Privacy Policy 79z – Personal Data Protection for Malaysia Members

This Privacy Policy is an official document describing the personal data handling practices of 79z ("Platform", "kami"). This document applies to all members, prospective members and visitors accessing the 79z platform via the website 79z.wine or our mobile app. We encourage you to read this Privacy Policy carefully before using the platform, as it contains important information regarding your rights and how we manage your data.

79z is committed to being a transparent and responsible platform in every aspect of personal data processing. If you have any questions after reading this document, our team is ready to assist via live chat or support email.

In operating the 79z platform, we collect several categories of personal data depending on the type of interaction you have with our platform. This data collection is necessary to ensure we can deliver the best service while meeting applicable regulatory obligations.

We only collect data that is strictly necessary for the stated purposes. Our "data minimisation" principle ensures that no excessive data is collected without solid justification.

The personal data we collect is used for the following purposes, all of which have a solid legal basis and are consistent with your reasonable expectations as a 79z member:

• Account Management: Registering, verifying, and managing your member account, including KYC processes required by regulators.
• Transaction Processing: Processing all deposits and fund withdrawals securely via FPX, TNG eWallet, GrabPay, DuitNow, and other supported payment methods.
• Platform Security: Detecting and preventing fraud, hacking, money laundering, and any suspicious activity that could compromise the security of other members.
• Customer Support: Providing effective and relevant assistance whenever you contact our 24/7 support team via live chat or email.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and taking proactive measures in line with our responsible gaming policy.
• Marketing Communications: Sending promotional information, exclusive offers, and platform updates — only when you have given your consent to receive them.
• Legal Compliance: Meeting applicable legal and regulatory obligations, including anti-money laundering (AML) reporting requirements and tax obligations.
• Service Improvement: Analysing usage patterns in aggregate to improve the functionality, performance, and overall experience of the 79z platform.

Every personal data processing activity we carry out has a valid legal basis under Malaysia's Personal Data Protection Act 2010 (PDPA). The following outlines the basis we apply to each processing category:

• Contract Performance: Processing required to provide the 79z platform services you have requested, including account management and transaction processing.
• Legitimate Interest: Processing for security purposes, fraud prevention, and service improvement where our interests do not override your rights and freedoms.
• Legal Obligation: Processing required to comply with applicable laws, including KYC, AML, and regulatory reporting requirements.
• Consent: For marketing communications and non-mandatory data use, we will obtain your explicit consent in advance, and you are free to withdraw that consent at any time.

79z takes an extremely cautious approach to personal data sharing. We do not sell your personal data to any third party. However, there are limited situations where we need to share data with specific parties to enable the platform to function properly:

• Payment Providers: Required transaction information is shared with FPX, TNG eWallet, GrabPay, and DuitNow providers to securely process your financial transactions.
• Game Software Providers: Minimum technical data required is shared with licensed game providers to ensure game functions operate properly and fairly.
• KYC Service Provider: Identity verification documents are shared with authorized verification partners to carry out the KYC process as required by law.
• Regulatory Authority: Data required by law will be disclosed to the relevant government agencies or regulatory bodies when lawfully requested in accordance with applicable legislation.
• Professional Advisors: Lawyers, accountants, and auditors bound by professional confidentiality obligations may access the data necessary to provide advisory services to 79z.

All third parties who receive your personal data are required to comply with our Privacy Policy and data protection standards equivalent to or higher than our own. Binding data processing agreements are signed with every partner to ensure your data remains protected at all times.

Your personal data is stored on servers located in certified data centres meeting international security standards. 79z retains your personal data only for as long as it is needed for the stated purposes or as required by applicable law.

• Active Account Data: Retained throughout the period your account is active on the 79z platform, plus any additional period required by law.
• Financial Transaction Data: Retained for a minimum of seven (7) years after the transaction occurs, in line with Malaysian accounting and anti-money laundering legal requirements.
• KYC Records: Retained for five (5) years after the business relationship ends, or longer if required by law.
• Technical Logs: Security logs and access logs are retained for twelve (12) months for fraud detection and incident investigation purposes.
• Communication Data: Customer support communication records are retained for three (3) years for dispute resolution purposes.

Once the retention period expires, your personal data will be securely deleted or anonymized using methods that ensure the data cannot be recovered or re-identified.

79z invests seriously in security infrastructure to protect your personal data from unauthorized access, loss, misuse or disclosure. The technical and organizational measures we implement include:

• End-to-end data encryption using TLS 1.3 protocol and AES-256 encryption for all data stored and transmitted.
• Two-factor authentication (2FA) for all member accounts and internal staff access.
• Round-the-clock 24/7 security monitoring by a dedicated cybersecurity team.
• Penetration testing and security audits conducted regularly by certified independent experts.
• Role-based access control (RBAC) ensures that staff can only access the data required for their specific responsibilities.
• Mandatory data security training programme for all 79z staff who handle personal data.
• A comprehensive incident response plan to ensure any data breach is handled swiftly and effectively.

Under the Malaysia PDPA and the privacy principles we uphold, you have the following rights regarding your personal data held by 79z:

To exercise any of the above rights, please contact the 79z Privacy Officer via email at [email protected] or via our platform's live chat. We will process your request within 30 business days from the date of receipt of a complete request.

79z uses cookies and similar tracking technologies to enhance your user experience on our platform. Cookies are small text files stored on your device when you visit our website.

We use several categories of cookies:

• Essential Cookies: Required for core platform functions such as Login session verification and security. These cookies cannot be disabled.
• Performance Cookies: Helping us understand how visitors interact with the platform for continuous improvement. All data is collected in aggregate and anonymised form.
• Functional Cookies: Storing your preferences such as language, location, and display settings to deliver a more personalised experience.
• Security Cookies: Helping detect and prevent fraudulent activity, and protecting your account from unauthorized access.

You can manage cookie settings through your web browser settings. However, disabling certain cookies may affect the functionality of the 79z platform. For more information on managing cookies, please refer to your web browser's help documentation.

The 79z platform is strictly for individuals aged 18 and above. We do not intentionally collect or process personal data from individuals under the age of 18. Should we discover that a minor's personal data has been inadvertently collected, we will take immediate steps to delete that data and terminate the associated account.

79z reserves the right to update or amend this Privacy Policy at any time to reflect changes in our privacy practices, new legal requirements or relevant technological developments. When material changes occur, we will notify you via:

• In-platform notification upon your next login.
• Email to the address registered in your account for significant amendments.
• Update the "Last Updated" date at the top of this page.

Continued use of the 79z platform after any amendments to the Privacy Policy take effect will be considered acceptance of the latest version. We recommend you review this page periodically to stay informed of how we protect your personal data.

If you have any questions, concerns, or complaints regarding how 79z handles your personal data, you may reach our Privacy Officer through the following channels:

• Privacy Officer Email: [email protected] — please state "Privacy Inquiry" in your email subject line.
• Live Chat: Available 24/7 via the 79z platform — the fastest way to get an instant response.
• FAQ: Visit FAQ page us for answers to the most frequently asked privacy questions.

We are committed to addressing every privacy inquiry and complaint seriously and within a reasonable timeframe. If you are not satisfied with our response, you have the right to file a complaint with the Malaysia Personal Data Protection Department or the relevant authority.