Surga33 Privacy Policy – Player Data and Information Protection

Surga33 is an online entertainment and gaming platform serving Malaysian players. We understand how important privacy is to every user, especially on a platform that involves financial transactions and sensitive personal data.

This Privacy Policy ("Policy") clearly explains how we handle the information you provide when registering, using the platform, making financial transactions, or interacting with our support team. We have written this document in plain language because we want you to genuinely understand your rights — not just have a lengthy document that nobody reads.

This Policy applies to all surga33 members, unregistered website visitors, and anyone who interacts with our platform in any capacity. By continuing to use the surga33 platform after this Policy's effective date, you confirm your acceptance of the terms stated herein.

Surga33 collects your personal data through various touchpoints as you interact with the platform. Below are the main categories of data we collect and the reasons for doing so:

Data You Provide Directly

This includes all information you enter during account registration, the KYC process, profile updates, and interactions with customer support. You are responsible for ensuring all information provided is accurate and up to date.

Automatically Collected Data

When you use the surga33 platform, we automatically collect certain technical data to ensure platform security and performance. This includes your IP address, device information, and activity patterns on the platform.

All data collected by Surga33 is used for legitimate and specific purposes. We do not use your data for anything unrelated to platform operations or outside your reasonable expectations. The primary purposes of data use are as follows:

• Account Management: Create and maintain your account, ensure secure login and enable access to all platform features.
• Financial Transaction Processing: Process deposits, withdrawals and all other financial activities related to your account securely and accurately.
• Identity Verification (KYC): Verify your identity to comply with anti-money laundering legal requirements and ensure the security of the platform ecosystem.
• Fraud Detection and Prevention: Monitor suspicious activity, protect your account from unauthorized access and ensure platform integrity.
• Customer Support: Provide relevant and efficient assistance when you contact our support team, and maintain records of interactions to improve service quality.
• Responsible Gambling: Analyze usage patterns to identify signs of problem gambling and offer appropriate assistance.
• Platform Communications: Send important account-related notices, terms updates and promotional information that you have agreed to receive.
• Platform Improvements: Analyze usage patterns in aggregate to understand how players interact with the platform and make meaningful improvements.

Surga33 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. This is a commitment we do not compromise on. However, there are limited situations where data sharing with trusted parties is required for platform operations:

Approved Service Providers

Surga33 works with carefully selected third parties to support platform operations, including payment service providers, licensed game suppliers, identity verification services, and technology infrastructure providers. All such partners are required to meet the same strict privacy standards as Surga33 and are bound by robust confidentiality agreements.

Legal and Regulatory Requirements

Surga33 may disclose data when required by applicable law, court order, or direction from a competent authority. In such cases, we will disclose only the minimum information necessary and will notify you where permitted by law.

Platform and User Protection

In cases where there is a threat to platform security or other users, surga33 may share necessary data with relevant parties to prevent or investigate criminal activity or fraud.

Surga33 continuously invests in security infrastructure to ensure your data is protected to the highest industry standards. The following are the key security measures we have in place:

• 256-bit SSL Encryption: All data transmitted between your device and Surga33's servers is protected by 256-bit SSL encryption — the same standard used by Malaysia's major banks.
• Stored Data Encryption: Sensitive data stored on our servers, including financial information and passwords, is encrypted using robust encryption algorithms.
• Strict Access Control: Only staff who require access for their work purposes may view user data. All access is logged and monitored.
• Two-Factor Authentication (2FA): Additional security features are available for your account to provide an extra layer of protection against unauthorised access.
• 24/7 Security Monitoring: Automated monitoring systems operate around the clock to detect and respond to security threats in real time.
• Regular Security Audits: The surga33 platform undergoes regular independent security audits and penetration testing to identify and address any vulnerabilities.

While we take all reasonable steps to protect your data, no system can guarantee absolute security. You also play an important role by keeping your password confidential and promptly reporting any suspicious activity to us.

The surga33 platform uses cookies and similar tracking technologies to enhance your experience and ensure the platform functions properly. The following are the types of cookies we use:

Essential Cookies

These cookies are required for the platform to function properly. They include session cookies that keep you logged in during an active session and security cookies that help detect suspicious activity. These cookies cannot be disabled without affecting core platform functionality.

Performance and Analytics Cookies

These cookies help us understand how players use the platform — which pages are visited most frequently, where users spend the most time and where technical issues may occur. This information is used in aggregate and is not used to identify you personally.

Functional Cookies

These cookies save your preferences such as language settings, display mode (light or dark) and other personal choices so you don't need to reconfigure the platform every time you log in.

You can manage your cookie preferences through your web browser settings. Please note that disabling certain cookies may affect the functionality of some parts of the surga33 platform.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have certain rights regarding the personal data we hold about you. surga33 fully respects these rights.

To exercise any of the above rights, please contact our privacy team through the available support channels. We may require identity verification before processing your request to ensure the security of your data.

Surga33 retains your personal data only for as long as necessary to fulfil the stated collection purpose or to comply with applicable legal requirements. Retention periods vary by data type:

• Active Account Data: Retained for the duration your account is active and for a reasonable period after account closure.
• Financial Transaction Records: Retained for at least seven (7) years to comply with applicable financial and tax legal requirements.
• KYC Documents: Retained in accordance with the minimum requirements of applicable anti-money laundering laws.
• Security Logs: Retained for a sufficient period to allow investigation of security incidents if required.
• Support Communication Records: Retained for a reasonable period to enable continuity of support and dispute resolution.

Once the retention period expires, your data will be securely deleted or anonymised using methods that ensure it cannot be recovered or re-identified.

Surga33 may update or amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or new platform features. The date of the most recent update will always be displayed at the top of this document.

When material changes are made to this Policy, we will notify you via:

• Clear notice on the surga33 website
• In-platform or mobile app notifications
• Email to your registered address for significant changes

We encourage you to review this Policy periodically. Continued use of the surga33 platform after any changes take effect constitutes your acceptance of the updated terms.

If you have any questions, concerns, or wish to exercise your rights regarding this Privacy Policy or how we handle your personal data, please contact us through the following channels:

Surga33 is committed to responding to all privacy-related enquiries within thirty (30) business days. For more complex requests, we may require additional time and will notify you accordingly.