Privacy Policy Luck88 – Your Personal Data Protection

1. Introduction and Scope of This Policy

This Privacy Policy is published by luck88 ("we", "Platform") and applies to all users who access or register on the luck88 website (luck88.sh) and our mobile app. This policy explains our data processing practices and your rights as a data subject under applicable data protection laws.

We take data governance seriously. Every decision regarding how your data is used is made with your security and privacy as the top priority. The luck88 platform complies with Malaysia's Personal Data Protection Act 2010 (PDPA) and applicable international data protection standards.

By using the luck88 platform – whether via the website or app – you agree to the collection and use of information as described in this privacy policy. If you do not agree with the terms of this policy, please discontinue use of our platform.

2. Types of Personal Data We Collect

Luck88 collects the information necessary to provide a safe, fair, and seamless service. Below are the categories of data we collect and their purposes:

We only collect data that is strictly necessary for the stated purposes. This "data minimisation" principle means we do not collect excessive or irrelevant information beyond what is needed to operate the luck88 platform.

3. How We Use Your Data

The personal data we collect is used solely for the following purposes:

• Account management: Creating and maintaining your member account, including the registration process, login, and identity verification (KYC).
• Payment processing: Processing deposits and withdrawals securely through trusted payment providers such as FPX, DuitNow, and local digital wallets.
• Platform security: Detecting and preventing fraudulent activity, money laundering, multi-account usage, and other security threats that could affect other members.
• Customer Support: Providing effective technical support and customer service when you contact our support team.
• Platform communications: Sending important notifications related to your account, security, promotions you have opted into, and updates to terms and policies.
• Responsible gaming: Monitoring gaming patterns to identify potential gambling problems and offering appropriate self-control tools.
• Legal compliance: Fulfilling reporting obligations to relevant authorities when required by applicable law.
• Platform improvements: Analysing usage data in aggregated and anonymised form to improve the user experience and platform performance.

Luck88 will not use your data for any purpose other than those stated above without obtaining your prior consent. We do not make fully automated decisions that produce legal or similarly significant effects on you without human review.

4. Data Sharing and Disclosure

Luck88 does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. Your data is only shared in the following limited circumstances:

• Payment service provider: Minimum necessary data shared with FPX, DuitNow, Touch 'n Go, and bank providers to process your financial transactions.
• Identity verification provider: Identity information is shared with trusted third-party KYC services solely for document verification purposes.
• Technology service provider: Cloud computing infrastructure and data hosting providers that process data on our behalf, subject to strict confidentiality agreements.
• Legal Authority: When lawfully required by a Malaysian court, regulatory body, or law enforcement agency.
• Fraud prevention: Required information may be shared with industry fraud prevention networks to protect all platform members.

5. Data Security and Protection

Luck88 continuously invests in security infrastructure to ensure your personal data remains protected at all times. The technical and organisational measures we implement include:

• 256-bit SSL encryption: All data transmitted between your device and luck88 servers is protected with bank-grade encryption that cannot be intercepted by any third party.
• Data-at-rest encryption: Sensitive data stored in our databases is also protected with AES-256 encryption, ensuring data remains unreadable even in the event of a physical breach.
• Strict access control: Only authorised personnel with a legitimate business need may access members' personal data, and all access is logged and monitored.
• Real-time monitoring: An automated threat detection system monitors platform activity 24/7 to identify and respond swiftly to any anomalies.
• Regular security audits: Security audits and penetration testing are conducted periodically by independent security experts.
• Two-factor authentication (2FA): Members are encouraged to enable 2FA for an additional layer of account security.

While we take all reasonable precautions, no security system is one hundred percent impenetrable. In the event of any data breach that affects you, we are committed to notifying you and the relevant authorities within the timeframe required by law.

6. Cookies, Tracking and Related Technologies

Luck88 uses cookies and similar tracking technologies to enhance the user experience and platform security. The following types of cookies are used:

• Essential cookies: Required for core platform functions such as login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance cookies: Collecting information about how you use the platform (pages visited, time spent) to help us improve our services. This data is collected anonymously.
• Functional cookies: Saving your preferences such as language, display theme, and other settings so you do not need to reconfigure them every time you log in.
• Security cookies: Helping identify the devices you use to log in and detecting suspicious login attempts from unrecognised devices.

You can manage cookie settings through your web browser at any time. However, disabling essential cookies may affect your ability to use certain luck88 platform features correctly.

7. Data Retention Period

Luck88 retains your personal data only for as long as necessary to fulfil the purposes stated in this privacy policy, or as required by applicable law.

• Active account data: Retained for the duration your account remains active and for 5 years after account closure, to meet audit and legal compliance requirements.
• Financial transaction records: Retained for 7 years after each transaction in compliance with Malaysia's financial and tax legal requirements.
• Security logs: Retained for 2 years for the purposes of security incident investigation and fraud detection.
• Customer support data: Conversation records and support tickets are retained for 3 years for reference and service improvement purposes.
• Marketing data: If you choose to receive marketing communications, your data is retained until you withdraw that consent.

Once the retention period expires, your data will be securely deleted or anonymised so it can no longer be associated with you. Our deletion procedures ensure that data cannot be recovered once the deletion process is complete.

8. Your Rights as a Data Subject

As a luck88 member and data subject under Malaysia's PDPA, you have the following rights regarding your personal data:

To exercise any of the above rights, please contact our data protection team via the in-platform live chat or support email. We will process your request within 30 business days. In complex cases, this period may be extended by up to 60 days with prior notice to you.

9. Protection of Children's Data

The luck88 platform is strictly restricted to individuals aged 18 and above. We do not intentionally collect, store, or process any personal data from individuals under the age of 18.

If we discover that a child's data has been collected without our knowledge, we will take immediate steps to delete that data and close the account in question. Parents or guardians who have reason to believe their child has provided data to luck88 are requested to contact us immediately.

10. Changes to This Privacy Policy

Luck88 reserves the right to update this privacy policy from time to time to reflect changes in our practices, legal requirements, or the technologies we use. Any significant changes will be communicated to members via:

• In-platform or luck88 app notifications at least 14 days before the changes take effect.
• Notification emails sent to the email address registered on your account.
• Update the "Last Updated" date at the top of this document.

Continued use of the luck88 platform after the effective date of any changes will be considered acceptance of the updated privacy policy. We encourage you to review this page periodically to stay informed about how we handle your data.

11. Contact Our Data Protection Team

If you have any questions, concerns, or complaints regarding how luck88 handles your personal data, our data protection team is available to assist you 24 hours a day, 7 days a week.

• Live Chat: Fastest way – click the chat icon at the bottom corner of the luck88 platform or app.
• Email: Send your enquiry to [email protected] and we will respond within 24 business hours.
• Help Centre: Visit page FAQ us for answers to frequently asked questions about privacy and account security.

For formal complaints regarding data protection that cannot be resolved directly with us, you have the right to refer the matter to Malaysia's Department of Personal Data Protection (JPDP) or the relevant authority.