Suga22 Privacy Policy – Malaysia Member Personal Data Protection

1 Information We Collect

Suga22 collects various types of information to ensure our services run smoothly, securely, and appropriately for every member. The information collected falls into two main categories: information you provide directly, and information collected automatically when you use our platform.

Information you provide directly:

• Full name, date of birth, and identification card number (for KYC verification purposes).
• Email address, phone number, and current residential address.
• Bank account details or payment methods registered for deposits and withdrawals.
• Username, password (stored in encrypted hashed form), and account profile information.
• Identity verification documents such as photos of your identity card or passport uploaded during the KYC process.
• Correspondence with our customer support team.

Information collected automatically:

• IP address, device type, operating system, and web browser information used.
• Activity log data including pages visited, session duration, in-game actions, and platform usage patterns.
• Geolocation information at city or state level (not precise GPS coordinates) for regional verification purposes.
• Cookie data and similar tracking technologies as described in Section 5.

2 How We Use Your Data

All information we collect is used for clear and legitimate purposes. suga22 uses member personal data for the following:

We will not use your data for any other purposes not listed above without obtaining your consent beforehand.

3 Sharing Information with Third Parties

Suga22 takes an extremely cautious approach to data sharing. We do not sell or disclose your personal information to outside parties except in the situations outlined below, and all such instances are carried out with appropriate safeguards.

Third parties that may receive your data:

• Payment Providers: Transaction information is shared with approved payment processors solely to enable deposits and withdrawals to be processed securely. All such providers are bound by strict confidentiality agreements.
• Game Providers: Third-party game software providers may receive a unique user identifier (not full personally identifiable information) for technical purposes such as game session management.
• KYC Service Providers: Trusted third-party identity verification platforms are used to process member verification documents securely and efficiently.
• Authorities: We will disclose required information to law enforcement agencies or regulatory bodies when mandated by law or a valid court order.

4 Data Security

Protecting members' personal information is suga22's highest priority. We continuously invest in security infrastructure to ensure your data remains safe at all times.

The technical and organisational security measures we implement include:

• 256-bit SSL/TLS Encryption for all communications between your browser and suga22 servers, ensuring data cannot be intercepted during transmission.
• Hashed password storage using strong cryptographic algorithms — your password is never stored in plain text.
• Two-factor authentication (2FA) available to all members to add an extra layer of security to your account.
• Real-time threat monitoring by our cybersecurity team monitoring suspicious activity around the clock.
• Firewall and intrusion detection systems updated regularly to defend against the latest threats.
• Regular security audits by independent third parties who verify the resilience of our infrastructure against known vulnerabilities.
• Strict internal access controls — only authorised staff with a legitimate business need may access member data.

5 Cookies and Tracking Technologies

Suga22 uses cookies and similar tracking technologies to enhance the user experience, maintain Login session security, and understand how members interact with our platform.

Types of cookies we use:

• Necessary Cookies (Essential Cookies): Required for core platform functions such as maintaining Login sessions and security. These cookies cannot be disabled.
• Performance Cookies: Helping us understand how members use the platform so we can improve the user experience. Data collected is anonymised.
• Functional Cookies: Saving your preferences such as language, display settings, and game preferences for a smoother experience in the future.
• Analytics Cookies: Used to analyze platform traffic and usage patterns in aggregate for continuous improvement purposes.

You can manage cookie settings through your web browser settings. Please note that disabling certain cookies may affect the functionality of the suga22 platform.

6 Your Privacy Rights

As a suga22 member, you have the following rights regarding your personal data. We are committed to respecting and facilitating the exercise of these rights:

7 Data Retention Period

Suga22 does not retain personal data longer than necessary. Retention periods are determined based on the purpose of data collection and applicable legal requirements.

• Active account data: Retained for as long as your account remains active and operational on the suga22 platform.
• Data after account closure: Transaction records and KYC records are retained for a minimum of five (5) years after account closure to fulfil anti-money laundering (AML) compliance obligations and tax requirements.
• Support communication logs: Retained for three (3) years for reference and dispute resolution.
• Cookie data: Session cookies expire when you close your browser, while persistent cookies have varying expiry periods depending on their type.
• Marketing data: Retained until you withdraw consent or close your account.

Once the retention period expires, your data will be securely deleted or anonymised in accordance with established data disposal procedures.

8 Third-Party Links

The suga22 platform may contain links or integrations to third-party services such as game providers or payment platforms. This Privacy Policy applies solely to the suga22 platform.

Suga22 is not responsible for the privacy practices of any third-party websites or services accessed through our platform. We encourage you to read the privacy policy of each third-party service you use separately.

9 Changes to This Privacy Policy

Suga22 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform improvements. The "Last Updated" date at the top of this page will be revised whenever an amendment is made.

For material changes that significantly affect how we use your data, we will:

• Sending a notice to the email address registered to your account at least seven (7) days before the changes take effect.
• Displaying clear notices on the platform's Home page and within your account panel.
• Requesting your consent again should any changes involve new data processing purposes.

Continued use of the suga22 platform after the effective date of any changes will be considered your acceptance of the updated Privacy Policy.

10 Contact Our Privacy Team

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, the suga22 privacy team is here to help.

You can reach us via:

• Privacy Email: [email protected]
• Live Support: Via the live chat function on the suga22 platform, which operates 24 hours a day, 7 days a week.
• Support Ticket: Submit an official request through the help center in your account for a formal written record.

We are committed to responding to all privacy-related inquiries within 72 working hours. For more complex data rights requests, we will notify you of a more accurate estimated processing time upon receiving your request.