Privacy Policy gula77 — Member Personal Data Protection

This Privacy Policy is published by gula77 ("we", "Platform") to clearly and transparently explain how we collect, use, process, store, and protect your personal data ("member", "you") when you access or use any part of the gula77 platform — including the website, mobile app, and all related services.

This Policy applies to all individuals who register as gula77 members, visit our website without registering, and anyone who interacts with our customer support team through any available communication channel.

We are committed to protecting your privacy in accordance with Personal Data Protection Act 2010 (PDPA) Malaysia. If you are under 18 years of age, please do not use this platform as we do not knowingly collect data from minors.

Gula77 collects personal data from various sources to ensure our platform operates safely, efficiently and in compliance with all applicable legal requirements. The categories of data we collect are as follows:

Data you provide directly:

• Account registration details: full name, date of birth, email address, mobile number, and residential address.
• Identity verification documents for the KYC process: copies of your national ID, passport, or valid travel document, as well as proof of address such as a utility bill or bank statement.
• Payment method details you use for deposits and withdrawals.
• Any information you share when contacting our customer support team.

Data we collect automatically:

• Technical data: IP address, web browser type and version, device operating system, screen resolution, and other device information.
• Usage data: pages visited, time spent on the platform, navigation patterns, and features used.
• Gaming session data: game types played, wagering amounts, wins, and session duration.
• Cookie data and similar tracking technologies (see Section 6 for more information).

Gula77 uses your personal data only for legitimate purposes that are clearly stated. We do not use your data for any other purpose without first obtaining your consent. Those purposes are:

• Account management: To create, verify and manage your member account, including the KYC identity verification process required before your first withdrawal.
• Transaction processing: To process deposits, withdrawals and any other financial transactions you conduct on the platform securely and efficiently.
• Customer support: To handle your enquiries, complaints and requests effectively across all available support channels.
• Security and fraud prevention: To detect, investigate and prevent fraudulent activity, money laundering or any other security threats against our platform and members.
• Legal compliance: To fulfil applicable legal and regulatory obligations, including reporting requirements to the relevant authorities.
• Platform improvements: To analyse usage patterns and feedback in order to improve the functionality, performance and user experience of our platform.
• Promotional communications: To notify you of the latest promotions, bonuses and offers — only if you have agreed to receive such communications.
• Responsible gaming: To monitor gameplay patterns and identify members who may need support related to responsible gaming.

Gula77 does not sell or trade members' personal data to any third party. However, we may share your data in certain limited circumstances as follows:

• Service providers: We work with carefully selected third-party companies to provide specific services such as payment processing, KYC identity verification, cloud services, and analytics. All these providers are bound by strict confidentiality agreements and are only permitted to use your data for the specified purposes.
• Legal authorities: gula77 may be required to disclose members' personal data to law enforcement agencies, regulatory bodies or other authorities when mandated by law or court order.
• Fraud prevention: In cases involving fraud, money laundering, or suspected illegal activity, we reserve the right to share relevant information with the appropriate authorities or fraud prevention organisations.
• Business transfers: In the event of a merger, acquisition, or sale of gula77 assets, members' personal data may be transferred to a new entity, subject to notice being given to you and equivalent privacy protections being in place.

The security of your personal data is gula77's highest priority. We implement multiple layers of technical and organizational protection to keep your data safe from unauthorized access, disclosure, alteration, or destruction.

Security measures we practice include:

• 256-bit SSL Encryption for all data transferred between your browser and our servers, ensuring no third party can intercept those communications.
• Role-based access control which ensures that only specifically authorised personnel can access sensitive member data, with every access recorded in an audit log.
• 24/7 security monitoring to detect and respond to any suspicious activity or security threats in real time.
• Regular security testing including penetration testing and vulnerability assessments to identify and remediate any security gaps before they can be exploited.
• Secure data backups to ensure service continuity and data recovery in the event of an emergency.

Gula77 uses cookies and similar tracking technologies to enhance your experience on our platform, ensure account security and analyse usage patterns for continuous improvement.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login verification and session security. These cookies cannot be disabled as the platform will not function properly without them.
• Functional Cookies: Stores your preferences such as language, display settings, and other preferences to deliver a more personalized experience.
• Analytics Cookies: Helps us understand how members use the platform, which pages are most popular, and where users encounter difficulties, enabling us to continuously improve our services.
• Security Cookies: Used to identify and prevent fraudulent activity, including detecting suspicious login patterns.

You can manage your cookie settings through your web browser settings. However, disabling certain cookies may affect the functionality and your experience on the gula77 platform.

As a gula77 member and data subject under Malaysia's PDPA, you have the following rights regarding the personal data we hold about you:

Gula77 is an online gambling platform designed exclusively for adults aged 18 and above. We do not knowingly or intentionally collect, process or store personal data of individuals under the age of 18.

If we discover or are notified that a child's personal data has been collected without our knowledge, we will take immediate steps to delete that data and close the relevant account. Parents or guardians who become aware that their child has registered on this platform are advised to contact our support team immediately.

The gula77 platform may contain links to third-party websites or services from time to time. This Privacy Policy applies only to the gula77 platform and does not cover the privacy practices of any external websites you may visit through those links.

Gula77 is not responsible for the content, privacy policies or practices of any third-party websites. We recommend that you read the Privacy Policy of every website you visit to understand how your data is handled by them.

Third-party service providers we use — such as payment processors and analytics platforms — have their own privacy policies governing the use of data shared with them. All providers we select are trusted and meet security standards that satisfy our requirements.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how gula77 handles your personal data, our team is available to assist you 24 hours a day, 7 days a week.

You can reach us via:

• Email: [email protected] — for privacy and personal data enquiries
• Live Support: Via the live chat function available on the gula77 platform
• FAQ Section: For frequently asked questions that may already be answered on the FAQ us

We are committed to responding to all privacy-related inquiries within 3 working days. For requests involving data access or deletion rights, the response period is up to 30 calendar days in accordance with PDPA requirements.