War138 Privacy Policy – Malaysia Member Personal Data Protection

1 Introduction and Scope of This Privacy Policy

War138 ("we", "Platform") is committed to protecting the privacy of every member and user of our services. This Privacy Policy clearly explains how we collect, process, store, and protect your personal data when you use the website, mobile app, and all services offered by war138.

This policy applies to all users of the war138 platform in Malaysia, including registered members, users browsing the site without registering, and any individuals who interact with war138 through our customer support channels. This document is written in English to ensure clarity for our Malaysian users.

War138 operates in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA). We appoint an internal Data Protection Officer (DPO) responsible for ensuring that all our data handling practices comply with applicable law and international industry standards.

2 Types of Personal Data We Collect

War138 only collects data that is strictly necessary to provide a safe, responsible, and high-quality service. The following are the categories of data we collect:

We do not collect sensitive data such as medical information, political views, or religious affiliations unless a specific legal requirement obliges us to do so. All data collection is carried out transparently with your knowledge.

3 How war138 Uses Your Personal Data

War138 uses your personal data only for lawful, necessary, and relevant purposes in connection with the provision of our platform services. The primary purposes for which data is used are as follows:

• Account Management: Creating, verifying and managing your member account, including the KYC process required to comply with financial compliance laws.
• Transaction Processing: Handling deposits, withdrawals and all financial transactions securely and efficiently through your chosen payment method.
• Platform Security: Detecting and preventing fraud, suspicious activity, hacking and platform abuse that could compromise the security of other members.
• Customer Support: Providing effective assistance when you contact our support team, including verifying your identity before discussing account information.
• Service Communications: Sending important notifications related to your account, transactions, promotions you have subscribed to and policy changes that affect you.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and providing appropriate responsible gaming tools.
• Legal Compliance: Meet compliance, reporting and audit obligations required by relevant authorities.
• Platform Improvements: Analysing usage data in aggregated and anonymised form to improve the user experience, platform performance and to offer more relevant content.

4 Information Sharing and Disclosure

War138 does not sell, rent, or trade members' personal data to any third party for commercial purposes. However, there are limited situations where we may need to share certain information with other parties:

• Payment Service Providers: Required transaction information is shared with payment processors such as FPX, DuitNow and e-wallet providers to securely process deposits and withdrawals. These providers are bound by strict confidentiality agreements.
• Game Providers: Minimal technical information is shared with game software providers to ensure smooth gameplay and game integrity.
• Authorities and Law Enforcement: war138 will disclose required information to lawful authorities when mandated by law, court order, or regulatory compliance requirements.
• Fraud Prevention Services: Certain technical data may be shared with third-party fraud detection services to protect the security of all our members.
• Business Transfers: In the event of a merger, acquisition or sale of war138 assets, user data may be transferred as part of that transaction, subject to notification to members and the continuation of the same level of privacy protection.

All third parties receiving data from war138 are required to uphold data protection standards at least equivalent to our Privacy Policy and applicable Malaysian law.

5 Data Security and Protection

Protecting members' personal data is a top priority at war138. We implement multi-layered security measures covering technical, organisational and physical aspects:

• 256-bit SSL Encryption: All data communications between your device and war138's servers are encrypted using the latest TLS/SSL protocols, ensuring data cannot be intercepted in transit.
• Two-Factor Authentication (2FA): war138 supports two-factor authentication for all member accounts, adding an extra layer of security that protects your account even if your password is compromised.
• 24/7 Monitoring: Our automated monitoring systems and security team monitor the platform around the clock to detect and respond to any security threats.
• Internal Access Controls: Access to members' personal data within war138 is restricted on a need-to-know basis. All access is logged and regularly audited.
• Regular Security Testing: war138 conducts regular penetration testing and independent security audits to identify and address any system vulnerabilities.
• Data Backup: Data is regularly backed up to a secure, separate location to ensure swift data recovery in the event of any technical incident.

While we take all reasonable steps to protect your data, no security system can be guaranteed 100% safe. You also play an important role by using a strong password, not sharing your login credentials, and reporting any suspicious activity to us promptly.

6 Cookies, Tracking Technologies and Analytics

War138 uses cookies and similar tracking technologies to enhance the user experience, secure login sessions, and understand how our platform is used. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login sessions, language preferences, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collecting anonymous information about how pages are used to help us improve overall performance and user experience.
• Functional Cookies: Remembering your preferences and settings such as language, display layout and game preferences to provide a more personalised experience.
• Analytics Cookies: Used to understand platform usage patterns in aggregate. This analytics data does not contain personally identifiable information.

You can manage your cookie settings through your web browser. However, disabling all cookies may affect the functionality of certain parts of the war138 platform. For more information on managing cookies, refer to your browser's help documentation.

7 Your Rights Regarding Personal Data

As a data subject under Malaysia's PDPA and international best practices, you have the following rights regarding your personal data held by war138:

To exercise any of these rights, please contact the war138 customer support team. We will process your request within 14 business days. Please note that these rights are subject to certain legal exemptions, particularly in relation to financial compliance and crime prevention requirements.

8 Data Retention Period

War138 retains your personal data only for as long as necessary to fulfill the purposes stated in this Privacy Policy, or as required by applicable Malaysian law:

• Active Account Data: Retained for the duration your account is active and used to provide our services.
• KYC and Identity Verification Data: Retained for a minimum of 6 years after account closure, in accordance with Malaysia's financial compliance legal requirements.
• Financial Transaction Records: Retained for 7 years after each transaction in accordance with statutory accounting and audit requirements.
• Support Communication Logs: Retained for 3 years for reference and dispute resolution purposes.
• Technical Data and Security Logs: Retained for 12 months for security and incident investigation purposes.

Once the retention period expires, your data will be securely deleted or anonymised using methods that ensure it can no longer be linked back to you.

9 Children's and Underage User Privacy

War138 is an entertainment platform exclusively intended for individuals aged 18 years and above. We do not intentionally collect or process personal data from individuals under the age of 18.

If we discover that personal data of an individual under the age of 18 has been collected without our knowledge, we will take immediate steps to delete that data and close the account in question. Parents or guardians who suspect their child has registered at war138 are urged to contact our support team immediately.

War138 employs a range of technical measures and age verification processes to prevent minors from accessing our platform, including KYC checks that require an official identification document.

10 Changes to This Privacy Policy

War138 reserves the right to modify this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, or platform functionality. The "Updated" date at the top of this page reflects the date of the most recent revision.

For significant changes to this Privacy Policy, we will notify you via:

• In-platform notifications on war138 when you are logged in
• Email to the address registered in your account
• A prominent notice on the main page of our website

If you do not agree with the changes made to this Privacy Policy, you have the right to close your account and request deletion of your data in accordance with the rights stated in Section 7 above. Continued use of the platform after the changes take effect indicates your acceptance of the updated terms.

11 Contact Us About Privacy

If you have any questions, concerns or wish to exercise your privacy rights, please contact the war138 Data Protection Officer through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 directly from the war138 platform
• Response Time: We are committed to responding to all privacy-related enquiries within 2 business days

For more information on the overall platform usage rules, please refer to the Terms and Conditions us. To learn more about war138's commitment to responsible gaming, visit the Responsible Gaming us.

If you are not satisfied with how war138 has handled your privacy complaint, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia in accordance with the procedures set by that authority.