Club388 Privacy Policy – Data Protection & Malaysian Member Information Security

Club388 collects your personal information through several channels — directly when you register and use the platform, automatically through standard tracking technologies, and in some cases from legitimate third-party sources for verification purposes.

Information you provide directly:

• Registration information: full name, Malaysian phone number, email address and password
• Verification information: date of birth and other identity details required to confirm member eligibility
• Financial information: e-wallet account names (Touch 'n Go, GrabPay, Boost, ShopeePay), DuitNow account numbers or FPX account details (Maybank2u, CIMB Clicks) used for deposits and withdrawals in Malaysian Ringgit (MYR)
• Communication information: the content of messages you send to the Club388 support team
• Feedback and surveys: your responses to any questionnaires or satisfaction surveys we conduct

Information collected automatically:

• Technical data: IP address, device type (Android/iOS mobile, laptop), operating system, browser type and version
• Activity data: pages visited, time spent on the platform, navigation patterns and interactions with Club388 features
• Transaction data: records of all deposits, withdrawals and bets placed through your Club388 account
• Session data: login information, session duration and account activity history

Club388 uses the personal information collected for legitimate and necessary purposes to operate the platform effectively. Every use of your data has a sound legal basis — whether for the performance of a contract, legitimate interests, or legal obligations.

The primary purposes for which Club388 uses your data are as follows:

• Account Management: Creating, verifying and managing your Club388 account, including identity verification and membership eligibility
• Transaction Processing: Processing deposits in MYR via Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow and FPX, and promptly crediting winnings to your account
• Service Provision: Powering all Club388 products — including Sports Betting, Live Casino, e-sports, and Table Games — smoothly and seamlessly
• Communications: Sending important account-related information, transaction notifications, and policy updates via email or SMS.
• Security: Detecting and preventing fraud, money laundering, multi-account use, and any suspicious activity or violations of Club388's Terms & Conditions
• Marketing: Sending you information about Club388 promotions, bonuses and exclusive offers that may interest you — subject to your marketing preferences
• Platform Improvements: Analysing aggregated usage patterns to improve the design, performance, and user experience of the Club388 platform.
• Legal Compliance: Fulfilling legal and regulatory obligations applicable in Malaysia, including financial record-keeping requirements

Club388 does not sell, rent, or trade members' personal data to any third party for commercial gain. However, in the course of operating the platform, there are specific circumstances where we may need to share certain information with designated parties:

• Payment Service Providers: Payment gateways that process your MYR transactions include Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow, and FPX. This sharing is limited strictly to the information needed to process your transactions.
• Game Providers: Companies such as Microgaming, Playtech and NetEnt, which supply gaming software to Club388, may receive minimal technical data to ensure games run correctly
• IT Service Providers: Companies that provide server infrastructure, cybersecurity, and technical support services to Club388, subject to strict confidentiality agreements
• Law Enforcement Authorities: Malaysian authorities with the lawful power to request information in connection with criminal investigations or regulatory compliance
• Professional Advisors: Lawyers, accountants, or auditors providing professional services to Club388, subject to their professional confidentiality obligations

In all instances of data sharing, Club388 ensures that:

• Only the minimum information necessary for the relevant purpose is shared
• All recipient parties are bound by confidentiality agreements or equivalent legal obligations
• Data sharing is conducted through secure, encrypted channels.

Club388 continuously invests in robust technical and organisational security measures to protect your personal data from unauthorised access, loss, alteration, or accidental disclosure.

Key security measures we have implemented include:

• Data Encryption: All data in transit is protected using 256-bit TLS/SSL protocols. Sensitive data stored in databases is also encrypted using industry-standard algorithms.
• Access Control: Access to members' personal data is restricted to Club388 staff who require it to perform their duties, and all access is logged for audit purposes.
• Two-Factor Authentication: Club388's internal systems require two-factor authentication (2FA) for staff access to sensitive member data.
• Security Monitoring: Club388's IT security team monitors our systems in real time, 24/7, to detect and respond to any cyber threats or suspicious activity
• Penetration Testing: Club388 conducts regular security assessments, including independent penetration testing, to identify and address vulnerabilities before they can be exploited
• Data Backup: Member data is regularly backed up to secure, segregated locations to ensure service continuity

While Club388 takes all reasonable steps to protect your data, no security system is entirely foolproof. In the event of a data breach affecting your personal information, Club388 will notify you and the relevant authorities within the timeframe required under applicable Malaysian law.

Club388 uses cookies and similar tracking technologies to enhance your experience on our platform, maintain your login session and analyse usage patterns on an aggregate basis.

Types of cookies we use:

• Essential Cookies: Required for core platform functionality, such as maintaining your login session, remembering language preferences and processing transactions. These cookies cannot be disabled, as the platform will not function properly without them
• Performance Cookies: Collects information about how you use Club388 — the most frequently visited pages, load times and any errors encountered — to help us improve platform performance
• Functional Cookies: Remembering your preferences — such as display settings, frequently used betting limits, and other account configurations — to provide a more personalised experience
• Analytics Cookies: Used to understand overall platform usage patterns on an aggregated, anonymous basis, helping us make better-informed improvement decisions.

You can manage or block cookies through your web browser settings. However, blocking essential cookies may affect the functionality of the Club388 platform and your overall experience. All cookies we use comply with the privacy guidelines set out under applicable Malaysian law.

As a Club388 member residing in Malaysia, you have the following rights regarding your personal data, in accordance with the Personal Data Protection Act 2010 (PDPA) Malaysia:

• Right of Access: You have the right to know what personal data we hold about you and how it is being used. You may request a copy of your personal data by contacting the Club388 support team
• Right to Rectification: If any information we hold about you is inaccurate or out of date, you have the right to request a correction. We will update our records within a reasonable timeframe
• Right to Erasure: Under certain circumstances, you may request that we delete your personal data. However, we may need to retain some data to fulfil legal obligations or other legitimate purposes.
• Right to Restriction of Processing: You may request that we restrict how we use your data under certain circumstances, such as when you are disputing the accuracy of that data
• Right to Object: You have the right to object to the use of your data for direct marketing purposes at any time
• Data Portability: You may request a copy of your personal data in a machine-readable format for transfer to another service, to the extent that is technically practicable

Club388 retains your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required under applicable Malaysian law.

Our data retention guidelines are as follows:

• Active Account Data: Retained for as long as your account remains active and for such period thereafter as is necessary to resolve any outstanding claims or disputes
• Financial Transaction Records: Retained for a minimum of 7 years after a transaction takes place, in line with Malaysian legal requirements on financial records and anti-money laundering
• Security Activity Logs: Retained for 2 years for investigation purposes in the event of a security incident
• Support Communication Data: Interaction records with the Club388 support team are retained for 3 years.
• Closed Account Data: Upon account closure, we will delete or anonymise personal data that is no longer required within 90 days, except for data that must be retained for legal reasons.

Once the retention period expires, Club388 will securely delete or anonymise your personal data in accordance with approved disposal procedures, ensuring it cannot be recovered by any unauthorised party.

Club388 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our privacy practices, new legal requirements or improvements to platform operations.

When we make material changes to this Privacy Policy:

• The "Last Updated" date at the top of this page will be revised accordingly
• We will notify you via your registered email address or through in-platform notifications on Club388.
• For significant changes that fundamentally affect how we use your data, we may require your consent again before those changes take effect

We encourage you to review this Privacy Policy periodically. Continued use of the Club388 platform after any changes are published will be considered your acceptance of the updated Privacy Policy.

If you have any questions, concerns, or complaints about how Club388 handles your personal data, we encourage you to contact us directly in the first instance. Club388's privacy and support team is committed to addressing every enquiry thoroughly and within a reasonable timeframe.

How to reach the Club388 privacy team:

• Email: support@club388.my — use the subject line "Privacy Policy Enquiry" or "Personal Data Request"
• Live Chat: Via the live chat function within the Club388 platform, available 24 hours a day, 7 days a week
• Response Time: We aim to respond to all privacy-related enquiries within 3 business days and to resolve formal requests within 14 working days

If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia or the relevant authority under the Personal Data Protection Act 2010 (PDPA).

This Privacy Policy and all matters relating to it are governed by the laws of Malaysia. Any disputes arising shall be resolved in accordance with the jurisdiction of the relevant Malaysian courts.