Privacy Policy Cair77 — Data Protection & User Privacy

1Introduction & Policy Scope

This Privacy Policy explains how cair77 ("Platform", "we", "Company") collects, uses, stores and protects the personal information you provide when registering, accessing or using the services offered through cair77.vin and our official mobile app.

We understand that entrusting personal data to any online platform requires a high level of confidence. That is why cair77 building a data protection system that is robust, transparent, and aligned with Malaysia's Personal Data Protection Act 2010 (PDPA) — so you can play with peace of mind, without worrying about your privacy.

This policy applies to all registered members, prospective members, website visitors and any party that interacts with the platform cair77. By using our platform, you acknowledge that you have read and agreed to the terms in this Privacy Policy.

2Personal Data We Collect

cair77 collects various types of personal data depending on your interactions with our platform. Below is a full breakdown of the data that may be collected:

We also collect data automatically through cookies and similar tracking technologies when you browse our platform. This data is used solely to improve user experience and platform security.

3How We Use Your Data

Every piece of data collected by cair77 has a clear purpose. We do not process your data beyond what is necessary to operate our services. Below are the primary purposes for which your data is used:

• Account Management: Create, verify and securely maintain your member account on the platform cair77.
• Transaction Processing: Process all deposits, withdrawals and online financial transactions accurately and securely.
• Identity Verification (KYC): Ensure all members meet age and identity requirements in accordance with applicable regulations.
• Fraud Prevention: Detect and prevent fraud, money laundering and platform abuse.
• Customer Support: Respond to enquiries, resolve complaints and provide technical support to members.
• Personalize Your Experience: Recommend games, promotions and relevant content based on your interests and gameplay patterns.
• Marketing Communications: Send promotional information, exclusive offers and platform updates — only with your consent.
• Legal Compliance: Meet reporting obligations to the relevant authorities in accordance with applicable law.

4Data Sharing & Disclosure

cair77 does not sell, rent, or share your personal data with third parties for their own marketing purposes. However, there are certain situations where data sharing is necessary and legally permissible:

• Service Providers: We share necessary data with payment providers (such as DuitNow, FPX, Touch 'n Go), game providers and IT infrastructure providers that help us operate the platform. All third parties are bound by strict confidentiality agreements.
• Regulatory Authority: Data may be disclosed to government authorities or law enforcement when required by Malaysian law or court order.
• Fraud Prevention: Certain information may be shared with anti-fraud agencies or other platforms within a mutual protection network to detect illegal activity.
• Business Transfers: In the event of a merger, acquisition, or sale of company assets, user data may be transferred as part of that transaction. Members will be notified in advance.

In all of the above data sharing situations, cair77 ensures that recipient parties adhere to data protection standards equal to or higher than our own.

5Cookies & Tracking Technologies

Platform cair77 uses cookies and similar tracking technologies to enhance the user experience, analyze usage patterns, and maintain login session security. Below are the types of cookies we use:

• Strictly Necessary Cookies: Required for core platform functions such as session authentication, secure login and account security. These cookies cannot be disabled.
• Performance Cookies: Gather information about how you use the platform to help us improve speed, stability and overall functionality.
• Functional Cookies: Remember your preferences such as language, display settings and login details to deliver a more personalised experience.
• Analytics Cookies: Help us understand platform traffic, most visited pages and user navigation patterns on an aggregated and anonymised basis.

You can control or delete cookies through your web browser settings at any time. Please note that disabling certain cookies may affect the functionality or user experience of the platform cair77.

6Security & Data Protection

cair77 implements a range of technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Among the measures we have in place:

• Data in transit is encrypted using 256-bit TLS/SSL protocols for all communications between your device and our servers.
• Data at rest is encrypted for sensitive information such as passwords and financial details.
• 24/7 security monitoring with real-time threat detection systems.
• Role-based access control — only authorised staff may access sensitive data.
• Regular security audits by independent third parties to detect system vulnerabilities.
• A comprehensive incident response plan to address any data breach swiftly and effectively.

7Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and the internal policies of cair77, you have the following rights regarding your personal data:

To exercise any of the above rights, please contact our privacy team via email or live chat. We will process your request within 30 business days from the date of receipt.

8Data Retention Period

cair77 retains your personal data only for as long as necessary to fulfill the original purpose of collection or as required by law. Below are the general data retention guidelines:

• Active Account Data: Retained for as long as your account is active and you continue using the platform cair77.
• KYC & Identity Verification Data: Retained for a minimum of 7 years after account closure in line with anti-money laundering obligations.
• Financial Transaction Records: Retained for 7 years in accordance with applicable financial reporting and tax requirements in Malaysia.
• Security Logs: Retained for 12 months for security incident investigation purposes.
• Support Communication Records: Retained for 3 years for reference and service improvement purposes.

When the retention period expires, data will be securely deleted using methods that ensure it cannot be recovered. For data that must be retained for legal reasons, access will be restricted and use limited to permitted purposes only.

9Cross-Border Data Transfers

In the course of operating the platform cair77, your personal data may be processed or stored outside Malaysia, particularly in data centres located in the Asia Pacific region. All cross-border data transfers are carried out with adequate protection guarantees through:

• Data processing agreements that comply with international data protection standards.
• Use of recognised standard contractual clauses for data protection during transfers.
• Selection of cloud service providers with internationally recognised security certifications such as ISO 27001.

By using the platform cair77, you agree to this cross-border data transfer as described in this policy. We ensure that a level of protection equivalent to Malaysia's PDPA is maintained throughout our data processing chain.

10Child Protection & Age Restrictions

Platform cair77 is intended exclusively for individuals aged 18 years and above. We do not intentionally collect or process personal data of children under 18 years of age.

If we determine that personal data of a minor has been inadvertently collected, we will take immediate steps to:

• Close the relevant account immediately.
• Delete all personal data associated with the individual.
• Refund any deposited funds in accordance with the applicable procedures.

If you believe a child has registered an account on the platform cair77, please contact our support team immediately at [email protected] so that prompt action can be taken.

11Privacy Policy Amendments

cair77 reserves the right to update this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, or technologies used. The date of the last update will always be displayed at the top of this document.

For significant amendments, we will provide notification via:

• In-platform notification upon your next login.
• Email to your registered address at least 14 days before the amendment takes effect.
• A prominent announcement on the platform homepage cair77.

Continued use of the platform after an amendment takes effect will be considered acceptance of the updated policy. If you do not agree with the amendment, you have the right to close your account before the effective date.

12Contact Our Privacy Officer

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data by cair77, please contact us via the following channels:

• Privacy Email: [email protected] (please state "Privacy Inquiry" in the email subject line)
• Live Chat: Available 24/7 on the platform or mobile app cair77

Our privacy team will respond to your enquiry within 3 business days. For more complex requests such as data deletion or data export, the processing period is up to 30 business days.