Privacy Policy 78ace — Malaysian Player Data Protection

78ace ("we", "platform", or "78ace") is the data controller responsible for the processing of your personal data in connection with your use of our online entertainment platform at 78ace.best. We provide online casino services, Sports Betting, e-sports, virtual sports and related entertainment products to players in Malaysia.

This Privacy Policy is drafted in compliance with Personal Data Protection Act 2010 (PDPA) Malaysia and explains transparently how we manage your personal data from the moment you register through to after you stop using our platform. We have written this document in plain language because we believe you deserve to know clearly what happens to your information — not have it buried in small print.

By registering a 78ace account or using any of our services, you agree to the processing of your personal data as described in this Privacy Policy. If you do not agree, please do not proceed with registration or use of our platform.

78ace collects several categories of personal data depending on your activity on the platform. Below is a comprehensive list of the data we collect and how we obtain it:

78ace does not collect sensitive data such as health information, political views, religious beliefs, or biometric data unless specifically required by law and with your explicit consent.

Every piece of data we collect is used for a specific and legitimate purpose. Below is a full explanation of how 78ace uses your personal data:

78ace will not use your data for any purpose beyond those stated above without your prior consent. We do not engage in any undisclosed or silent use of your data for purposes that have not been made clear to you.

78ace does not sell, lend, or disclose your personal data to third parties for marketing purposes. However, in certain limited and legitimate circumstances, we may need to share your data with the following parties:

• Payment Providers: Required transaction information is shared with payment processors such as Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow and FPX to process your deposits and withdrawals. These providers are bound by strict confidentiality obligations.
• Game Providers: Your username and the minimum game data required are shared with game software providers (such as slots and Live Casino providers) to enable gameplay. They do not receive your full personal identification details.
• KYC & Identity Verification Services: For legally mandated identity verification, your information may be checked through accredited document verification services.
• Legal Authorities: 78ace will disclose your data to Malaysian authorities (PDRM, BNM or relevant bodies) when required by law, court order, or for legitimate criminal investigations. This includes compliance with anti-money laundering (AML) requirements.
• Professional Advisors: 78ace's lawyers, accountants, and auditors may access certain data within the scope of their professional duties, which are bound by legal confidentiality obligations.

78ace invests seriously in technical and organisational security measures to protect your personal data against unauthorised access, accidental disclosure, alteration, or destruction. The following are the security layers we employ:

• 256-bit SSL/TLS Encryption: All communications between your browser or app and 78ace servers are encrypted using the latest TLS protocol. No one can intercept or read your data in transit.
• Stored Data Encryption: Sensitive data stored in our databases, including financial information and identity documents, is encrypted at rest using AES-256 encryption.
• Role-Based Access Control: Only 78ace staff with a specific work-related need are granted access to player data, and only to the extent required for their role. All access is logged and regularly audited.
• Two-Factor Authentication (2FA): 78ace's internal systems require multi-factor authentication for all staff accessing sensitive player data.
• 24/7 Security Monitoring: Our intrusion detection and threat monitoring systems run around the clock to identify and respond to suspicious activity immediately.
• Regular Security Testing: Independent penetration testing and security reviews are conducted on a regular basis to identify and patch vulnerabilities before they can be exploited.

While we take all reasonable steps to protect your data, no security system is entirely foolproof. If you suspect that your account security has been compromised, please contact 78ace customer support immediately.

78ace retains your personal data for as long as your account is active and for as long as necessary to fulfil the purpose for which it was collected or to meet applicable legal obligations.

Once the retention period expires, your data will be securely deleted or anonymised so it can no longer be linked back to you. We do not retain data for longer than necessary — this is one of the core principles of our data management.

78ace uses cookies and similar tracking technologies to enhance your experience on the platform. Cookies are small text files stored on your device when you visit our website.

Types of cookies we use:

• 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: Collects information about how you use the platform — most visited pages, errors encountered, and similar data. All information is collected in aggregate and anonymised form.
• Functional Cookies: Remembering your preferences such as language, display settings, and login details for your convenience.
• Analytics Cookies: Helps us understand how players interact with the 78ace platform so we can make meaningful improvements.

You can manage your cookie settings through your web browser. However, disabling certain cookies may affect the functionality of some parts of the 78ace platform. For more detailed cookie management, refer to the "Privacy" or "Cookies" settings in your browser.

Under Malaysia's PDPA and the privacy principles we uphold, you have the following rights regarding your personal data held by 78ace:

• Right of Access: You have the right to request a copy of the personal data we hold about you. We will provide this information in a clear, readable format within 21 business days of receiving your request.
• Right of Rectification: If you find that the data we hold about you is inaccurate or out of date, you have the right to request a correction. Most basic information can be updated directly within your account.
• Right to Withdraw Consent: For data processing that relies on your consent (such as marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the validity of any processing that took place prior to it.
• Right to Object: You may object to the processing of your data for specific purposes, such as direct marketing.
• Right to Data Portability: You have the right to receive the data you have provided to us in a structured, machine-readable format.
• Right to Erasure: Under certain circumstances (where an account is closed and there is no legal obligation to retain the data), you may request the deletion of your data.

To exercise any of the rights above, please contact the 78ace Data Protection Officer by email at support@78ace.best with the subject line "Privacy Rights Request" or via live chat on our platform.

78ace services are exclusively for individuals aged 18 and above. We do not knowingly collect or process personal data of anyone under 18.

All prospective players are required to verify their age at registration. 78ace takes reasonable technical and procedural measures to prevent registration by underage individuals, including:

• Age verification during the account registration process
• A KYC process requiring verification of valid Malaysian identity documents
• Ongoing monitoring to detect accounts that may belong to individuals who are underage

If we discover that we have inadvertently collected personal data from an individual under the age of 18, we will immediately close the account in question and delete all associated data. If you are a parent or guardian who believes your underage child has registered a 78ace account, please contact us immediately at support@78ace.best.

As a responsible financial platform, 78ace is required by Malaysian law to comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements. This means we need to collect and verify certain information about you in the following situations:

• First withdrawal exceeding RM1,000
• Cumulative withdrawal amount exceeds RM5,000
• When our systems detect unusual transaction patterns
• Requests from competent authorities

Documents that may be requested during the KYC process include:

• A valid copy of your MyKad or Malaysian passport
• Proof of address (utility bill or bank statement dated within the last 3 months)
• Bank statements or e-wallet account screenshots as proof of ownership of the payment method

All documents you submit for the KYC process are stored with full encryption and can only be accessed by 78ace's trained compliance team. These documents are not shared with any party except where required by law. Full details on how we handle the KYC process can be found in the Terms & Conditions us.

78ace reserves the right to amend this Privacy Policy at any time to reflect changes in our practices, new legal requirements, or improvements we make to the platform. When we make material changes, we will:

• Updating the "Last Updated" date at the top of this document
• Displaying in-platform notifications on 78ace to registered users
• Sending notices via registered email for significant changes

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Continued use of the 78ace platform after any changes are published will be considered your acceptance of the updated Privacy Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the management of your personal data by 78ace, please contact us through any of the following channels:

• Email: support@78ace.best — use the subject line "Privacy Enquiry" or "Data Rights Request" to help us respond faster
• Live Chat: Available 24/7 on the 78ace platform — the fastest way to get urgent queries resolved
• Target Response Time: Privacy-related enquiries are typically responded to within 3 business days. Data rights requests (access, correction, erasure) are fulfilled within 21 business days in accordance with PDPA requirements.

If you are not satisfied with how 78ace has handled your personal data after contacting us, you have the right to lodge a complaint with Malaysian Communications and Multimedia Commission (MCMC) or the relevant body responsible for PDPA compliance in Malaysia.

We value every piece of feedback and every enquiry you send our way — it helps us do better in protecting the privacy of the 78ace player community across Malaysia.