Privacy Policy — 77win

Section 01

Introduction

This Privacy Policy ("Policy") is issued by 77win ("77win", "we", "us", "our") and applies to all personal data processed in connection with your use of the 77win website located at https://77win.click, including all associated pages, mobile-optimised services, and digital products offered through the platform (collectively, the "Platform").

77win is committed to protecting the privacy of all individuals who interact with our Platform, including registered players, prospective users, and visitors. We process personal data responsibly, transparently, and in accordance with applicable data protection legislation, including the Malaysian Personal Data Protection Act 2010 (PDPA) and such international frameworks as are applicable to our operations.

This Policy should be read alongside our Terms & Conditions, which govern the broader contractual relationship between you and 77win. In the event of any conflict between this Policy and the Terms and Conditions, this Policy shall prevail in respect of data protection matters.

Section 02

Definitions

For the purposes of this Privacy Policy, the following terms shall bear the meanings assigned below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, date of birth, financial data, and device identifiers, as defined under the Malaysian PDPA 2010 and applicable international data protection frameworks.
• "Data Controller" — 77win, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" — any third-party service provider engaged by 77win to process Personal Data on our behalf, subject to binding contractual data processing obligations.
• "Processing" — any operation or set of operations performed on Personal Data, whether by automated or manual means, including collection, storage, use, disclosure, alteration, and deletion.
• "Data Subject" — the natural person whose Personal Data is being processed. In the context of 77win, this refers to registered Players and Platform visitors.
• "Consent" — a freely given, specific, informed, and unambiguous indication by the Data Subject signifying agreement to the processing of their Personal Data for one or more specified purposes.
• "KYC" — Know Your Customer verification procedures required for identity, age, and source-of-funds verification in accordance with applicable compliance obligations.
• "Cookies" — small text files stored on a user's device by a website to collect and retain information about the user's browsing activity and preferences.

Section 03

Personal Data We Collect

77win collects personal data through various means, including information you provide directly upon registration, data generated through your use of the Platform, and information obtained from third parties for identity verification and fraud prevention purposes.

3.1 Data You Provide Directly

3.2 Data Collected Automatically

• Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, session duration, click behaviour, game activity logs, wagering history, and feature interaction patterns.
• Location Data: Approximate geolocation derived from your IP address, used to apply jurisdictional access controls.
• Cookie Data: First-party and third-party cookie identifiers, session tokens, and preference settings. See Section 7 for full details.

3.3 Data from Third Parties

• Identity verification data from KYC service providers to validate documents and cross-check against sanctions lists.
• Fraud screening signals from payment processors and risk management platforms.
• Publicly available information used to meet anti-money laundering (AML) and responsible gambling obligations.

Section 04

Legal Basis for Processing

77win processes your Personal Data on one or more of the following legal bases, in accordance with applicable data protection legislation:

• Contractual Necessity: Processing required to perform our contract with you — including account management, payment processing, game delivery, withdrawal handling, and customer support.
• Legal Obligation: Processing necessary to comply with applicable legal and regulatory requirements, including KYC identity verification, AML compliance, age verification (21+ minimum), responsible gambling obligations, and tax reporting duties.
• Legitimate Interests: Processing conducted in pursuit of 77win's legitimate business interests, where those interests are not overridden by your rights and freedoms — including platform security, fraud prevention, service improvement, and analytics.
• Consent: Where no other legal basis applies, we will seek your prior explicit consent before processing your Personal Data. You retain the right to withdraw consent at any time without detriment to prior processing.

Section 05

How We Use Your Personal Data

77win uses the Personal Data we collect for the following purposes:

• Account Administration: Creating, managing, and maintaining your registered account; processing login authentication; managing account security settings including two-factor authentication.
• Payment Processing: Facilitating deposits and withdrawals via supported Malaysian payment channels including Maybank, CIMB, Public Bank, DuitNow, FPX, Touch 'n Go eWallet, Boost, and GrabPay; reconciling transactions denominated in MYR; processing refunds where applicable.
• Identity & Age Verification: Verifying that you meet the 21+ minimum age requirement; confirming identity in compliance with KYC obligations; screening against sanctions and politically exposed persons (PEP) lists.
• Service Delivery: Providing access to sports betting, live casino, slot games, lottery, and other gaming products available on the Platform.
• Customer Support: Responding to queries submitted via live chat or email at [email protected]; managing complaints and dispute resolution processes.
• Fraud Prevention & Security: Detecting and preventing fraudulent transactions, account takeovers, money laundering, and other forms of financial crime; monitoring unusual account behaviour.
• Responsible Gambling: Monitoring gambling patterns to identify potentially problematic behaviour; administering self-exclusion and deposit limit requests; fulfilling our duty-of-care obligations toward players.
• Legal & Regulatory Compliance: Meeting obligations under applicable gaming licences, AML regulations, tax reporting requirements, and court or regulatory orders.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve Platform functionality, game selection, and user experience.
• Communications: Sending account-related notifications, security alerts, promotional communications (where you have opted in), and platform update notices.

Section 06

Data Sharing & Disclosure

77win does not sell your Personal Data to any third party. We may, however, share your data with the following categories of recipients where such sharing is lawful and necessary:

• Payment Service Providers: Banks, e-wallet operators, and payment gateway partners (including DuitNow, FPX network participants, Touch 'n Go eWallet, Boost, and GrabPay) for the purpose of processing transactions.
• Identity Verification Providers: Third-party KYC and AML service providers used to verify identity documents, screen sanctions lists, and conduct enhanced due diligence where required.
• Technology Partners: Cloud hosting providers, data analytics platforms, and IT infrastructure suppliers engaged under binding data processing agreements that restrict use of your data to the specific purposes for which it was shared.
• Game Content Providers: Where specific games are provided by third-party studios or aggregators, limited technical data may be shared with those providers solely for the purpose of game session delivery and technical support.
• Regulatory & Law Enforcement Authorities: Where required by law, court order, or regulatory direction — including disclosures to gaming regulatory bodies, financial intelligence units, and tax authorities.
• Successor Entities: In the event of a merger, acquisition, or asset sale involving 77win, personal data held by 77win may be transferred to a successor entity, subject to equivalent data protection commitments.

Section 07

Cookies & Tracking Technologies

77win uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, analyse usage patterns, and maintain session security. The following categories of cookies are employed:

You may manage your cookie preferences through your web browser settings. Disabling strictly necessary cookies will impair the functionality of the Platform and may prevent you from accessing certain features. Your browser's help documentation provides instructions for managing cookie preferences specific to your browser.

Section 08

Data Retention

77win retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable legal, regulatory, or contractual obligations.

• Active Account Data: Retained for the duration of your active account and for a period of five (5) years following account closure, to satisfy regulatory record-keeping requirements under applicable gaming and AML legislation.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification or account closure (whichever is later), in compliance with applicable AML and gaming regulatory requirements.
• Financial Transaction Records: Retained for seven (7) years from the date of transaction in accordance with Malaysian financial record-keeping obligations.
• Communication Records: Support interactions and email correspondence retained for three (3) years from the date of communication.
• Technical & Usage Data: Anonymised or aggregated usage analytics data may be retained indefinitely for Platform improvement purposes, provided it can no longer be used to identify individual Data Subjects.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised using industry-standard data destruction procedures.

Section 09

Data Security

77win implements a comprehensive set of technical and organisational security measures designed to protect Personal Data against unauthorised access, disclosure, alteration, loss, and destruction. These measures include, but are not limited to:

• Encryption: All data transmitted between your device and the 77win Platform is protected using 256-bit SSL/TLS encryption. Sensitive data fields, including passwords and financial identifiers, are encrypted at rest using industry-standard cryptographic protocols.
• Access Controls: Access to Personal Data within 77win's systems is restricted on a need-to-know basis, with role-based access controls and regular access review procedures.
• Two-Factor Authentication: 2FA is available to all players and strongly recommended. Internal system access by 77win staff requires multi-factor authentication.
• Penetration Testing: Regular third-party security assessments and vulnerability scans are conducted on 77win's infrastructure and applications.
• Incident Response: 77win maintains a documented data breach response plan. In the event of a security incident affecting your Personal Data, we will notify you and relevant regulatory authorities in accordance with our legal obligations.
• Staff Training: All 77win personnel with access to personal data receive mandatory data protection and security training upon onboarding and annually thereafter.

Section 10

Your Data Rights

Subject to applicable law and the grounds on which your Personal Data is processed, you hold the following rights in relation to your personal data held by 77win:

To exercise any of these rights, please submit your request in writing to [email protected] with the subject line "Data Rights Request". We will acknowledge your request within five (5) business days and respond substantively within thirty (30) calendar days. Where a request is complex or numerous, we may extend this period by a further thirty (30) days, notifying you of the extension and reasons therefor.

We may require you to verify your identity before processing your request, to ensure that Personal Data is not disclosed to unauthorised individuals.

Section 11

Children's Privacy & Age Restrictions

The 77win Platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect, process, or retain Personal Data from individuals under the age of 21 under any circumstances.

All registration attempts are subject to mandatory age verification as part of 77win's KYC procedures. Where we have reasonable grounds to believe that an account has been registered by, or is being used by, a person under the age of 21, we will immediately:

• Suspend the account and restrict all gaming activity pending investigation.
• Conduct enhanced KYC verification to establish the account holder's true age.
• Where the underage use is confirmed, permanently close the account, forfeit any balance in accordance with applicable regulatory requirements, and delete or anonymise associated personal data to the extent legally permissible.
• Report the matter to relevant regulatory authorities where required by law.

Section 12

Cross-Border Data Transfers

In the course of providing its services, 77win may transfer your Personal Data to service providers or infrastructure partners located outside Malaysia. Such transfers may occur to jurisdictions where data protection laws differ from those applicable in Malaysia.

Where such transfers occur, 77win takes appropriate safeguards to ensure that your Personal Data receives a level of protection consistent with the standards required under applicable Malaysian law and this Privacy Policy. These safeguards may include:

• Binding contractual clauses with recipient entities imposing equivalent data protection obligations.
• Transfer only to jurisdictions that maintain adequately protective data protection frameworks as assessed by 77win's compliance team.
• Technical measures including encryption and pseudonymisation to minimise the risk associated with cross-border data flows.

Where required by applicable law, 77win will obtain your consent prior to transferring your Personal Data internationally, or will ensure that an appropriate exemption or safeguard applies to such transfer.

Section 13

Updates to This Privacy Policy

77win reserves the right to update, revise, or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. All amendments will be published on this page with a revised effective date.

Where changes are material in nature — meaning they significantly affect how we process your Personal Data or your rights in respect of it — we will provide advance notice via email to your registered address or via a prominent notice on the Platform prior to the amended Policy taking effect.

Your continued use of the 77win Platform following publication of an amended Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to remain informed of how your Personal Data is handled.

Section 14

Contact & Data Protection Enquiries

If you have any questions, concerns, or requests in connection with this Privacy Policy, your Personal Data, or the exercise of your data rights, please contact 77win through the following channels:

• Privacy & Data Protection Enquiries (Email):
  [email protected]
  Please include "Privacy Policy Enquiry" or "Data Rights Request" in the subject line.
• Live Chat Support: Available 24/7 through the 77win Platform — for urgent account-related data queries. Average response: under 5 minutes (Malaysian Standard Time, UTC+8).

We aim to acknowledge all privacy-related correspondence within five (5) business days and to respond substantively within thirty (30) calendar days of receipt. Where a request requires additional time to process, we will notify you of the extended timeline and the reasons for it.