Privacy Policy 38vf — Your Data Security

Information We Collect

To provide a secure, personalised and effective service, 38vf collects several categories of information from our players. This collection is done directly (when you register or interact with the platform) as well as automatically during use.

Personal Identification Information:

• Full name as it appears on a valid identification document.
• Date of birth — for age verification purposes (18 years and above).
• National identification number (MyKad) or passport number for international players.
• Full current residential address.

Contact Information:

• An active and valid email address for account communication purposes.
• Mobile phone number for two-factor authentication (2FA) and transaction notifications.

Financial Information:

• Bank account number, bank name, and account holder name for processing deposits and withdrawals.
• Digital wallet information (such as TNG eWallet, Boost, GrabPay) linked to your account.
• Records of deposit, withdrawal and wagering transactions within the platform.

Technical Information (Automatically Collected):

• IP address, web browser type, operating system, and device information.
• Login session data including date, time, and approximate geographic location.
• Platform usage data such as pages visited, games played, and session duration.
• Cookie data and similar tracking technologies (see Section 5).

How We Use Your Information

Information collected is used solely for the purpose of operating the 38vf platform and providing you with the best experience as a player. The following are the primary purposes for which your data is used:

Data Sharing & Disclosure

38vf does not sell, rent, or disclose your personal data to third parties for their commercial gain. However, in certain limited circumstances, we may share your information with the following parties:

• Payment Service Providers: Payment gateway providers, banks, and digital wallets used to process your financial transactions. They receive only the information necessary to complete the transaction.
• Gaming Technology Providers: Third-party game software companies that provide gaming content on our platform. Disclosure is limited to session identifiers without full personally identifiable information.
• Regulatory Bodies & Law Enforcement: When required by Malaysian law, a valid court order, or to assist in financial crime investigations such as money laundering.
• KYC Verification Services: Certified third-party identity verification service providers to ensure the authenticity of your documents.
• Group Companies: Corporate members within the 38vf group of companies, operating within strict operational necessity limits.

All third parties we work with are required to comply with data security standards equal to or higher than our own, and may only use your data for the purposes we have specified.

Data Security & Encryption

Protecting your data from unauthorised access, alteration, disclosure, or destruction is our absolute priority. 38vf implements multiple comprehensive layers of technical and organisational security:

• Transmission Encryption: All communications between your browser or app and our servers are protected by TLS 1.3 protocol with AES-256-bit encryption.
• Stored Data Encryption: Sensitive data such as banking information and passwords are stored in encrypted form using irreversible one-way encryption algorithms.
• Two-Factor Authentication (2FA): An additional security layer via SMS OTP or an authenticator app is available and encouraged for all accounts.
• 24/7 Security Monitoring: A real-time threat monitoring system that automatically detects and responds to suspicious activity.
• Regular Penetration Testing: Security audits and penetration testing are conducted periodically by independent security experts to identify and address any system vulnerabilities.
• Role-Based Access Control: Internal staff may only access data relevant to their job responsibilities, with every access recorded in an audit trail.

Cookies & Tracking Technologies

38vf uses cookies and similar tracking technologies to enhance your experience on our platform. Understanding how these cookies work helps you make more informed decisions about your privacy.

Types of Cookies We Use:

• Essential Cookies (Required): Required for core platform functions such as login authentication, session security, and language preferences. These cookies cannot be disabled without affecting platform functionality.
• Performance & Analytics Cookies: Helps us understand how players interact with the platform — pages frequently visited, time spent, and technical issues that need to be resolved. This data is collected in aggregate and anonymised form.
• Functional Cookies: Stores your preferences such as display language, personal settings, and login information ("Remember Me") for your convenience when you return.
• Marketing Cookies (Optional): Used to display relevant promotions and offers based on your interests. You may decline this type of cookie without affecting core platform functionality.

You may manage or delete cookies at any time through your web browser settings. Please note that disabling essential cookies may limit your ability to use certain features of our platform.

Your Rights as a User

As a 38vf player, you have the following rights regarding your personal data under Malaysia's PDPA and the international best practices we voluntarily uphold:

• Right of Access: You have the right to request and receive a copy of the personal data we hold about you. Requests will be processed within 14 working days.
• Right to Rectification: If any of your information is inaccurate or outdated, you have the right to request an immediate correction. For information you can update yourself, you may do so directly through your account profile settings.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data, subject to our legal obligations to retain certain records (such as financial transaction records for 7 years under Malaysia's AML regulations).
• Right to Restrict Processing: You have the right to request that we restrict how we process your data under certain circumstances, such as while a dispute regarding data accuracy is being resolved.
• Right to Object: You may object to the processing of your data for direct marketing purposes at any time, and we will cease such processing immediately.
• Right to Data Portability: You have the right to receive your data in a structured, machine-readable format for the purpose of transferring it to another service provider.

To exercise any of the above rights, please contact our customer support team through the platform. We may need to verify your identity before processing your request to ensure the security of your data.

Data Retention & Deletion

38vf retains your personal data for as long as necessary to fulfil the original purpose of collection, or as required by applicable Malaysian law.

• Active Account Data: Retained for as long as your account remains active. Data will be updated as needed during continued use.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with the requirements of the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLATFPUAA).
• KYC & Identity Verification Records: Retained for the duration of the active account period and an additional 5 years after account closure for regulatory compliance purposes.
• Log & Security Data: Retained for 12 months for security purposes, fraud detection, and dispute resolution.
• Inactive Account: Account data that has been inactive for more than 3 years with no outstanding balance may be archived and eventually deleted following an appropriate notification process.

Once the retention period expires, your data will be securely deleted using methods that ensure it cannot be recovered.

Privacy Policy Changes

38vf reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our service practices, legal requirements, or technological developments.

Any material changes to this policy will be communicated to you via:

• A prominent notice on our platform's home page or upon login.
• A notification email will be sent to the address registered to your account.
• In-app notifications via the 38vf mobile app (if you have enabled notifications).

Changes will take effect at least 14 days after the notice is published, giving you sufficient time to review them. Your continued use of our platform after the effective date will be considered your acceptance of the updated Privacy Policy.

If you disagree with any changes to this Privacy Policy, you have the right to close your account before the changes take effect. To do so, please contact our support team, available to assist you 24 hours a day.