Borneo77 Privacy Policy – User Personal Data Protection

1 Introduction

Welcome to the borneo77 Privacy Policy page. This document is a binding data protection agreement between you as a user of our platform and the borneo77 management team operating at the website borneo77.fun.

Borneo77 takes user privacy very seriously. In today's digital world, personal data is a valuable asset that must be carefully protected. We understand that your trust in us is not something to be taken lightly — and that trust begins with transparency about how we handle your information.

This Privacy Policy details the types of data we collect when you use the Borneo77 platform, how that data is used to enhance your experience, the security measures we take to protect it, and your rights as the owner of that data. We encourage you to read this document in full carefully.

By registering an account at Borneo77, logging in to our platform, or simply browsing our website, you are deemed to have understood and accepted the terms set out in this Privacy Policy. If you disagree with any part of this policy, please contact our support team before continuing to use the platform.

2 Personal Data We Collect

Borneo77 only collects data that is strictly necessary to operate the platform safely, comply with legal requirements, and provide you with the best user experience. Below are full details of the types of data we may collect:

We do not collect information considered sensitive under Malaysian law, such as health information, religious beliefs, or political affiliations, unless voluntarily shared by you in a specific context directly related to our services.

3 Purposes for Using Your Personal Data

The data we collect is used solely for legitimate, transparent purposes directly related to the operation of the Borneo77 platform and to meet applicable legal requirements. Specifically, your data is used for the following purposes:

• Identity verification and account registration: Ensuring every user who registers is a real individual aged 18 and above and not an entity prohibited from using our services.
• KYC and AML Procedure Compliance: Meeting legal obligations related to anti-money laundering and counter-terrorism financing as required by the relevant licensing and regulatory authorities.
• Financial Transaction Processing: Ensuring all deposits and withdrawals are processed accurately, promptly, and securely to the correct account.
• Service provision and customer support: Enabling our support team to identify your account, understand your interaction history, and resolve issues more effectively.
• Account-related communications: Sending important security notices, policy updates, transaction confirmations, and technical information relevant to your account.
• Personalisation of user experience: Personalising content, game recommendations, and promotional offers based on your preferences and usage habits (with your consent).
• Platform security: Detecting and preventing fraud, unauthorised access, system abuse, and other security threats.
• Platform Enhancement: Analysing usage data in aggregate (without identifying individuals) to improve the performance, design, and functionality of the borneo77 platform.

Borneo77 will not use your data for any purpose beyond those stated above without first obtaining your permission. If we intend to use your data for a new material purpose, we will notify you and obtain your consent before doing so.

4 Legal Basis for Data Processing

Every processing of personal data carried out by borneo77 is based on one or more valid legal grounds, in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA). These grounds are:

• Consent: When you register an account and accept our Terms and Conditions and Privacy Policy, you give your consent to the data processing necessary to operate the platform's services.
• Contract Fulfillment: Processing of data required to fulfill our contractual obligations to you, such as processing payments and managing your account.
• Legal obligation: Processing required to comply with Malaysian laws and the regulations of applicable licensing authorities, including KYC and AML requirements.
• Legitimate interest: Processing carried out on the basis of legitimate business interests, such as fraud prevention, platform security, and service improvement — provided these interests do not override your fundamental rights and freedoms.

5 Data Sharing with Third Parties

Borneo77 maintains a strict policy regarding the sharing of users' personal data. We only share your data in the following limited situations, and always with appropriate safeguards in place:

• Payment Service Providers: Transaction information is shared with payment processors (such as e-wallet providers, banks, and cryptocurrency processors) solely to enable your deposits and withdrawals to be processed securely.
• Software and Game Providers: Minimum technical data is shared with third-party game providers (such as Pragmatic Play, Evolution Gaming, Spadegaming) to enable games to function within your account.
• KYC and identity verification services: Identity data is shared with accredited identity verification service providers that assist us in meeting legal compliance requirements.
• Authorities and regulatory bodies: Borneo77 complies with all lawful requests from government authorities, courts, or licensing bodies to disclose user data when required by law.
• Analytics services: Anonymised usage data (without personal identifiers) is shared with analytics tools to help us understand platform usage patterns and improve them.

All third parties we work with are required to uphold data protection standards equal to or higher than our own. We do not permit any third party to use your data for their own marketing purposes or for any purpose outside the agreed scope.

6 Data Storage & Retention Period

Borneo77 retains your personal data only for as long as it is needed for the purposes stated in this Privacy Policy, or for as long as required by applicable law. Our general data retention guidelines are as follows:

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised so that it can no longer be linked to any specific individual. We apply data deletion procedures that comply with industry security standards to ensure your information cannot be recovered once deleted.

7 Data Security Measures

Protecting your personal data is an absolute priority for borneo77. We continuously invest in security infrastructure and staff training to ensure your data remains protected against modern digital threats. The comprehensive security measures we employ include:

• Data encryption in transit: All communications between your browser and borneo77's servers are protected by TLS 1.3 with 256-bit SSL encryption — rendering your data unreadable to any party attempting to intercept the connection.
• Data encryption at rest: Sensitive data stored in our databases is encrypted using high-grade encryption algorithms, ensuring it remains secure even in the event of unauthorised physical access.
• Two-Factor Authentication (2FA): The 2FA feature is available to all Borneo77 user accounts, adding an extra layer of security that protects your account even if your password is compromised.
• Real-Time Threat Monitoring: Our automated monitoring system operates 24 hours a day, 7 days a week, to detect and respond to any suspicious activity or security threats before they can compromise your data.
• Strict access controls: Only borneo77 staff who genuinely require access to specific data to perform their duties are authorised to do so — based on the principle of least privilege access.
• Penetration testing: The borneo77 platform undergoes regular security testing by independent cybersecurity experts to identify and address any vulnerabilities before they can be exploited.
• Incident response plan: Borneo77 has clear procedures in place to respond to any data breach, including notifying affected users and relevant authorities within the timeframes prescribed by law.

8 Your Rights as a Data Owner

Under Malaysia's Personal Data Protection Act 2010 and Borneo77's internal policies, you have the following rights regarding your personal data: