Privacy Policy

Introduction

This Privacy Policy ("Policy") is issued by lpkk77 ("the Company", "we", "us", "our"), the operator of the online gaming platform accessible at https://lpkk77.cam and all associated mobile interfaces and sub-domains (collectively, "the Platform"). This Policy applies to all users who access, register on, or otherwise interact with the Platform ("you", "the User").

We are committed to processing your personal data responsibly, lawfully, and transparently. This Policy describes in clear terms the categories of personal data we collect, the purposes for which we process it, the parties with whom we may share it, the safeguards we employ to protect it, and the rights available to you under applicable data protection legislation.

By registering an account or using the Platform in any capacity, you acknowledge that you have read, understood, and consent to the data processing practices described in this Policy. If you do not agree to this Policy, you must not use the Platform. This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform generally.

Definitions

For the purposes of this Policy, the following definitions apply:

Data We Collect

lpkk77 collects personal data that is necessary for the provision of its services, compliance with legal obligations, and the security of the Platform. The categories of personal data we collect include:

How We Collect Data

Personal data is collected through the following channels and methods:

• Direct submission: When you complete the account registration form, submit KYC documents, make a deposit or withdrawal request, contact support, or respond to surveys or promotions.
• Automated collection: Technical and usage data is automatically collected when you access the Platform, through server logs, session tracking, and analytics tools. This data collection is necessary for Platform performance, security monitoring, and fraud detection.
• Payment processor data: When you initiate a payment via Touch 'n Go eWallet, DuitNow, FPX, or any other accepted payment method, the relevant payment service provider transmits transaction confirmation data to lpkk77 for the purpose of crediting your account and maintaining financial records.
• Third-party verification services: Where third-party identity verification or age verification vendors are used to support KYC processes, data may be shared with and received from those vendors for verification purposes only.
• Cookies and tracking technologies: As described further in Section 10 of this Policy.

Data Processing & Use

lpkk77 processes your personal data for the following purposes:

• Account creation and management: To establish your user account, verify your identity, maintain accurate account records, and provide access to the Platform's services.
• Payment processing: To process deposits and withdrawals in MYR via your chosen payment method, maintain transaction records, and reconcile financial accounts.
• Identity verification (KYC): To verify that you are who you claim to be, that you meet the minimum age requirement of 21 years, and to comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, money laundering, and other illegal or prohibited activities on the Platform.
• Customer support: To respond to your enquiries, resolve disputes, process complaints, and maintain a record of your communications with our support team.
• Legal compliance: To fulfil obligations under applicable laws and regulations, respond to lawful requests from regulatory or law enforcement authorities, and maintain required records.
• Platform improvement: To analyse usage patterns, identify technical issues, improve user experience, and develop new features or services on the Platform.
• Responsible gambling: To monitor betting patterns that may indicate problem gambling behaviour, enforce self-exclusion requests, and administer deposit and loss limits in accordance with your preferences.
• Service communications: To send you transactional emails, account notifications, security alerts, and — where you have opted in — promotional communications about bonuses, offers, and Platform updates.

Legal Basis for Processing

lpkk77 processes personal data only where there is a lawful basis to do so. The legal bases on which we rely are as follows:

• Contractual necessity: Processing required to establish and manage your account, process transactions, and provide the services you have requested under our Terms & Conditions.
• Legal obligation: Processing necessary to comply with applicable legal and regulatory requirements, including AML legislation, KYC mandates, tax reporting obligations, and responses to lawful authority requests.
• Legitimate interests: Processing carried out in our legitimate business interests — including fraud detection, security monitoring, platform analytics, and responsible gambling enforcement — where those interests are not overridden by your rights and interests.
• Consent: Where processing is based on your consent (for example, marketing communications or non-essential cookies), we will obtain your explicit consent before processing and you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Data Sharing & Disclosure

lpkk77 does not sell, rent, or trade your personal data to third parties for marketing or commercial purposes. We may disclose your personal data to the following categories of recipients strictly on a need-to-know basis:

• Payment service providers: Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX operators, Maybank, CIMB, Public Bank, Hong Leong Bank, and cryptocurrency exchange/wallet service providers — to facilitate your requested transactions. These providers operate under their own privacy and security standards.
• KYC and identity verification vendors: Third-party services engaged to assist with identity document verification, age verification, and AML screening. These vendors process data only as instructed by lpkk77 and under binding data processing agreements.
• IT and infrastructure providers: Cloud hosting, server management, and cybersecurity service providers who maintain the infrastructure on which the Platform operates. Access is restricted to what is necessary for their service function.
• Regulatory and law enforcement authorities: Where we are required by law or legal process to disclose data to regulators, courts, law enforcement agencies, or other governmental bodies. We will, where legally permissible, notify you of such disclosure.
• Professional advisers: Legal counsel, auditors, and accountants engaged by lpkk77, who are bound by confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of lpkk77's business, your personal data may be transferred to the acquiring entity as part of the transaction assets. You will be notified of any such transfer and your rights under this Policy will be maintained.

Data Retention

lpkk77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention principles apply:

• Active account data: Personal data associated with an active user account is retained for the duration of the account's existence.
• Financial transaction records: Transaction records (deposit and withdrawal history) are retained for a minimum of seven (7) years from the date of each transaction to satisfy financial regulatory and audit requirements.
• KYC documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the end of the business relationship, in compliance with AML obligations.
• Support communications: Records of customer support interactions are retained for three (3) years from the date of the last interaction.
• Closed account data: Following account closure, residual personal data is retained for a maximum of seven (7) years for legal compliance purposes, after which it is securely deleted or anonymised.

Where personal data is no longer needed and no legal obligation requires retention, it is securely deleted using industry-standard data destruction protocols that render recovery impossible.

Data Security

lpkk77 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security programme includes, but is not limited to:

• Transport security: All data transmitted between your device and the Platform is encrypted using 256-bit SSL/TLS encryption. The padlock icon in your browser confirms an active secure connection at all times.
• Data-at-rest encryption: Personal data and financial records stored on our servers are encrypted at rest using AES-256 or equivalent standards.
• Access controls: Access to personal data within lpkk77 is restricted to authorised personnel on a strict need-to-know basis. All staff access is logged and subject to periodic review.
• Firewall and intrusion detection: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and continuous security monitoring to identify and respond to threats in real time.
• Penetration testing: The Platform undergoes periodic security assessments and penetration testing by independent cybersecurity professionals.
• Incident response: In the event of a data security incident that affects your personal data, lpkk77 will notify affected users and relevant authorities in accordance with applicable breach notification requirements.

Cookies & Tracking Technologies

lpkk77 uses cookies and similar tracking technologies to operate the Platform, improve user experience, and analyse platform usage. The categories of cookies we use are as follows:

• Essential cookies: Strictly necessary for the Platform to function correctly. These include session management cookies, authentication tokens, and security cookies. These cannot be disabled without impairing Platform functionality.
• Functional cookies: Enable the Platform to remember your preferences, such as language settings, display configurations, and responsible gambling limit preferences, to provide a more personalised experience.
• Analytical cookies: Used to understand how users interact with the Platform — pages visited, time spent, error occurrences, and navigation paths. This data is used in aggregated, anonymised form to improve Platform performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection, multi-account identification, and session integrity verification.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the Platform but may limit certain personalisation features. We do not use third-party advertising cookies or share cookie data with advertisers.

International Data Transfers

In providing its services, lpkk77 may transfer your personal data to servers or processors located outside of Malaysia. Where such transfers occur, we take all necessary steps to ensure that your data receives an equivalent level of protection as it would within Malaysia, including:

• Executing binding data processing agreements with all international processors that incorporate applicable data protection standards and obligations.
• Transferring data only to countries or service providers that maintain demonstrably adequate data protection frameworks.
• Implementing appropriate contractual, technical, and organisational safeguards for all cross-border data flows.

By using the Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside of Malaysia for the purposes described in this Policy, subject to the safeguards described above.

Minors & Age Restriction

The Platform is strictly intended for persons aged 21 years and above. lpkk77 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account and delete all collected data in accordance with our data retention procedures.

Where lpkk77 has reason to suspect that a registered user may be under the age of 21, the account will be suspended pending KYC age verification. Users must submit valid age-confirming identification before the account can be reinstated or any funds withdrawn.

If you are a parent or guardian and believe that your child under 21 has accessed or registered on the Platform, please contact us immediately at [email protected] so that we can take prompt remedial action.

Your Data Rights

Subject to applicable data protection legislation, you hold the following rights in relation to your personal data held by lpkk77. To exercise any of these rights, please contact our Data Protection team as described in Section 15.

Policy Amendments

lpkk77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. The "Last Updated" date at the top of this Policy will be revised to reflect the date of any material change.

For material changes that substantively affect your rights or the way we process your data, we will provide prominent notice on the Platform and, where appropriate, send notification to your registered email address. Your continued use of the Platform following any such notification constitutes your acknowledgement of the updated Policy.

We encourage you to review this Policy periodically to remain informed about how we protect your personal data. Archived versions of this Policy are available upon written request to our Data Protection team.

Contact & Data Enquiries

If you have any questions, concerns, or requests in relation to this Privacy Policy or the processing of your personal data, please contact our Data Protection team using the details below. We are committed to responding to all privacy-related enquiries within five (5) business days.

If you are not satisfied with our response to your privacy enquiry or data rights request, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. For Malaysian users, this may include making a report to the relevant regulatory body responsible for personal data protection in Malaysia.