puma77 Privacy Policy – How We Handle Your Personal Data on Our Malaysia Online Platform

puma77 ("puma77", "we", "us", "our") is the operator of puma77.club, an online casino and sports betting platform serving members across Malaysia and internationally. For the purposes of this Privacy Policy, puma77 is the data controller in respect of your personal data collected through the Platform.

puma77 operates under applicable international gaming authority regulations. Our commitment to data privacy is embedded in our operational and technical practices, and we take our obligations as a data controller seriously.

puma77 collects the following categories of personal data from members and prospective members:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (for age verification — all puma77 members must be 21 or above)
• Email address and mobile phone number
• Residential address
• Nationality and country of residence

2.2 Verification & KYC Data

• Government-issued identity document (e.g., MyKad, passport)
• Selfie or photograph for identity verification purposes
• Source-of-funds documentation where required by our AML policy

2.3 Financial Data

• Bank account details, e-wallet identifiers (Touch 'n Go eWallet, Boost, GrabPay, DuitNow), or other payment instrument details used for deposits and withdrawals
• Transaction history: deposits, withdrawals, bonuses, and wager records
• Account wallet balance history

2.4 Technical & Usage Data

• IP address, device type, operating system, and browser information
• Login timestamps and session durations
• Pages viewed, games played, bets placed, and navigation patterns within the Platform
• Geolocation data (city/country level, derived from IP address)

2.5 Communications Data

• Records of correspondence with puma77 support, including live chat transcripts and email exchanges
• Feedback and survey responses where voluntarily provided

puma77 collects personal data through the following channels:

Direct collection: Data you provide when registering a puma77 account, completing KYC verification, making a deposit or withdrawal request, contacting our support team, or participating in a promotion.

Automated collection: Technical and usage data collected automatically when you access the Platform, including data gathered through cookies, web beacons, and similar tracking technologies (see Section 8).

Third-party sources: Identity and fraud verification data from third-party KYC service providers; payment processing data from our payment partners; and, where applicable, data from gaming regulatory databases used to enforce self-exclusion obligations.

puma77 processes your personal data for the following purposes and on the following legal bases:

• Account registration and management — necessary for performance of the contract between you and puma77
• Age verification and KYC compliance — legal obligation; puma77 is required to verify that all members are aged 21 or above and to comply with anti-money laundering regulations
• Processing deposits, withdrawals, and wagers — necessary for performance of the contract
• Fraud prevention and security monitoring — legitimate interests of puma77 in protecting the Platform and its members from fraudulent activity
• Customer support and dispute resolution — legitimate interests and contractual obligation
• Regulatory reporting and compliance — legal obligation under applicable gaming and financial regulations
• Responsible gaming monitoring — legal obligation and legitimate interests; puma77 monitors gaming patterns to identify members who may be experiencing harm
• Platform analytics and improvement — legitimate interests of puma77 in operating and improving the Platform
• Direct marketing communications — consent, where you have opted in to receive promotional communications from puma77. You may withdraw consent at any time by contacting support or updating your account preferences

puma77 does not sell your personal data. We may share your data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate contractual protections:

5.1 Service Providers. Third parties engaged by puma77 to provide operational services, including: payment processing partners (e.g., FPX, DuitNow, and e-wallet providers), KYC and identity verification providers, cloud hosting and infrastructure providers, customer support platform providers, and game content providers (e.g., Pragmatic Play, PG Soft, Evolution Gaming). All service providers are bound by data processing agreements that restrict their use of your data to the purposes for which it was shared.

5.2 Regulatory Authorities. puma77 may disclose personal data to gaming regulators, financial intelligence units, law enforcement agencies, or other government authorities where required to do so by law, court order, or regulatory directive. We will notify affected members of such disclosures where legally permitted to do so.

5.3 Responsible Gaming Databases. Where required by our gaming licence, puma77 shares self-exclusion data with national or international responsible gaming databases to give effect to self-exclusion requests across multiple operators.

5.4 Business Transfers. In the event of a merger, acquisition, or sale of all or part of puma77's business, personal data may be transferred to the acquiring entity as part of the transaction, subject to equivalent data protection commitments.

puma77 operates internationally and may transfer personal data to countries outside Malaysia for processing by our service providers. Where such transfers occur, puma77 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to the protections provided under this Policy.

Safeguards for international transfers include: standard contractual clauses approved by the relevant data protection authority; transfers to service providers in jurisdictions recognised as providing an adequate level of data protection; and binding corporate rules where applicable.

puma77 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for a minimum of five (5) years following account closure, as required by applicable anti-money laundering regulations
• Financial transaction records: Retained for a minimum of seven (7) years following the transaction date, as required by applicable financial regulations
• Communications data: Retained for a minimum of two (2) years from the date of the communication
• Technical and usage data: Retained for up to twelve (12) months, except where required for longer periods for fraud investigation or regulatory purposes
• Self-exclusion records: Retained for the duration of the self-exclusion period and for a minimum of five (5) years thereafter

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with puma77's data destruction procedures.

puma77 uses cookies and similar tracking technologies on the Platform for the following purposes:

8.1 Strictly Necessary Cookies. These cookies are essential for the Platform to function correctly. They maintain your login session, remember your account preferences, and enable security features such as CSRF protection. These cookies cannot be disabled without impairing the functionality of the Platform.

8.2 Analytics Cookies. puma77 uses first-party analytics to understand how members navigate the Platform, which pages are most visited, and where members encounter difficulties. This data is used to improve the Platform experience. Analytics data is aggregated and does not identify individual members.

8.3 Functional Cookies. These cookies remember your preferences — such as your preferred language, last-visited game category, and display settings — to personalise your experience on subsequent visits to puma77.

8.4 Managing Cookies. You may control cookies through your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform. For other cookie categories, you may opt out without affecting core Platform functionality. Note that clearing cookies will log you out of your puma77 session.

puma77 implements the following technical and organisational security measures to protect your personal data:

• Transport encryption: All data transmitted between your device and puma77's servers is encrypted using 256-bit SSL/TLS encryption
• Access controls: Access to personal data is restricted to puma77 personnel and service providers with a legitimate need. Role-based access controls and multi-factor authentication are applied to all internal systems
• Data storage: Personal data is stored on secure servers with regular backups, intrusion detection systems, and vulnerability monitoring
• Incident response: puma77 maintains a data breach response procedure. In the event of a breach that poses a risk to your rights, we will notify affected members and the relevant regulatory authority within the timeframes required by applicable law

While puma77 takes significant steps to protect your data, no internet transmission is completely secure. You are responsible for keeping your puma77 account credentials confidential and for notifying us immediately if you suspect unauthorised access to your account.

Subject to applicable law, you have the following rights in respect of your personal data held by puma77:

• Right of access: You may request a copy of the personal data puma77 holds about you
• Right of rectification: You may request correction of inaccurate or incomplete personal data
• Right to erasure: You may request deletion of your personal data where we no longer have a legal basis to retain it. Note that this right is subject to our legal retention obligations under AML and financial regulations
• Right to restrict processing: You may request that we restrict processing of your data in certain circumstances, such as while a rectification request is under review
• Right to data portability: Where processing is based on your consent or on contract performance, you may request that we provide your data in a structured, machine-readable format
• Right to object: You may object to processing based on legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing

To exercise any of the above rights, contact puma77 via live chat or at [email protected]. We will verify your identity before processing any request and will respond within 30 days. For complex or numerous requests, this period may be extended by a further 30 days with prior notice.

puma77 is strictly for individuals aged 21 and above. We do not knowingly collect personal data from persons under 21. If we become aware that personal data has been collected from a person under the age of 21, we will promptly close the relevant account and delete the associated data in accordance with our data retention policy.

If you believe that a person under 21 has registered a puma77 account, please contact us immediately via live chat or at [email protected].

puma77 may update this Privacy Policy from time to time to reflect changes in our data practices, service offerings, or applicable law. When we make material changes, we will notify registered members via their registered email address or via a prominent notice on the Platform at least 14 days before the changes take effect.

The effective date at the top of this Policy indicates when the current version took effect. We recommend that you review this Policy periodically. Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgement of the updated Policy.

If you have questions about this Privacy Policy, wish to exercise a data right, or wish to raise a concern about puma77's data practices, please contact us through the following channels:

puma77 support operates in English, Malay, and Mandarin. For members across Malaysia — whether you're in Kuala Lumpur, Penang, Johor Bahru, or elsewhere — live chat is the fastest channel for privacy-related enquiries. We aim to acknowledge all written privacy requests within 2 business days.