Privacy Policy — Panen77

This Privacy Policy (hereinafter "Policy") is published by Panen77 (hereinafter "Panen77", "we", "us", or "the Company") and governs the collection, use, storage, disclosure, and protection of personal data submitted by or collected from all users (hereinafter "User", "Player", or "you") of the Panen77 website located at https://panen77.cam and all associated services (collectively, the "Platform").

Panen77 operates an online casino and sports betting platform principally serving players in Malaysia and international markets, with primary transactional support for Malaysian Ringgit (MYR). In the course of providing our services — including account registration, identity verification, payment processing, customer support, and marketing communications — we necessarily collect and process certain categories of personal data.

We are committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection laws and internationally recognised privacy principles. This Policy sets out in detail the nature of the data we hold, the purposes for which it is processed, and the rights you may exercise over that data at any time.

For the purposes of this Policy, the following terms carry the meanings defined below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial data, or online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, alteration, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means Panen77, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of Panen77 under a written contractual arrangement.
• "KYC Data" means identity and document verification data collected for Know Your Customer compliance purposes, including government-issued identification, proof of address, and source of funds documentation.
• "Cookies" means small text files placed on your device by the Platform to facilitate session management, analytics, and personalised experiences.
• "Consent" means freely given, specific, informed, and unambiguous agreement to the processing of your Personal Data for a stated purpose.
• "Sensitive Data" means categories of Personal Data warranting heightened protection, including financial account details and government identification numbers.

Panen77 collects the following categories of Personal Data, depending on the nature of your interaction with the Platform:

Panen77 collects Personal Data through the following methods:

• Direct submission: Data you actively provide during account registration, KYC verification, deposit and withdrawal requests, or customer support communications.
• Automated technical collection: Data collected automatically when you access the Platform, including IP address, device identifiers, browser configuration, and session activity logs — collected via server logs, session management systems, and analytics tools.
• Cookies and similar tracking technologies: Session cookies, persistent cookies, and pixel tags deployed on the Platform to manage authenticated sessions, optimise performance, and analyse usage patterns.
• Third-party payment processors: Transaction confirmation data and payment instrument validation data received from payment gateways following deposit or withdrawal processing.
• Identity verification partners: Where Panen77 uses third-party KYC service providers, verified identity confirmation data may be shared with us upon completion of the verification workflow.

Panen77 processes your Personal Data solely for the following legitimate purposes:

1. Account Management: To create, maintain, and administer your Panen77 account, verify your identity, and enable secure login.
2. Service Delivery: To provide access to gaming products, process bets and transactions, calculate winnings, and manage your account balance.
3. Payment Processing: To facilitate deposits and withdrawals through your chosen payment channels, including Malaysian banking networks, e-wallets (Touch 'n Go, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, DuitNow, FPX), and cryptocurrency networks.
4. KYC and Regulatory Compliance: To verify player age (minimum 21 years), identity, and source of funds in accordance with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
5. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, account takeovers, bonus abuse, and other security threats.
6. Customer Support: To respond to your queries, process complaints, and provide technical assistance through Live Chat, WhatsApp, WeChat, and email support channels.
7. Responsible Gambling: To monitor gaming behaviour and apply responsible gambling tools — including deposit limits, loss limits, cooling-off periods, and self-exclusion — where triggered by Player request or Platform monitoring thresholds.
8. Marketing Communications: To send promotional offers, bonus notifications, and platform updates to Users who have opted in to receive such communications. Marketing consent may be withdrawn at any time.
9. Platform Improvement: To analyse usage patterns, conduct internal research, and improve the performance, usability, and content of the Platform.
10. Legal Compliance: To fulfil any legal obligations imposed on Panen77 by applicable laws, regulatory directives, court orders, or law enforcement requests.

Panen77 relies on the following legal bases for processing your Personal Data:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws, including KYC/AML obligations, age verification requirements, and regulatory reporting duties.
• Legitimate interests: Processing necessary for Panen77's legitimate business interests — including fraud prevention, platform security, and service improvement — where these interests are not overridden by your fundamental privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — principally for direct marketing communications. You may withdraw consent at any time without detriment to your account or service access.

Panen77 does not sell, rent, or trade your Personal Data to any third party for commercial or marketing purposes. We may share your Personal Data with the following categories of recipients solely to the extent necessary for the stated purpose:

• Payment processors and financial institutions: To process your deposits and withdrawals via Malaysian banking networks, e-wallets, and cryptocurrency channels. These entities process data under their own privacy policies and applicable payment network security standards.
• Identity verification providers: KYC service providers engaged to verify your identity documents and confirm your age as part of our regulatory compliance obligations.
• Technology and infrastructure providers: Cloud hosting services, database management systems, cybersecurity tools, and platform analytics providers engaged to support Platform operations under data processing agreements.
• Regulatory authorities and law enforcement: Where required by applicable law, court order, or governmental directive, Panen77 may disclose Personal Data to relevant regulatory bodies or law enforcement agencies.
• Fraud prevention networks: Shared fraud intelligence databases used to detect and prevent fraudulent activity across the gaming industry.

All third-party Data Processors engaged by Panen77 are contractually required to maintain appropriate technical and organisational security measures and to process Personal Data only for the specified purposes, in accordance with Panen77's instructions.

Panen77 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 guidelines apply:

• Active account data: Retained for the duration of your account relationship with Panen77 and for a minimum of five (5) years following account closure, to satisfy regulatory and legal obligations.
• KYC documentation: Retained for a minimum of five (5) years following the last transaction on your account, in accordance with AML regulatory requirements.
• Financial transaction records: Retained for a minimum of five (5) years to comply with financial record-keeping obligations.
• Customer support communications: Retained for three (3) years from the date of the support interaction, or until resolution of any related dispute or complaint.
• Marketing preferences: Retained until you withdraw consent or request removal from marketing lists, at which point records of the opt-out are retained for compliance purposes.
• Technical and usage data: Retained in aggregated or anonymised form for analytical purposes indefinitely; identifiable technical data is deleted within twelve (12) months of collection.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with our data destruction procedures.

Panen77 uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies deployed are as follows:

• Strictly necessary cookies: Essential to the functioning of the Platform — these enable secure login, session management, and core transactional features. These cookies cannot be disabled without impairing Platform functionality.
• Performance and analytics cookies: Collect anonymised data on how users navigate the Platform — pages visited, session duration, error reports — to help us improve the Platform experience.
• Functionality cookies: Remember your language preferences, display settings, and account configuration to provide a more personalised experience on return visits.
• Marketing cookies: Track your interaction with promotional content on the Platform to enable relevant, targeted bonus and promotion notifications. These are deployed only with your consent.

You may manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the availability of Platform features. For further information on managing cookies in popular browsers, consult the help documentation provided by your browser provider.

Panen77 implements a comprehensive suite of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit TLS/SSL encryption applied to all data transmitted between your browser and Panen77's servers — the same encryption standard used by major financial institutions.
• Encrypted data storage for all sensitive Personal Data at rest, including KYC documentation, financial data, and authentication credentials.
• Access controls and least-privilege principles — Panen77 staff are granted access only to the Personal Data strictly necessary for their specific role, and all access is logged and audited.
• Multi-factor authentication (MFA) available for Player accounts and mandatory for internal administrative systems.
• Regular security assessments — periodic vulnerability scanning, penetration testing, and third-party security audits of Platform infrastructure.
• 24/7 fraud monitoring — automated systems and human analysts monitor transaction patterns around the clock to detect and respond to suspicious activity in real time.

Panen77 operates on an international basis and may transfer your Personal Data to countries outside your jurisdiction of residence for processing by our service providers, technology partners, or affiliated entities. Such transfers may occur to countries that do not provide a level of data protection equivalent to that in your home jurisdiction.

Where Personal Data is transferred internationally, Panen77 ensures that adequate safeguards are in place, including:

• Standard contractual clauses or equivalent data transfer agreements with recipient entities;
• Binding corporate rules where transfers occur within the Panen77 group of companies;
• Transfer to jurisdictions recognised by applicable law as providing adequate levels of data protection.

By using the Platform, you acknowledge and consent to the international transfer of your Personal Data subject to the safeguards described in this clause.

Subject to applicable data protection legislation, you hold the following rights in respect of your Personal Data held by Panen77. To exercise any right, submit a written request to our Data Privacy team via the contact details in Section 15.

Panen77 will respond to all verifiable data subject requests within thirty (30) calendar days of receipt, subject to identity verification. In complex cases, this period may be extended by a further thirty (30) days with written notice.

The Platform is strictly intended for persons aged 21 years and above. Panen77 does not knowingly collect Personal Data from individuals under 21 years of age. Our KYC verification process is designed to identify and exclude underage registrations.

If Panen77 becomes aware that Personal Data has been collected from a person under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that your minor child's data may have been collected in error, please contact us immediately using the details in Section 15.

Panen77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. Where amendments are material, we will notify registered Users via their registered email address or through a prominent Platform notice prior to the changes taking effect.

The current version of this Policy, together with its effective date, will always be accessible at https://panen77.cam/privacy-policy. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy. We encourage you to review this page periodically.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact Panen77's Data Privacy team through the following channels:

• Email (plain text — not a clickable link): [email protected]
• Subject line: Please include "Privacy Request" or "Data Subject Request" in your subject line to ensure prompt routing.
• Live Chat: Available 24/7 on the Platform — average response time under 5 minutes; select "Privacy & Data" from the support menu.
• Postal correspondence: Written requests may also be submitted; please contact Live Chat for the current correspondence address.

All data subject requests will be acknowledged within five (5) business days of receipt. Identity verification is required before any Personal Data is disclosed or modified in response to a request.