Privacy Policy 739

1Information We Collect

739 collects several types of personal information to provide each member with a secure, seamless, and personalised experience. The information we collect falls into three main categories:

Information You Provide Directly:

• Full name as per identity card (MyKad) or passport.
• Date of birth for age verification (18 and above).
• A valid email address and mobile phone number.
• Bank account or digital wallet details for deposit and withdrawal purposes.
• Identity verification documents (KYC) such as a copy of your MyKad, passport, or proof of address.
• Language preferences and personal account settings.

Information Collected Automatically:

• Your device's IP address and network information.
• Browser type, operating system, and device version.
• Activity log data: pages visited, session duration, bets placed, and games played.
• Geolocation data at country or state level (not precise GPS location).
• Cookie information and device identifiers for session verification purposes.

Information from Trusted Third Parties:

• Identity verification data from an authorised KYC service provider.
• Fraud information or blacklists from responsible gambling industry bodies.
• Transaction data from payment processors such as FPX, DuitNow, and digital wallet providers.

Below is a summary of the data types and the purposes for which they are collected:

2How We Use Your Personal Data

739 uses the personal data collected solely for legitimate and necessary purposes to operate the platform safely and efficiently. We do not use your data beyond the scope stated in this Privacy Policy without first obtaining your additional consent.

The primary purposes for which your personal data is used include:

• Account Management — creation, verification, maintenance, and security of your 739 account.
• Financial transaction processing — verifying and processing deposits, withdrawals, and bonuses in accordance with registered payment details.
• Legal compliance — fulfilling obligations under the PDPA 2010, Anti-Money Laundering Act 2001, and applicable regulatory directives.
• Fraud Prevention — detecting and investigating suspicious activity, multiple account usage, money laundering, and platform abuse.
• Customer Support — handling enquiries, complaints, and support requests more efficiently and accurately.
• Platform Improvements — analysing usage patterns in aggregate (without identifying individuals) to improve user experience, platform performance, and product offerings.
• Marketing communications — sending promotions, exclusive offers, and the latest product updates to members who have given their consent — you may withdraw this consent at any time.
• Responsible Wagering — monitoring wagering patterns to identify signs of problem gambling and reaching out to members who may need support.

3Security & Data Protection

We continuously invest in robust data security infrastructure to ensure your personal information is always protected against unauthorized access, data breaches, and cyber threats. Key security measures we implement include:

• 256-bit SSL/TLS Encryption for all data transmitted between your browser and the 739 servers.
• Database-Level Data Encryption (AES-256) for sensitive information stored on our systems, including passwords (in bcrypt hash form) and payment details.
• Two-Factor Authentication (2FA) for account login and withdrawals, adding an extra layer of security.
• 24/7 security monitoring using an anomaly detection system that monitors login activity and suspicious transactions in real time.
• Role-based access control (RBAC) — 739 staff may only access the data necessary for their specific role.
• Regular Security Audits by independent third-party experts to identify and address any system vulnerabilities.
• Incident response plan — in the event of a data breach, 739 will notify the relevant authorities within 72 hours and promptly inform affected members.

4Data Sharing & Disclosure to Third Parties

739 values your trust. We do not sell, rent, or disclose your personal data to third parties for their own marketing or commercial purposes. However, there are limited situations where data sharing is necessary to operate our platform:

Authorised Service Providers: We work with carefully selected third-party service providers, including payment processors (FPX, DuitNow), KYC service providers, cloud infrastructure providers, and transactional email services. All providers are bound by strict confidentiality agreements and may only use your data for specific, limited purposes.

Legal & Regulatory Requirements: 739 may be required to disclose your personal data to government authorities, law enforcement bodies, or regulatory agencies if mandated by Malaysian law or a valid court order. This includes compliance with the Anti-Money Laundering Act 2001 and directives from Bank Negara Malaysia.

Business Transfer: In the event of a merger, acquisition, or sale of 739's assets, your personal data may be transferred to the new entity involved. You will be notified in advance, and the new entity will be bound by this Privacy Policy or an equivalent one.

All third parties that receive data from 739 are required to maintain data protection standards equal to or higher than those set out in this Privacy Policy. We conduct due diligence reviews on all new service providers before any data sharing takes place.

5Cookie & Tracking Technology Policy

739 uses cookies and similar tracking technologies to ensure the platform functions properly and to provide you with a better experience. Cookies are small text files stored in your browser when you visit our website.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login session verification, security, and language preferences. These cookies cannot be disabled.
• Performance & Analytics Cookies: Collecting aggregated, anonymized information about how you interact with our platform to help us improve website performance and navigation.
• Functional Cookies: Saving your preferences such as display settings, game preferences, and language for a more convenient experience.
• Security Cookies: Used to detect suspicious login attempts and protect your account from unauthorised access.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling essential cookies may affect the functionality of the 739 platform and your login experience.

6Data Retention Period

739 retains your personal data for as long as necessary to fulfil the purposes stated in this Privacy Policy or as required by applicable Malaysian law. Our general data retention principles are as follows:

• Active account data: Retained for the duration your account is active and for 7 years after account closure to meet audit and legal requirements.
• KYC documents: Retained for a minimum of 6 years after the date of the last transaction, in accordance with the Anti-Money Laundering Act 2001.
• Financial transaction records: Retained for 7 years for financial audit and tax compliance purposes.
• Customer support communication logs: Retained for 2 years for reference and service improvement purposes.
• Technical activity log data: Retained for 12 months before being automatically deleted or anonymised.
• Marketing data: Retained until you withdraw your consent or request deletion.

Once the retention period expires, your personal data will be securely deleted or fully anonymised so that it can no longer be linked to your identity.

7Your Rights Under PDPA 2010

As a registered 739 member in Malaysia, you have the following rights under the Personal Data Protection Act 2010 (PDPA) and we are committed to facilitating the exercise of those rights:

• Right of Access: You have the right to obtain a copy of the personal data we hold about you. Access requests will be processed within 21 business days.
• Right of Rectification: If your personal data is inaccurate or outdated, you have the right to request a correction. You can update certain information directly in your account settings.
• Right to Withdraw Consent: You may withdraw consent to marketing data processing at any time without affecting the validity of processing carried out prior to withdrawal.
• Right of Erasure: In certain circumstances, you may request the deletion of your personal data. Such requests are subject to the legal retention obligations we are required to comply with.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: You have the right to receive your personal data in a machine-readable format for transfer to another service provider where applicable.

To exercise any of these rights, please contact our data protection team by email at [email protected] or via live chat within the platform. Please include your account number and sufficient information to allow us to process your request accurately.

8Children's Data Protection

The 739 platform is intended exclusively for individuals aged 18 and above. We do not knowingly collect or process personal data from individuals under the age of 18.

All account registrations go through a strict age verification process. Should we discover that personal data of an individual under 18 has been collected without our knowledge, the account will be closed immediately and all related data will be securely deleted within 30 days.

If you are a parent or guardian and believe your child has registered an account at 739, please contact us immediately at [email protected]. We will take immediate action to close the account and remove the relevant data.

9Amendments to the Privacy Policy

739 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or improvements in data protection. Any material amendments will be communicated to you via:

• An email notification will be sent to your registered email address at least 14 days before any amendments take effect.
• A clear notice on the 739 platform homepage and within your account dashboard.
• In-app notifications on the 739 mobile app if you use our app.

The "Last Updated" date at the top of this document will be updated whenever changes are made. We encourage you to review this Privacy Policy periodically. Continued use of the 739 platform after any amendment takes effect will be considered acceptance of the new terms.

10Contact Our Data Protection Officer

739 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and ensuring the data rights of our members are fully respected.

For any enquiries, concerns, or requests relating to your privacy and personal data, you may reach us via:

• Privacy Email: [email protected] — for data access, correction, or deletion requests.
• General Support Email: [email protected] — for general enquiries related to your account and the platform.
• Live Chat: Available 24/7 within the 739 platform for immediate assistance.

We are committed to responding to all privacy-related enquiries within 5 business days. For complex issues or those requiring in-depth investigation, we will provide a status update within that period and deliver a final resolution within 21 business days.