Privacy Policy of padu44

Introduction

padu44 ("we", "us", "our", "Company") is the operator of the online gaming and sports betting platform accessible at padu44.cam (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered Members, prospective users, and visitors.

This Privacy Policy ("Policy") sets out the basis on which personal data we collect from you, or that you provide to us, will be processed by padu44. This Policy is intended to meet the transparency obligations applicable to data controllers and to inform you of your rights as a data subject.

This Policy applies to all personal data collected in connection with your use of the padu44 Platform, including data collected through the website interface, account registration processes, financial transactions, customer support interactions, and any marketing or promotional communications.

By registering a Member Account on padu44, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein, to the extent that your consent is required as a legal basis for such processing.

Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings assigned below:

Personal Data We Collect

padu44 collects the following categories of personal data in connection with the operation of the Platform. We collect only data that serves a defined purpose as described in Section 5.

3.1 Identity and Registration Data. When you register an Account or complete KYC verification, we collect your full legal name, date of birth, nationality, residential address, government-issued identification number, and copies of identity documents such as your MyKad, passport, or other equivalent documentation acceptable for your jurisdiction.

3.2 Contact Data. This includes your email address, registered phone number, and any other contact details you provide when creating your account or interacting with our customer support team.

3.3 Financial Data. We collect information regarding your deposits, withdrawals, transaction history, and the payment methods associated with your account, including e-wallet account references (such as Touch 'n Go eWallet, Boost, GrabPay), bank account details used for FPX or direct bank transfers (Maybank, CIMB, Public Bank, Hong Leong), and cryptocurrency wallet addresses where applicable. We do not store full card numbers or banking login credentials.

3.4 Gaming and Betting Activity Data. We collect records of all bets placed, games played, wager amounts, game outcomes, session durations, and betting patterns on the Platform. This data is necessary for account management, dispute resolution, regulatory compliance, and responsible gambling monitoring.

3.5 Technical and Device Data. This includes your IP address, browser type and version, operating system, device identifiers, screen resolution, time zone, language settings, and referring URL. This data is collected automatically when you access the Platform.

3.6 Communications Data. Records of your interactions with our customer support team, including live chat transcripts, email correspondence, and any screenshots or attachments submitted in connection with a support query.

3.7 Responsible Gambling Data. If you utilise responsible gambling tools such as deposit limits, self-exclusion requests, or cooling-off periods, we maintain records of those elections to ensure they are properly enforced across your account and, where applicable, shared with gambling management programmes.

How We Collect Your Data

padu44 collects personal data through the following channels and mechanisms:

• Directly from you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, respond to a survey, or participate in a promotion.
• Automatically through your use of the Platform, including via cookies, web beacons, server logs, and similar tracking technologies as described in Section 10.
• From third-party payment processors such as FPX, DuitNow, and e-wallet providers, who communicate transaction status and reference information necessary to credit or debit your account.
• From identity verification services engaged to assist with KYC processes, who may provide verification outcomes, fraud risk scores, or document authentication results.
• From fraud prevention and security providers who assist padu44 in identifying suspicious activity, bonus abuse patterns, or potential violations of our Terms & Conditions.
• From publicly available sources such as corporate registries or sanction screening databases, where required for regulatory compliance purposes.

Purposes of Data Processing

padu44 processes your personal data for the following defined purposes. Each purpose is linked to a lawful basis as described in Section 6:

Legal Bases for Processing

padu44 processes your personal data on the following legal bases, depending on the purpose of processing:

• Contractual Necessity: Processing required to fulfil our obligations to you under the Member Agreement, including account creation, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering legislation, age verification requirements, and regulatory reporting obligations.
• Legitimate Interests: Processing carried out for our legitimate business interests — including fraud prevention, platform security, and improving our services — where those interests are not overridden by your privacy rights.
• Consent: Where we rely on your consent as the legal basis for processing — such as for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing. Withdrawal of consent does not affect processing conducted on other legal bases.

Third-Party Disclosure

padu44 does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. We may, however, share your personal data with the following categories of third parties for the purposes described:

7.1 Payment Service Providers. We share transaction reference data with payment processors — including operators of FPX, DuitNow, Maybank, CIMB, Public Bank, Hong Leong, Touch 'n Go eWallet, Boost, GrabPay, and cryptocurrency network providers — to facilitate deposits and withdrawals. These providers process data under their own privacy policies and are not data processors acting on our instruction.

7.2 Identity Verification Providers. We engage third-party KYC and age verification services who process identity documents on our behalf. These providers act as data processors under contractual data protection obligations and may not use your data for any purpose outside the verification service.

7.3 Fraud Prevention and Security Services. We may share technical and transactional data with fraud detection services and cybersecurity providers to protect the Platform and its Members from unauthorised access, fraud, and abuse.

7.4 Cloud Infrastructure and Hosting. Your data may be stored and processed on servers operated by our cloud infrastructure providers. These providers are data processors operating under strict contractual and security obligations.

7.5 Regulatory and Law Enforcement Bodies. We may be required to disclose personal data to regulators, law enforcement agencies, or other public authorities where required or permitted by applicable law, including in response to lawful requests, court orders, or regulatory investigations.

7.6 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or part of our business, your personal data may be transferred to the acquiring entity as part of the transaction, subject to equivalent privacy protections.

International Data Transfers

The padu44 Platform serves Members across Malaysia, and the majority of our data processing infrastructure is designed to operate within the regional context of Southeast Asia. However, some of our third-party service providers — including cloud infrastructure, identity verification, and fraud prevention providers — may process data in jurisdictions outside Malaysia.

Where such transfers occur, padu44 takes appropriate measures to ensure that your personal data receives an equivalent level of protection in the destination jurisdiction. This may include contractual clauses requiring recipient parties to maintain data protection standards consistent with applicable requirements, or reliance on recognised adequacy frameworks where available.

Data Retention

padu44 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, or as required by applicable law, regulatory obligations, or legitimate business interests such as dispute resolution and fraud prevention.

The following general retention guidelines apply:

• Active Account Data: Retained for the duration of your active membership on padu44 and for a period thereafter as required by applicable law and our internal policies.
• Financial Transaction Records: Retained for a minimum of seven (7) years from the date of the transaction, in compliance with applicable financial record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years following account closure or the completion of the business relationship, whichever is later, in compliance with anti-money laundering obligations.
• Customer Support Records: Retained for a period of three (3) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained until you withdraw consent or request deletion, plus a reasonable period thereafter to demonstrate compliance.
• Gaming Activity Logs: Retained for a minimum of three (3) years for responsible gambling monitoring, dispute resolution, and regulatory audit purposes.

Upon the expiry of applicable retention periods, personal data is securely deleted or anonymised such that it can no longer be attributed to an identified individual.

Cookies & Tracking Technologies

padu44 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are in use:

You may manage optional cookie preferences through your browser settings. Note that disabling certain optional cookies may affect Platform personalisation features. Strictly necessary and security cookies cannot be disabled without compromising the functional integrity of the Platform.

Your Rights as a Data Subject

As a Member of padu44, you hold the following rights in relation to your personal data. padu44 is committed to honouring these rights in a timely and transparent manner. To exercise any of the rights below, please contact us as described in Section 15.

padu44 will respond to all verifiable data subject requests within 30 days of receipt. In complex or high-volume cases, this period may be extended by a further 60 days, and we will notify you of such extension and its reasons.

Children & Minors

The padu44 Platform is strictly intended for adults aged21 years and above. We do not knowingly collect, use, or process personal data from individuals under the age of 21.

padu44 employs age verification measures at the point of registration, including collection of date of birth and — as part of KYC procedures — documentary verification of age. Where we discover or reasonably suspect that a Minor has registered an Account on the Platform, we will immediately suspend that account, void all associated bets and transactions, and contact the account holder to arrange for the return of any deposited funds in accordance with applicable law and our Terms & Conditions.

Parents and guardians who believe that a minor in their care has registered an account on padu44 should contact our support team immediately. We will act promptly on all such notifications.

Security Measures

padu44 implements and maintains a comprehensive information security programme designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include, but are not limited to:

• TLS 1.3 with 256-bit encryption for all data in transit between your device and our Platform servers.
• AES-256 encryption at rest for sensitive data including financial records, identity documents, and KYC files.
• Multi-factor authentication available for all Member accounts and enforced for administrative access to data systems by padu44 personnel.
• Role-based access controls ensuring that padu44 employees and contractors can only access personal data to the extent necessary for their specific job function.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Intrusion detection systems and 24/7 security monitoring of Platform infrastructure.
• Employee data protection training conducted regularly for all staff who handle Member personal data.

While we employ industry-leading security measures, no online system is completely immune from security risks. In the event of a personal data breach that poses a significant risk to your rights and freedoms, padu44 will notify affected individuals and relevant authorities in accordance with applicable notification obligations.

Amendments to This Policy

padu44 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where material changes are made to this Policy, we will provide reasonable advance notice to Members via the Platform's notification system or by email to your registered address. Your continued use of the Platform following the effective date of any updated Policy constitutes your acknowledgement of and agreement to the revised terms.

We encourage you to review this Policy periodically to remain informed of how padu44 handles your personal data. The most current version of this Policy is always accessible at padu44.cam/privacy-policy.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or padu44's processing of your personal data, you may contact our Data Protection team through the following channels:

Where your request cannot be resolved to your satisfaction through direct engagement with padu44, you retain the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. We encourage you to contact us in the first instance to give us the opportunity to address your concerns directly.