padu44 Privacy Policy — How We Handle Your Personal Data

This Privacy Policy ("Policy") applies to all personal data collected by padu44 ("we", "us", "our") in connection with the operation of the padu44 platform at padu44.co and any associated services (collectively, the "Services"). It applies to all registered users ("you", "your") and visitors to the Platform.

By registering a padu44 account or using the Services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, you should not create an account or use the Services.

This Policy is to be read in conjunction with the padu44 Terms & Conditions, which are incorporated herein by reference.

padu44 is the data controller in respect of personal data collected through the Platform. For all data-related enquiries, requests, or complaints, you may contact the padu44 Data Protection team at:

Email: [email protected]
Subject line: Data Privacy Request — [Your Registered Email]

We aim to respond to all data-related requests within 14 business days of receipt.

padu44 collects personal data in the following categories:

3.1 Registration Data

• Full legal name;
• Date of birth (for age verification purposes);
• Email address;
• Phone number;
• Residential address; and
• Username and hashed password.

3.2 Identity Verification Data (KYC)

• Government-issued photo identification (MyKad, passport, or equivalent);
• Proof of address documents; and
• Payment method verification documents where required.

3.3 Financial Data

• Deposit and withdrawal transaction records;
• Payment method identifiers (e.g., masked card numbers, eWallet account identifiers); and
• Account balance history.

3.4 Usage & Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features accessed;
• Game and betting activity logs; and
• Customer support interaction records.

3.5 Communications Data

• Correspondence submitted via support channels; and
• Preferences for marketing and promotional communications, where consent has been given.

padu44 processes your personal data for the following purposes and on the following legal bases:

• Account creation and management — necessary for the performance of the contract between you and padu44;
• Identity verification and KYC compliance — necessary to comply with gaming authority licensing obligations and financial crime prevention requirements;
• Processing of deposits and withdrawals — necessary for the performance of the contract;
• Fraud prevention and security monitoring — necessary for padu44's legitimate interests in protecting the Platform and its users;
• Responsible gaming monitoring — necessary to comply with regulatory obligations and for the protection of user wellbeing;
• Customer support — necessary for the performance of the contract;
• Platform analytics and improvement — necessary for padu44's legitimate interests in improving the Services; and
• Marketing communications — based on your consent, which may be withdrawn at any time.

padu44 does not sell, rent, or trade personal data. We may share your data with the following categories of third parties, strictly for the purposes described in this Policy:

• Payment processors — Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank, Visa/Mastercard, DuitNow, and FPX service providers — to process your financial transactions;
• KYC and identity verification providers — to verify your identity in compliance with gaming authority requirements;
• Gaming software providers — limited technical identifiers required to operate game sessions on behalf of padu44;
• IT infrastructure and cloud service providers — operating under data processing agreements that prohibit independent use of your data; and
• Regulatory and law enforcement authorities — where padu44 is required by applicable law, court order, or gaming authority directive to disclose information.

All third-party service providers who process personal data on padu44's behalf are subject to contractual data protection obligations consistent with this Policy.

padu44 retains personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, and audit obligations. The following minimum retention periods apply:

• Account and KYC data: minimum 5 years from account closure, as required by gaming authority regulations;
• Financial transaction records: minimum 7 years, in accordance with financial record-keeping requirements;
• Customer support records: minimum 3 years from the date of the last interaction; and
• Marketing consent records: retained until consent is withdrawn, plus 12 months as an audit trail.

Upon expiry of applicable retention periods, personal data will be securely deleted or anonymised.

The padu44 Platform uses cookies and similar tracking technologies. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function — including session authentication tokens and security cookies. These cannot be disabled without affecting core Platform functionality.
• Analytics Cookies: Used to understand how users interact with the Platform (e.g., pages visited, session duration, feature usage). Data is aggregated and anonymised. These cookies may be disabled through your browser settings without affecting core functionality.
• Preference Cookies: Used to remember your language, display preferences, and responsible gaming settings between sessions.

You can manage your cookie preferences at any time through your browser's settings. Note that disabling strictly necessary cookies may prevent you from logging in to your padu44 account.

Subject to applicable data protection law and our regulatory obligations, you have the following rights in respect of your personal data held by padu44:

• Right of access — you may request a copy of the personal data padu44 holds about you;
• Right to rectification — you may request correction of inaccurate or incomplete personal data;
• Right to erasure — you may request deletion of your personal data, subject to padu44's legal retention obligations;
• Right to restrict processing — you may request that padu44 restricts the processing of your data in certain circumstances;
• Right to data portability — you may request a machine-readable copy of personal data you have provided to padu44; and
• Right to withdraw consent — where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact padu44 at [email protected] with the subject line "Data Privacy Request". We will respond within 14 business days.

padu44 implements industry-standard technical and organisational security measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit;
• Encryption of sensitive data at rest, including password hashes and payment identifiers;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security audits and penetration testing;
• Two-factor authentication options for user accounts; and
• Login anomaly detection and automated alerting for suspicious access patterns.

No method of data transmission or storage is completely secure. In the event of a data breach that poses a risk to your rights, padu44 will notify affected users as required by applicable regulation.

The padu44 Platform is strictly for users aged 21 and above. padu44 does not knowingly collect personal data from individuals under 21. If padu44 becomes aware that an account has been registered by or on behalf of a minor, the account will be closed immediately, all associated funds forfeited, and the data deleted in accordance with this Policy. If you believe a minor has created a padu44 account, please notify us immediately at [email protected].

padu44 reserves the right to update this Privacy Policy at any time. Material changes will be notified to registered users via email to their registered address or via an in-platform notification prior to the effective date of the change. Your continued use of the Platform following notification of a change constitutes acceptance of the revised Policy.

The current version of this Policy is always accessible at padu44.co/privacy-policy. We recommend reviewing this Policy periodically.