Privacy Policy cly8 – User Personal Data Protection

1 Introduction and Scope of Privacy Policy

This Privacy Policy is issued by cly8 ("we", "the platform", or "cly8.org") to transparently explain how we manage your personal data when you use our online betting platform. We take the privacy of every member seriously and take every reasonable step to ensure your information remains secure.

This Privacy Policy applies to all users who access the cly8.org website, use our mobile app, contact our support team, or engage in any transaction through the cly8 platform. It covers all personal data we collect, whether directly from you or automatically through your use of the platform.

By registering an account or continuing to use the cly8 platform, you confirm that you have read and understood this Privacy Policy and agree to the way we manage your personal data as described herein. If you do not agree with any part of this Privacy Policy, you are advised not to use the cly8 platform.

2 Types of Information We Collect

Cly8 collects various types of information depending on how you interact with our platform. All data collection is carried out lawfully and transparently based on defined purposes. The following are the main categories of information we may collect:

a) Registration & Identity Information

• Full name as it appears on official identification documents
• Date of birth for age verification (must be 18 years or above)
• Active email address and mobile phone number
• Account password (stored in encrypted form)
• Current residential address and postcode

b) Identity Verification Information (KYC)

• Copy of Malaysian identity card (MyKad) or passport
• Proof of address documents such as a recent utility bill or bank statement
• Selfie photo for biometric identity verification when required

c) Financial & Transaction Information

• Bank account number or eWallet details used for deposits and withdrawals
• Complete transaction history including deposits, withdrawals, and wagering
• Credit or debit card information (stored as tokens, not full card numbers)

d) Usage & Technical Data

• IP address, web browser type, and device operating system
• Login data including access time, date, and location
• Gaming and wagering information including selected markets and gambling statistics
• Cookie and tracking technology data as described in Section 6

3 How We Use Your Personal Data

The personal data we collect is used solely for lawful and transparent purposes. cly8 processes your data on a solid legal basis — whether for the performance of a contract, legal compliance, the platform's legitimate interests, or with your explicit consent.

For marketing communications, you may withdraw your consent at any time by contacting our support team or through your account settings. Withdrawal of consent will not affect any data processing carried out prior to the withdrawal.

4 Information Sharing and Disclosure

Cly8 does not sell, rent, or share your personal data with third parties for their own marketing purposes. However, in certain defined situations, we may need to share your information with the parties listed below for service delivery and legal compliance purposes:

• Payment Service Providers: To process deposit and withdrawal transactions, transaction information will be shared with licensed and trusted payment gateway providers such as FPX, Touch 'n Go, GrabPay, and other related providers. All such providers are bound by strict confidentiality agreements.
• Game Providers: Required betting information will be shared with our Live Casino and sports game providers to ensure smooth and fair gameplay.
• Regulatory Authority: cly8 will disclose required information to the relevant authorities when mandated by law, court order, or official investigation. This includes financial regulatory bodies and law enforcement agencies.
• KYC Verification Services: Third-party providers responsible for verifying your identity documents to meet anti-money laundering (AML) legal requirements.
• Technology Providers: Companies providing technology infrastructure including cloud computing services, cybersecurity, and platform analytics. All such providers are subject to strict data protection agreements.

In all cases where data sharing is required, cly8 ensures that the receiving party complies with data protection standards equivalent to or higher than our own. We do not permit third parties to use your data for any purpose other than those stated.

5 Data Security Measures

The security of your personal data is cly8's highest priority. We continuously invest in the latest security technologies and procedures to ensure your data is always protected from unauthorized access, data breaches, and cyber threats.

Key security measures we have implemented include:

• 256-bit SSL Encryption: All communications between your browser and the cly8 server are encrypted using the latest TLS 1.3 protocol, ensuring that data transmitted cannot be intercepted or tampered with.
• Two-Factor Authentication (2FA): Users are encouraged to enable two-factor authentication to protect their account from unauthorized access even if their password is compromised.
• Continuous Security Monitoring: Our automated monitoring system operates 24/7 to detect and respond to any suspicious or unusual activity.
• Regular Penetration Testing: Independent security experts conduct regular penetration testing to identify and address system vulnerabilities before they can be exploited.
• Role-Based Access Control: Staff only have access to data required for their duties. All access is logged and monitored.
• Staff Security Training: All cly8 staff undergo regular cybersecurity awareness training to ensure best practices in data handling are consistently observed.

While we take all reasonable steps to protect your data, no system can guarantee absolute security. In the unlikely event of a security incident involving your data, cly8 will notify you within the timeframe required under applicable laws.

6 Cookies and Tracking Technologies

The cly8 platform uses cookies and similar tracking technologies to enhance user experience, analyze platform performance, and ensure certain features function correctly. Cookies are small text files stored in your web browser 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: Collect information on how visitors use the platform, including the most frequently visited pages and any error messages. This data is used in aggregate and does not identify individuals.
• Functional Cookies: Allow the platform to remember your preferences such as language, display settings, and login details for ease of use.
• Analytics Cookies: Help us understand platform usage patterns for continuous improvement. Analytics data is processed anonymously.

You can control or block cookies through your web browser settings. However, blocking essential cookies may affect your ability to use certain platform features. More information on managing cookies is available in your web browser's documentation.

7 User Rights Regarding Personal Data

As a cly8 platform user, you have various rights regarding your personal data protected under Malaysia's Personal Data Protection Act 2010 (PDPA). cly8 respects these rights and provides straightforward mechanisms for you to exercise them.

• Right of Access: You have the right to request a copy of the personal data we hold about you. Such requests will be processed within 21 business days.
• Right to Rectification: If you find that your personal data is inaccurate or outdated, you have the right to request a correction.
• Right to Restriction of Processing: In certain circumstances, you may request that we restrict how we process your data.
• Right to Withdraw Consent: You may withdraw consent for consent-based data processing at any time, without affecting the validity of any processing carried out prior to withdrawal.
• Right to Object: You have the right to object to the processing of your data for direct marketing purposes at any time.
• Right to Erasure: In certain circumstances, you may request the deletion of your personal data, subject to legal obligations that require us to retain it.

To exercise any of these rights, please contact the cly8 support team via live chat available 24/7 within the platform, or through our support email. Include your account identification details and the specifics of your request. We will verify your identity before processing any data-related request.

8 Data Retention & Deletion Policy

Cly8 retains your personal data only for as long as necessary to fulfill the purpose for which it was collected or to comply with applicable legal and regulatory requirements. Once the retention period expires, data will be securely deleted or anonymized.

General guidelines for data retention periods:

• Active Account Data: Retained for as long as your account is active and for an additional period after account closure to meet legal requirements.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with Malaysian financial and tax legal requirements.
• KYC Documents: Retained for a minimum of 5 years after the end of the business relationship in accordance with AML requirements.
• Support Communication Logs: Retained for 2 years for customer service reference.
• Technical Log Data: Retained for 90 days for security and technical troubleshooting purposes.
• Marketing Data: Retained until you withdraw consent or request deletion.

When data is no longer required, cly8 applies secure, irreversible deletion methods. For data stored on physical media, appropriate destruction procedures are followed to ensure the data cannot be retrieved by unauthorised parties.

9 Children's Privacy & Protection of Vulnerable Individuals

The cly8 platform is strictly for individuals aged 18 and above. We do not knowingly collect or process personal data of individuals under 18. Our registration process is designed to screen and reject users who do not meet this minimum age requirement.

If we become aware of or have reasonable grounds to believe that a child's personal data (under 18 years of age) has been collected without proper verification, we will take immediate steps to:

• Closing the relevant account immediately
• Deleting all personal data associated with the individual
• Returning any remaining account balance to the appropriate party
• Reporting the case to the relevant authorities if required

If you are a parent or guardian and discover that your underage child has registered an account on the cly8 platform, please contact our support team immediately via live chat or support email for prompt action.

10 Privacy Policy Updates & Contact Us

Cly8 reserves the right to amend, update, or replace this Privacy Policy from time to time to reflect changes in our practices, the latest legal requirements, or the expansion of our services. We will endeavor to notify you of any significant changes through a prominent notice on the platform or via email.

Each updated version of the Privacy Policy supersedes the previous version and takes effect immediately upon publication on our website. The latest effective date will be displayed at the top of this document. Continued use of the platform following any changes constitutes acceptance of the amended Privacy Policy.

For any inquiries, concerns, or requests regarding this Privacy Policy or how we manage your personal data, you may contact the cly8 Data Protection Officer (DPO) through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week directly within the cly8 platform
• Email: [email protected] (response within 1–3 business days)
• Language: We accept enquiries in Malay and English