Surga11 Privacy Policy – Protection of Your Personal Data

1Introduction and Scope of This Policy

This Privacy Policy ("Policy") describes how Surga11 ("we", "Platform") manages personal information with respect to the collection, use, storage, protection, and disclosure of personal data belonging to users ("you", "Member") of the Surga11 platform, including our official website and mobile app.

We are fully committed to protecting your privacy in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and applicable international standards. By registering an account or using surga11's services, you consent to the collection and use of your information as described in this Policy.

This Policy applies to all Surga11 platform users, including visitors browsing the website without registering an account, registered members actively using our services, and former members whose accounts have been closed but whose data is still retained for the period required by law.

2Personal Information We Collect

Surga11 only collects information required to provide services that are secure, efficient, and legally compliant. Below are the categories of data we collect:

2.1 Information You Provide Directly

• Identity Information: Full name, date of birth, identity card number (MyKad) or passport number, gender, and nationality.
• Contact Information: Email address, mobile number, and current residential address.
• Account Information: Username, password (stored in encrypted hash form), and security questions.
• KYC Verification Documents: Copies of identity card, passport, utility bills, bank statements, or other documents requested for the identity verification process.
• Financial Information: Bank account details, e-wallet account numbers, and records of deposit and withdrawal transactions.

2.2 Automatically Collected Information

• IP address, device type, operating system, and browser version used.
• General location data based on IP address (country and region).
• Platform activity logs include games played, session duration, and wagering records.
• Cookie and tracking technology data that helps us understand how you use the platform.
• Mobile device information such as Device ID when using the surga11 app.

3How We Use Your Data

Every piece of data we collect is used for a clear and legitimate purpose. Below is a summary table of data usage purposes at Surga11:

Surga11 will not use your data for any purpose other than those listed above without first obtaining your explicit consent. Should there be a need to use your data for a new purpose, we will notify you and obtain the necessary consent.

4Information Sharing and Disclosure

Surga11 does not sell, rent, or disclose your personal data to third parties for marketing purposes. However, under certain circumstances, we may share information with the following parties:

4.1 Third-Party Service Providers

We work with carefully selected service providers to support platform operations, including payment processors, cloud service providers, identity verification companies, and analytics platforms. All providers are bound by strict confidentiality agreements and may only process your data in accordance with surga11's instructions.

4.2 Legal and Regulatory Requirements

Surga11 may disclose your information to government authorities, regulatory bodies, or law enforcement agencies when required by law or court order, or when there is a need to investigate fraudulent activity or money laundering.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of company assets, user data may be transferred as part of the business assets. We will notify you in advance and ensure that equivalent privacy standards are upheld by the acquiring party.

5Data Security Measures

Protecting your personal data is surga11's highest priority. We implement multiple layers of technical and organizational security to ensure your data is always protected against unauthorized access, loss, or accidental disclosure.

• 128-bit SSL Encryption: All data transmitted between your device and the Surga11 servers is protected using the latest SSL/TLS encryption protocols.
• Stored Data Encryption: Sensitive information such as passwords and bank account numbers is stored in encrypted form using robust encryption algorithms.
• Two-Factor Authentication (2FA): An additional security layer is available for all user accounts to prevent unauthorized access.
• Continuous Monitoring: Our systems are monitored 24 hours a day to detect and respond to any security threats promptly.
• Internal Access Controls: Only authorised personnel may access user personal data, and every access is logged and audited on a regular basis.
• Regular Security Testing: Our platform is regularly subject to penetration testing and security audits conducted by independent experts.

While we take all reasonable steps to protect your data, no security system can be guaranteed 100% secure. You also have a responsibility to safeguard your own account by using a strong password and not sharing your login credentials with anyone.

6Cookies and Tracking Technologies

Surga11 uses cookies and similar tracking technologies to enhance the user experience, understand platform usage patterns, and deliver more relevant content.

6.1 Types of Cookies We Use

• Essential Cookies: Required for core platform functions such as login, session management, and security. These cookies cannot be disabled.
• Performance Cookies: Collects data on how users use the platform to help us identify issues and make improvements.
• Functional Cookies: Stores your preferences such as preferred language and display settings to provide a more personalized experience.
• Analytics Cookies: Used by analytics tools such as Google Analytics to understand website traffic in an aggregated and anonymised manner.

6.2 Managing Your Cookie Preferences

You can manage or delete cookies at any time through your browser settings. However, disabling certain cookies may affect platform functionality. Essential cookies cannot be disabled as they are required for platform security and core functionality.

7Your Rights Regarding Personal Data

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data that we hold:

To exercise any of the above rights, please contact our privacy team via email at [email protected]. We will process your request within 30 business days.

8Data Retention Period

Surga11 retains your personal data only for as long as necessary to fulfil the purposes stated in this Policy, or as required by applicable laws and regulations.

• Active Account Data: Retained for the duration your account is active and up to 7 years after account closure to meet anti-money laundering (AML) compliance requirements.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with applicable financial regulatory requirements.
• Platform Activity Logs: Retained for 2 years for security and dispute resolution purposes.
• Support Communication Data: Retained for 3 years from the date of last interaction.
• Analytics Cookie Data: Set automatically in accordance with third-party analytics provider policies, typically between 30 days and 2 years.

When data is no longer needed, we will securely delete or destroy it using methods that ensure it cannot be recovered.

9Child Protection

The surga11 platform is exclusively for individuals aged 18 years and above. We do not knowingly collect or process personal data from minors.

If we determine that personal data of a minor has been collected without proper age verification, we will take immediate action to delete that data and close the relevant account. Parents or guardians who are concerned that their child has registered on our platform are encouraged to contact us promptly.

10Amendments to This Privacy Policy

Surga11 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, new legal requirements, or platform service improvements.

Any material changes to this Policy will be communicated to you via your registered email or in-platform notification at least 14 days before the changes take effect. The "Last Updated" date at the top of this document will be revised to reflect the date of the latest amendment.

Your continued use of the surga11 platform after the effective date of any changes constitutes your acceptance of the amended Privacy Policy. If you do not agree with the changes made, you have the right to close your account in accordance with the established procedure.

11Contact Us Regarding Privacy

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please do not hesitate to contact our privacy team:

• Privacy Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 on the Surga11 platform

We are committed to responding to all privacy-related inquiries within 7 business days. For more complex requests such as data access or deletion, we will provide a full response within 30 business days.