views, or biometric data unless it is specifically required for identity verification purposes and clearly disclosed to you.

Every piece of personal data we collect has a clear and lawful purpose. 711cu does not collect data excessively or for undisclosed purposes. The following are the primary purposes for collecting your personal data:

• Account management: Creating, verifying, and securely maintaining your member account, including processing registration and KYC verification.
• Transaction processing: Processing deposits, withdrawals, and all other financial transactions accurately and securely using available payment methods including FPX, Touch 'n Go eWallet, GrabPay, and bank transfers.
• Security & fraud prevention: Detecting, investigating, and preventing fraudulent activity, money laundering, and any misuse of the platform.
• Regulatory compliance: Fulfilling legal obligations under the PDPA, anti-money laundering (AML) laws, and applicable regulatory requirements.
• Service improvement: Analysing usage patterns to improve the user experience, platform performance, and the relevance of our product offerings.
• Customer support: Providing technical assistance and resolving any enquiries or complaints you submit to our support team.
• Marketing communications: Sending information about promotions, bonuses, and special offers – only if you have given consent to receive such communications.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling and providing appropriate support in line with our policy Responsible Gaming us.

The processing of your personal data by 711cu is grounded in a solid legal basis under Malaysia's PDPA. We process your data on one or more of the following bases:

• Consent: You have provided explicit consent for data processing for specific purposes, such as receiving marketing communications. You may withdraw this consent at any time.
• Contract fulfillment: Processing is necessary to perform a contract to which you are a party — namely, your use of 711cu services under the agreed Terms and Conditions.
• Legal obligation: Processing is required to comply with applicable Malaysian law, including KYC, AML, and financial regulatory requirements.
• Legitimate interest: Processing is necessary for the legitimate interests of 711cu or third parties, such as fraud prevention and platform security enhancement, provided those interests do not override your rights and freedoms.

711cu does not sell, rent, or trade your personal data to third parties for their own marketing purposes. However, in operating our services, we may share your data with the following categories of third parties under limited and controlled circumstances:

• Payment service providers: Financial institutions, payment processors, and e-Wallet providers required to securely process your deposits and withdrawals.
• Game providers: Gaming software companies that provide game content within the 711cu platform. Data sharing is limited to information required to verify player identity and prevent fraud.
• Technical service providers: Companies that provide technical infrastructure, cloud computing, data analytics, and IT support services that enable our platform to operate efficiently.
• Regulatory authorities and law enforcement: In circumstances where we are legally required to disclose data to Malaysian or international authorities, we will do so in accordance with proper legal procedures.
• Legal and financial professionals: Lawyers, accountants, or auditors bound by strict professional confidentiality obligations who only receive data that is strictly necessary.

Every third party that receives your data is required to sign a data processing agreement ensuring they handle your information in accordance with the security standards set by 711cu and meet PDPA requirements.

711cu retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by Malaysian law. The following are our general data retention guidelines:

• Active account data: Retained for the duration your 711cu account remains active and in use on the platform.
• Financial transaction data: Retained for a minimum of 7 years after the transaction occurs, in line with Malaysia's accounting and AML legal requirements.
• KYC records: Retained for 5 years after the business relationship ends, or longer if required by applicable law.
• Support communication logs: Retained for 3 years to allow review of interaction history and dispute resolution where necessary.
• Technical data and access logs: Retained for 12 months for security and incident investigation purposes.
• Marketing data: Retained until you withdraw consent or request data deletion, whichever comes first.

Upon expiry of the retention period, your data will be securely deleted or anonymised so that it can no longer be linked to you personally.

Under Malaysia's PDPA, you have the following rights regarding your personal data held by 711cu. We are committed to respecting and facilitating the exercise of these rights:

The 711cu website and app use cookies and similar tracking technologies to enhance the user experience and gather analytical information. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collecting information on how you use the platform – pages visited, time spent, and any errors encountered – to help us improve our services.
• Functional Cookies: Enables the platform to remember your preferences such as language, account settings, and display options to deliver a more personalised experience.
• Analytics Cookies: Used to understand aggregated user behaviour for product improvement purposes. This data is anonymised and not linked to any individual identity.

You can manage cookie settings through your browser settings. Please note, however, that disabling essential cookies may affect overall platform functionality and your user experience.

In some cases, your personal data may be transferred to, or processed in, countries outside Malaysia — particularly when we use cloud service providers or technical infrastructure based overseas.

711cu ensures that all international data transfers are carried out with adequate safeguards, including:

• Transfers only to countries recognized as having a level of data protection equivalent to or higher than Malaysia
• Use of approved standard data transfer agreements with contractually binding protection clauses
• A data protection impact assessment is conducted before any new transfer is approved

711cu implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Key measures we employ include:

• Data encryption in transit: All communications between your device and our servers are secured by TLS 1.3 protocol with 256-bit SSL encryption.
• Data encryption at rest: Sensitive data stored in our databases is encrypted using industry-standard encryption algorithms.
• Role-based access control: Access to member personal data is restricted to staff with a legitimate business need only, based on the principle of least privilege.
• 24/7 security monitoring: Threat detection and anomaly monitoring systems operate around the clock to identify and address any suspicious activity.
• Regular penetration testing: Security audits and penetration testing are conducted periodically by independent security experts to identify system vulnerabilities.
• Staff training: All 711cu staff who handle personal data undergo comprehensive security and privacy training on a regular basis.

In the event of a security incident affecting your personal data, 711cu will notify you and the relevant authorities within the timeframe required by law, and take immediate steps to contain and remediate the situation.

711cu reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, or the way we operate our services. Each new version will be published on this website with a clear update date.

For significant amendments, we will provide clear notice to members via:

• In-platform notification upon your next login
• Emailed to your registered email address at least 14 days before the changes take effect
• Banner or pop-up display notifying you of policy updates

Continued use of the 711cu platform after the effective date of any amendment constitutes acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, our Privacy Officer (Data Protection Officer) is ready to assist you:

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week directly on the 711cu platform
• FAQ: Visit FAQ page us for quick answers to frequently asked questions

We are committed to responding to all privacy-related enquiries within 14 Business Days. For more complex complaints requiring thorough investigation, we will notify you of a more precise timeline.

If you are not satisfied with our response, you have the right to file a complaint with Malaysia Department of Personal Data Protection which falls under the Ministry of Digital.