Privacy Policy surg77 —
Our Commitment to Protecting Your Data

Surg77 ("we", "Platform") takes the privacy of every member extremely seriously. This Privacy Policy explains in detail how we collect, use, store, protect, and in certain circumstances share your personal information when you use the surg77.win platform and the surg77 mobile app.

This policy is drafted in accordance with the requirements of Malaysia's Personal Data Protection Act 2010 (PDPA) and reflects surg77's commitment to handling your data responsibly, transparently, and with integrity. We believe you have the right to know exactly what happens to your personal information — not in dense legal language, but in a clear and straightforward way.

If you have any questions about how we handle your personal data after reading this Policy, the surg77 customer support team is available to assist you 24 hours a day, 7 days a week.

Surg77 collects various types of personal data depending on how you interact with our platform. Below is a summary of the data types we collect and the purposes for which they are collected:

We only collect data that is strictly necessary for the stated purposes. surg77 does not collect sensitive information such as your medical data, religious beliefs, or political views. All data is collected directly from you during registration, platform use, or through communications with our support team.

The personal data we collect is used exclusively for the following purposes, which are directly related to delivering surg77's services to you:

• Account Management: Creates, verifies, and maintains your member account, including the required KYC process.
• Transaction Processing: Processes deposits, withdrawals, and all financial transactions securely and efficiently.
• Platform Security: Detects and prevents fraud, money laundering, unauthorised access, and other suspicious activities that could compromise your account security.
• Customer Support: Addresses enquiries, resolves complaints, and provides the technical assistance you need.
• Service Communications: Sends important account notifications, security updates, and transaction information.
• Platform Improvements: Analyses usage patterns on an aggregate basis (not individually) to improve the user experience and develop new features.
• Promotions & Offers: With your consent, to send information about promotions, bonuses, and exclusive offers relevant to your interests.
• Legal Compliance: Fulfils reporting and compliance obligations under applicable Malaysian law.

Surg77 will not use your personal data for any purpose other than those stated above without first obtaining your explicit consent.

Surg77 does not sell or rent your personal data to any third party. However, in the course of operating the platform, we may share certain data with a limited set of third-party categories as follows:

• Payment Service Providers: Payment processors and financial institutions that help us securely process your deposits and withdrawals.
• Game Software Providers: Licensed gaming companies that provide slots, live casino, fish shooting, and other games on the surg77 platform.
• Cloud Service Providers: An internationally certified cloud computing company that stores and processes our platform data in a secure, audited environment.
• Statutory Authorities: Government agencies or authorised law enforcement bodies when required by law or court order.

All third parties working with surg77 are bound by strict confidentiality agreements and are only permitted to use your data for the specified purposes. We ensure every third-party partner complies with data protection standards equivalent to our own.

Surg77 continuously invests in comprehensive data security infrastructure to ensure your personal information is always protected against unauthorised access, loss, misuse, or accidental disclosure.

Key security measures we implement include:

• Data Encryption: All sensitive data is encrypted using AES-256 standards during storage and SSL/TLS during transmission.
• Two-Factor Authentication (2FA): An additional security layer is available for all member accounts to prevent unauthorised access even if your password is compromised.
• 24/7 Monitoring: An automated threat detection system continuously monitors platform activity and issues immediate alerts whenever suspicious activity patterns are detected.
• Internal Access Controls: Only authorised surg77 staff with a legitimate job requirement may access member personal data, and all access is logged for audit purposes.
• Regular Security Testing: The surg77 platform undergoes regular penetration testing and vulnerability assessments conducted by qualified independent third parties.

While we take all reasonable steps to protect your data, no security system can be guaranteed to be 100% foolproof. We therefore encourage you to play your part in securing your account by using a strong password, enabling 2FA, and never sharing your login credentials with anyone.

Surg77 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

The types of cookies we use are as follows:

• Essential Cookies: Required for core platform functions such as login, game sessions, and security. These cookies cannot be disabled as they ensure the platform operates correctly.
• Preference Cookies: Saves your preferences such as language, display theme, and other personal settings to deliver a more comfortable experience on your next visit.
• Analytics Cookies: Helps us understand how members use the surg77 platform so we can make meaningful improvements. Data collected is aggregated and anonymised.
• Security Cookies: Helps detect fraudulent activity and protects your account from unauthorised access.

You can manage your cookie settings through your web browser at any time. However, disabling certain cookies may affect the functionality and user experience of the surg77 platform.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have certain rights regarding the personal data held by surg77. surg77 fully respects and facilitates the exercise of these rights:

To exercise any of the above rights, please contact the surg77 privacy team by email at [email protected] or via our platform's live chat. We will process your request within 30 business days. In some cases, we may need to verify your identity before fulfilling the request to ensure the security of your data.

Surg77 retains your personal data only for as long as it is needed for the purposes stated in this Privacy Policy or to meet applicable legal requirements.

Data retention periods vary by data type:

• Active Account Data: Retained for the duration your account is active plus 7 years after account closure for anti-money laundering (AML) compliance purposes.
• Transaction Records: Retained for 7 years as required by Malaysian financial legislation.
• Communication Logs: Retained for 2 years for dispute resolution and service quality monitoring purposes.
• Analytics Data: Aggregated, anonymised data is retained indefinitely as it can no longer be linked to any specific individual.
• KYC Data: Retained for 5 years from the date of last verification or account closure, whichever is later.

Once the retention period has expired and no legal requirement mandates continued storage, your data will be securely deleted or permanently anonymised in accordance with surg77's standard data management procedures.

The surg77 platform is not intended for individuals under the age of 18. surg77 does not knowingly collect personal data from children or minors below the stipulated age limit.

If you believe someone under the age of 18 has registered an account on the surg77 platform, please contact us immediately. Once verified, we will take prompt action to close the account and permanently delete all associated data.

The surg77 platform may contain links to third-party websites or services — such as game provider pages or payment partners — that operate independently from surg77.

This Privacy Policy applies exclusively to the surg77 platform. surg77 is not responsible for the privacy practices or content of third-party websites. We encourage you to read the privacy policy of each third-party website you visit separately before providing any personal information to them.

Surg77 reserves the right to amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or improvements in how we protect your data. Any material amendments will be communicated to you via a prominent notice on the surg77 website or by email to your registered address.

The "Updated" date at the top of this page will always reflect the effective date of the latest version of the Privacy Policy. Your continued use of the surg77 platform after any amendments take effect constitutes your acceptance of the revised Policy. If you do not agree with the amendments, please discontinue use of the platform and contact us to close your account.

For any enquiries, concerns, or requests relating to this Privacy Policy or how we handle your personal data, please contact the surg77 Data Privacy Officer (DPO) through the following channels:

• Privacy Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 on surg77.win

We are committed to responding to all privacy-related enquiries within 5 business days. For formal data rights requests — such as access, correction, or deletion — our maximum response time is 30 business days from the date the request is received.

If you are dissatisfied with how we handle your privacy complaint, you have the right to lodge a complaint with Malaysia's Department of Personal Data Protection or the relevant supervisory authority under applicable law.