Privacy Policy SBK21 – Personal Data Protection for Malaysian Players

1. Introduction

Sbk21 ("Platform", "We") deeply values the trust you place in us when sharing personal information while using our online Sports Betting and casino platform at sbk21.click. This Privacy Policy transparently explains how we collect, use, disclose, store, and protect your personal data as a registered member or visitor of the sbk21 platform.

This document is prepared in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA), the primary legislation governing the processing of personal data in the context of commercial transactions in Malaysia. By registering for or continuing to use the sbk21 platform, you acknowledge that you have read and understood this Privacy Policy and agree to the practices described herein.

2. Personal Data We Collect

Sbk21 collects various types of personal data depending on the nature of your interactions with the platform. The following are the categories of data we may collect:

Sbk21 practises data minimisation — we only collect data that is genuinely necessary for clearly stated purposes. We do not collect sensitive information such as biometric data, health information, or religious beliefs unless required by law.

3. How We Collect Your Personal Data

Sbk21 collects your personal data through several different channels:

• Account Registration: When you register for an sbk21 account, you provide identification and contact information directly through the registration form.
• Platform Usage: Your activity on the sbk21 platform — including the bets you place, the games you play, and the time you spend — is automatically recorded as part of normal platform operations.
• Financial Transactions: Each time you make a deposit using Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, or FPX, or submit a withdrawal request, the transaction details are recorded in sbk21's system.
• Support Communications: When you contact the sbk21 support team via live chat or email, the content of that communication is retained for reference and service improvement purposes.
• Cookies & Tracking Technologies: sbk21 uses cookies and similar tracking technologies to collect technical data about how you interact with our platform. Further details are explained in Section 9.
• Identity Verification (KYC): During the KYC process, you may be asked to upload a copy of an identity document such as your MyKad, passport, or a utility bill as proof of address.
• Third-Party Sources: In certain cases involving identity verification or fraud prevention, sbk21 may receive information about you from third-party service providers we engage for those purposes.

4. The Purposes for Which We Use Your Personal Data

Sbk21 uses the personal data we collect for the following purposes, all of which are lawful under Malaysia's PDPA 2010:

• Account Management: Creating, verifying, and managing your sbk21 account, including identity verification and the KYC process as required by regulations.
• Service Delivery: Allowing you to access and use all sbk21 products, including Sports Betting, Live Casino, live matches, and bonus promotions.
• Transaction Processing: Processing deposits and withdrawals via your chosen Malaysian local payment method — Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, or FPX.
• Security & Fraud Prevention: Identifying, investigating, and preventing fraudulent activity, money laundering, collusion, and misuse of the sbk21 platform.
• Responsible Gaming: Monitoring gameplay activity patterns to identify signs of problem gambling and provide appropriate support to members who need assistance.
• Customer Support: Providing effective technical assistance and customer service when you contact the sbk21 support team.
• Legal Compliance: Fulfilling the legal and regulatory obligations applicable to the operation of the sbk21 platform, including anti-money laundering (AML) and Know Your Customer (KYC) requirements.
• Platform Improvements: Analysing aggregated and anonymised usage data to understand how players interact with sbk21 and to continuously improve the user experience.
• Service Communications: Sending important notifications about your account, changes to terms, security updates, and technical information related to your use of sbk21.
• Marketing (with consent): Sending promotional offers, bonuses, and new sbk21 product information — only to members who have given explicit consent to receive marketing communications.

5. Sharing Personal Data with Third Parties

Sbk21 does not sell or rent your personal data to any third party. However, in the course of normal platform operations, sbk21 may need to share your personal data with the following categories of third parties, and only for the purposes stated:

• Payment Processors: Payment service providers such as Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and Malaysian banks that support FPX need to receive the transaction information required to process your deposits and withdrawals.
• Technical Service Providers: Companies that provide sbk21 with technical infrastructure, server hosting, cybersecurity, and analytics services may have limited access to data necessary for those services. All such providers are bound by strict data processing agreements.
• Game Software Providers: Live casino software providers that supply the gaming platform to sbk21 may receive the minimum data required for the technical operation of game tables.
• Law Enforcement Authorities: sbk21 may be required to disclose personal data to law enforcement authorities, regulatory bodies, or courts when lawfully directed by a court order, warrant, or valid official directive. sbk21 will comply with all such requests in accordance with applicable Malaysian law.
• Business Transfer: Should sbk21 undergo a merger, acquisition, or asset transfer, your personal data may be transferred as part of the business assets. You will be notified if this situation arises and your rights will be upheld.

In all cases of data sharing with third parties, sbk21 ensures that the receiving party upholds data protection standards equivalent to those practised by sbk21, and that data is used only for permitted purposes.

6. Data Security Measures

Sbk21 implements a range of robust technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL Encryption: All communications between your browser and sbk21's servers are secured with Transport Layer Security (TLS) encryption at a 256-bit key length — the same standard used by Malaysia's leading banks.
• Encryption of Data at Rest: Sensitive data stored in sbk21's databases — including passwords and financial information — is encrypted using modern cryptographic algorithms. Your password is never stored in plain text.
• Internal Access Controls: Access to members' personal data within sbk21's internal systems is restricted to staff who genuinely require it to carry out their duties. All access is logged and monitored.
• Two-Factor Authentication (2FA): sbk21 offers 2FA for member accounts as an additional layer of security on top of your password. We encourage all members to enable this feature.
• Regular Security Audits: sbk21 conducts regular security assessments and penetration testing by independent third-party security experts to identify and address system vulnerabilities.
• Active 24/7 Monitoring: The sbk21 security team actively monitors systems around the clock to detect any suspicious activity or unauthorised access attempts.
• Incident Response Plan: sbk21 has clear procedures in place to respond to data security incidents, including notifying affected members and the relevant authorities within the prescribed timeframe.

7. Personal Data Retention Period

Sbk21 retains your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Malaysian law. In general:

• Active Account Data: For as long as your sbk21 account remains active, relevant personal data will be retained to support your account's operations.
• After Account Closure: When your sbk21 account is closed for any reason, sbk21 will retain data necessary to fulfil its legal obligations — including financial record-keeping and AML requirements — for a minimum period of seven (7) years in accordance with Malaysian law.
• Financial Transaction Records: All deposit and withdrawal transaction records — including those involving Touch 'n Go eWallet, GrabPay, DuitNow, and FPX — are retained for a minimum of seven (7) years in accordance with Malaysia's accounting and AML legal requirements.
• Support Communication Data: Live chat transcripts and support emails are retained for two (2) years from the date of communication for reference and dispute resolution purposes.
• Cookie Data: Cookie retention periods vary by type — session cookies expire when you close your browser, while persistent cookies may be stored for up to 12 months. You can delete cookies at any time through your browser settings.

When personal data is no longer needed and there is no legal obligation to retain it, sbk21 will securely delete or anonymise that data.

8. Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you as a data subject have certain rights regarding your personal data held by sbk21. sbk21 is committed to respecting and facilitating the exercise of these rights:

9. Cookies and Tracking Technologies

Sbk21 uses cookies and similar tracking technologies to enhance the user experience, maintain platform security, and understand how players interact with sbk21. Cookies are small text files stored on your device when you visit a website.

The types of cookies sbk21 uses include:

• Essential Cookies: Required for core sbk21 platform functions such as login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collecting information on how visitors use the sbk21 platform — including the most frequently visited pages, time spent, and error messages encountered. All data is collected on an aggregated and anonymised basis.
• Functional Cookies: Saves your personal preferences such as language, display settings, and game preferences so you do not have to reset them each time you access sbk21.
• Security Cookies: Helps sbk21 identify legitimate login sessions, detect suspicious access attempts, and protect your account from unauthorised access.

You can control and manage cookies through your web browser settings. However, disabling certain cookies may affect the functionality of the sbk21 platform. For guidance on managing cookies in popular browsers, refer to your browser's help documentation.

10. Protection of Children's Data

The sbk21 platform is strictly for individuals aged 18 and above. sbk21 does not knowingly collect or process personal data from anyone under the age of 18. Should sbk21 become aware that personal data has been collected from a person under 18, we will take immediate steps to delete that data and close the account in question.

Parents or guardians who believe that their child or dependent under the age of 18 has registered with or provided personal data to sbk21 are urged to contact us immediately at support@sbk21.click. sbk21 will respond promptly to address the situation.

11. Amendments to This Privacy Policy

Sbk21 reserves the right to amend, update, or supplement this Privacy Policy at any time to reflect changes in legislation, industry practices, or our platform's operations. For material amendments that affect how we process your personal data, sbk21 will provide reasonable notice via your registered email address or a prominent in-platform notification before the changes take effect.

The "Updated" date at the top of this Privacy Policy will be revised whenever any changes are made. We encourage you to review this Privacy Policy periodically. Your continued use of the sbk21 platform following any amendments constitutes your acceptance of the revised Privacy Policy.

12. How to Contact Us About Privacy

If you have any questions, concerns, or complaints regarding how sbk21 handles your personal data, or if you wish to exercise any of your rights under PDPA 2010, please contact us through the following channels:

• Email: support@sbk21.click — please include the subject line "Privacy Policy Enquiry" to help us process your request more quickly.
• Live Chat: Available directly on the sbk21 platform — 24 hours a day, 7 days a week, including Malaysian public holidays.

Sbk21 is committed to responding to all privacy enquiries within 14 business days of receipt. For more complex requests such as data access or deletion requests, we may require up to 21 business days and may ask for additional identity verification to safeguard your data.

If you are not satisfied with sbk21's response to your privacy enquiry, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia under the Personal Data Protection Act 2010.