77 Club Privacy Policy — Personal Data Protection for Malaysian Members

1Introduction & Scope of Privacy Policy

77 Club ("we", "the platform") is committed to protecting the privacy of every member who uses our services in Malaysia. This Privacy Policy has been drafted in accordance with the provisions of the Personal Data Protection Act 2010 (PDPA) Malaysia and clearly explains how we handle your personal information.

This Privacy Policy applies to all information collected through the 77club.my website, the 77 Club mobile app (where applicable), our official communication channels including email and live chat, and any other interactions between you and the 77 Club platform.

We believe transparency is the foundation of trust. This Privacy Policy is written in plain, accessible English so that every Malaysian member can understand it without needing to translate or seek external assistance.

2Types of Personal Data We Collect

77 Club collects two main categories of data: information you provide directly, and data collected automatically as you use our platform.

We only collect data that is strictly necessary to provide services to you. We do not collect sensitive data such as your medical information, religious beliefs, or political views.

3How We Use Your Data

Every piece of data we collect has a clear and legitimate purpose. Below is a full list of how 77 Club uses its members' personal data:

• Identity verification and member eligibility — verifying that you meet the minimum age requirement of 21 and other eligibility criteria in accordance with 77 Club's Terms & Conditions.
• Financial transaction processing — facilitating deposits via DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, FPX (Maybank2u, CIMB Clicks), and withdrawals to your bank account.
• Account management and security — detecting unusual login activity, preventing unauthorised access, and protecting your account from fraud.
• AML legal compliance — to meet Malaysia's mandatory Anti-Money Laundering (AML) requirements.
• Service communications — sending important notices regarding your account, transactions, policy changes, and relevant promotions.
• Platform enhancements — analysing aggregated usage patterns (without identifying individuals) to improve the 77 Club user experience.
• Customer support — resolving enquiries, complaints, and disputes more efficiently using previous interaction records.
• Responsible gambling — to identify betting patterns that may indicate problem gambling and offer early assistance to members in need.

4Information Sharing & Disclosure

77 Club does not sell your personal information with any party. However, in certain limited circumstances, we may need to share your data with the following parties:

• Payment Service Provider: Payment gateways processing transactions via DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, and FPX require access to the transaction information necessary to process your payments. All such providers are bound by strict confidentiality agreements.
• Malaysian Authorities: Where required by law, court order, or direction from a competent authority such as Bank Negara Malaysia or law enforcement agencies, we will disclose the necessary information.
• IT Service Providers: Companies that assist us in operating the platform's technical infrastructure — including server hosting and cybersecurity services — may access data in a limited capacity and are bound by confidentiality agreements.
• Independent Auditor: Appointed audit firms engaged to ensure regulatory and financial compliance may access certain records within the scope of their work.

In all sharing arrangements described above, 77 Club ensures that all recipients are bound by data protection obligations that are equivalent to or stricter than our own standards.

5Data Security Measures

77 Club continually invests in security infrastructure to ensure that Malaysian members' data is always protected to the highest standard. The security measures we have in place include:

• 256-bit SSL Encryption for all data transmitted between your browser and our servers.
• Encryption at rest for all sensitive data stored in our databases.
• Two-factor authentication (2FA) as an additional security layer for member account logins.
• 24/7 Monitoring by our cybersecurity team to detect any unusual activity or intrusion attempts.
• Regular security audits by independent third parties to identify and patch any system vulnerabilities.
• Strict internal access controls — only specifically authorised 77 Club staff may access member data, and all access is logged for audit purposes.

While we take all reasonable precautions, no digital system can guarantee absolute 100% security. We therefore encourage members to take personal security measures as well, such as using a strong password and not sharing account credentials.

6Cookie Policy

The 77 Club platform uses cookies — small text files stored on your device — to enhance your experience and ensure the platform runs smoothly. The following are the types of cookies we use:

You can manage or block cookies at any time through your web browser settings. Please note, however, that blocking essential cookies may affect the functionality of the 77 Club platform and could make logging in or completing transactions more difficult.

7Your Rights as a Member

Under Malaysia's PDPA and the 77 Club Privacy Policy, you have the following rights regarding your personal data:

To exercise any of the rights above, please contact us at support@77club.my with the subject line "Privacy Rights Request". We will process your request within 14 business days.

8Data Retention Period

77 Club retains your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required under Malaysian law. The following are our data retention guidelines:

• Active account data: For the duration of your active account plus 7 years after account closure (Malaysia AML requirements).
• Financial transaction records: Minimum 7 years in accordance with Malaysian financial regulatory requirements.
• Support communication logs: 2 years from the date of last interaction.
• Analytics cookie data: 90 days from the date of collection.
• Identity verification documents (KYC): 5 years after account closure, or as required by the relevant authorities.

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

9Children's & Minors' Privacy

77 Club Platform not directed to individuals under the age of 21. We do not knowingly collect any personal information from children or underage minors.

Should we find that personal information belonging to an individual under the age of 21 has been collected without proper age verification, we will promptly:

• Immediately suspending the account in question.
• Deleting all related data from our systems.
• Refunding any deposits made, subject to investigation.
• Reporting the case to the relevant authorities where necessary.

If you discover that a child or minor has registered on our platform, please contact us immediately at support@77club.my.

10Links to Third-Party Sites

The 77 Club platform may contain links to third-party websites or services in certain contexts. This Privacy Policy applies solely to the 77 Club platform and does not cover the privacy practices of external websites.

77 Club is not responsible for the content, privacy policies, or security practices of any third-party websites. We encourage you to read the privacy policy of each site you visit separately before providing them with any personal information.

11Privacy Policy Amendments

77 Club reserves the right to update or amend this Privacy Policy from time to time to reflect changes in operational practices, legal requirements, or service improvements. Whenever a significant amendment is made, we will:

• Updating the "Last Updated" date at the top of this page.
• Displaying a clear notice on the 77 Club platform homepage for at least 7 days.
• Sending notification emails to all active members when amendments are material in nature.

Your continued use of the 77 Club platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. It is your responsibility to review this page periodically.

12Contact Our Privacy Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please contact the 77 Club Data Protection Officer (DPO) through the following channels:

If you are not satisfied with our response, you have the right to lodge a complaint with Department of Personal Data Protection (JPDP) Malaysia which is responsible for overseeing PDPA compliance in this country.