Privacy Policy — paus138

paus138 ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all registered players and visitors to our website located at https://paus138.cam. This Privacy Policy ("Policy") describes in clear, structured terms how paus138 collects, processes, stores, shares, and safeguards personal information in connection with the operation of our online casino and sports betting services.

This Policy applies to all players registered on paus138 regardless of their location, with particular relevance to players based in Malaysia — including those located in Kuala Lumpur, Petaling Jaya, Penang, Johor Bahru, Shah Alam, and Bangsar — who access the platform and conduct transactions in Malaysian Ringgit (MYR).

By accessing the paus138 platform, registering an account, making a deposit via FPX, DuitNow, or any other supported payment method, or otherwise using our services, you confirm that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with this Policy, you should cease using the platform and close your account.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information that identifies or could reasonably identify a natural person, directly or indirectly, including name, identification number, contact details, IP address, device identifiers, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" means paus138 in its capacity as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third-party entity that processes Personal Data on behalf of paus138 in accordance with documented instructions, including payment processors such as FPX and DuitNow operators, KYC service providers, and platform infrastructure partners.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "Cookie" means a small text file placed on your device by the paus138 platform to facilitate session management, platform performance, and personalisation functions.
• "KYC" means Know Your Customer, the identity and document verification process conducted by paus138 to comply with applicable anti-money laundering and counter-terrorist financing obligations.

paus138 collects Personal Data in several categories depending on the nature of your interaction with the platform. The table below summarises the categories of data we collect and the context in which each category arises:

paus138 does not knowingly collect sensitive personal data such as racial or ethnic origin, religious beliefs, or health information beyond what is strictly required for responsible gambling monitoring purposes (for example, noting a player's self-reported gambling concern in the context of a self-exclusion request).

paus138 collects Personal Data through the following channels:

4.1 Direct Collection

Information you provide directly when you:

• Register an account on the paus138 platform.
• Complete KYC verification by submitting identification and address documentation.
• Make a deposit or request a withdrawal using FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, or bank transfer.
• Contact our support team via live chat or email.
• Claim a promotion or respond to a survey.
• Update your account profile or communication preferences.

4.2 Automated Collection

Technical data collected automatically when you access or use the platform, including through cookies, server logs, and analytics tools integrated directly into the platform infrastructure. This includes session data, device fingerprint information, and in-platform navigation behaviour.

4.3 Third-Party Sources

In limited circumstances, paus138 may receive Personal Data from authorised third-party service providers, including:

• Identity verification and KYC partners who assist in validating documents submitted during the verification process.
• Payment processing intermediaries who confirm transaction status for FPX and DuitNow transfers.
• Fraud detection and AML screening service providers who perform automated risk assessments.

paus138 processes your Personal Data for the following specific, documented purposes:

• Account Management: Creating, maintaining, and administering your paus138 player account, including processing your login, managing your account balance in MYR, and applying your account preferences.
• Identity Verification (KYC): Verifying your identity and age (21+ requirement) in compliance with applicable anti-money laundering, counter-terrorist financing, and responsible gambling obligations.
• Transaction Processing: Processing deposits and withdrawals via FPX, DuitNow, and other supported Malaysian payment channels, and maintaining accurate financial records of all MYR transactions.
• Legal Compliance: Fulfilling obligations under applicable laws, regulations, and licensing conditions, including reporting obligations to relevant regulatory bodies where required.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, account takeover attempts, and other security threats to protect both players and the platform.
• Customer Support: Responding to your enquiries, resolving disputes, and providing technical assistance through our 24/7 English-language support team.
• Responsible Gambling: Monitoring gameplay patterns to identify potentially problematic gambling behaviour and facilitating self-exclusion, deposit limit, and other responsible gambling tool requests.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, and user experience for players across Malaysia.
• Marketing Communications: Sending you promotional offers, reload bonus alerts, and relevant updates about paus138 services — only where you have provided consent or where a legitimate interest basis applies, and always with a clear opt-out mechanism.

paus138 processes your Personal Data on the following legal bases, depending on the specific purpose of processing:

• Contractual Necessity: Processing necessary for the performance of the contract between you and paus138, including account management, transaction processing, and the delivery of gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulatory obligations, including KYC, AML, and responsible gambling requirements.
• Legitimate Interests: Processing carried out in pursuit of paus138's legitimate business interests, including fraud prevention, platform security, and aggregated analytics — provided such interests are not overridden by your privacy rights.
• Consent: Processing of your Personal Data for optional purposes, such as direct marketing communications, where your explicit consent has been obtained. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

paus138 does not sell your Personal Data to third parties under any circumstances. We may share your data with the following categories of recipients only where necessary and subject to appropriate data processing agreements:

7.1 Service Providers (Data Processors)

• Payment Processors: FPX gateway operators, DuitNow infrastructure providers, and electronic wallet platforms (Touch 'n Go, Boost, GrabPay) receive the minimum necessary data to process your MYR transactions securely.
• KYC & Identity Verification Providers: Specialist third-party verification services receive copies of identity documents you submit during the KYC process, solely for the purpose of verifying their authenticity.
• IT Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who maintain the technical infrastructure on which the paus138 platform operates.
• Customer Support Platforms: Third-party live chat and ticketing systems that facilitate the delivery of our 24/7 English-language support service.

7.2 Legal and Regulatory Disclosure

paus138 may disclose your Personal Data to governmental authorities, regulatory bodies, law enforcement agencies, or courts of competent jurisdiction where we are required to do so by applicable law, court order, or regulatory instruction. Such disclosures will always be limited to what is strictly required by the relevant legal demand.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a material portion of the paus138 business, your Personal Data may be transferred to the acquiring or successor entity as part of that transaction, subject to equivalent data protection commitments being maintained.

paus138 operates internationally and some of the service providers and infrastructure partners with whom we share data may be located outside Malaysia. Where your Personal Data is transferred to, or processed in, a jurisdiction outside Malaysia, paus138 ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required under applicable Malaysian data protection law.

These safeguards may include binding contractual clauses with the receiving entity, reliance on an adequacy decision covering the recipient jurisdiction, or adherence to certified international data protection frameworks. By using the paus138 platform, you acknowledge and consent to these international transfers as necessary for the delivery of the services described in this Policy.

paus138 retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following retention principles apply:

• Active Account Data: Personal Data associated with your active account is retained throughout the duration of your account's active status and for a period of at least five (5) years following account closure, in accordance with applicable financial record-keeping obligations.
• Transaction Records: Financial transaction records, including MYR deposit and withdrawal history, are retained for a minimum of seven (7) years to comply with anti-money laundering and tax record requirements.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following the end of the business relationship, consistent with AML compliance requirements.
• Support Communications: Live chat transcripts and email correspondence are retained for a period of two (2) years from the date of each interaction, unless a longer period is required in connection with an open dispute or investigation.
• Marketing Data: Communication preference records and marketing consent logs are retained for the duration of your account plus five (5) years to demonstrate compliance with consent requirements.

Upon the expiry of the applicable retention period, Personal Data will be securely deleted or anonymised in a manner that renders re-identification impossible.

paus138 uses cookies and similar technologies to operate and improve the platform. Cookies are small text files stored on your device that allow the platform to recognise your browser session and remember certain preferences.

10.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the platform to function correctly. These include session authentication cookies, security tokens, and load-balancing identifiers. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Allow the platform to remember preferences such as your preferred language, currency display settings (MYR), and previously viewed game categories, delivering a more personalised experience.
• Analytics Cookies: Help us understand how players navigate the platform, which features are most used, and where technical issues arise. Analytics data is collected and analysed in aggregated, anonymised form only.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorised account access, and other security threats, including suspicious login patterns from unusual IP addresses.

10.2 Managing Cookies

You may manage cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies; however, please note that disabling strictly necessary cookies will impair your ability to log in and use the paus138 platform. paus138 does not deploy third-party advertising cookies or cross-site behavioural tracking technologies.

As a player whose Personal Data is processed by paus138, you hold the following rights in respect of your data. paus138 is committed to honouring these rights promptly and without imposing any charge for reasonable requests:

• Right of Access: You may request a copy of all Personal Data that paus138 holds about you, together with information about the purposes for which it is being processed.
• Right to Rectification: Where Personal Data held by paus138 is inaccurate or incomplete, you have the right to request that we correct or supplement it without undue delay.
• Right to Erasure ("Right to Be Forgotten"): In certain circumstances — for example, where data is no longer necessary for the purpose for which it was collected — you may request the deletion of your Personal Data, subject to applicable legal retention obligations.
• Right to Restriction of Processing: You may request that paus138 restrict the processing of your Personal Data in specific circumstances, such as while the accuracy of disputed data is under review.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request your Personal Data in a structured, machine-readable format for the purpose of transferring it to another service provider.
• Right to Object: You may object at any time to the processing of your Personal Data for direct marketing purposes, including betting promotions and bonus offers. You may also object to processing based on legitimate interests, subject to our ability to demonstrate overriding legitimate grounds.

paus138 implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the paus138 platform.
• Encrypted storage of sensitive account data, including hashed and salted password credentials.
• Two-factor authentication (2FA) options available to all registered players for enhanced account security.
• Continuous real-time monitoring of platform transactions and login events for anomalous or suspicious activity.
• Regular independent security assessments and penetration testing of platform infrastructure.
• Strict internal access controls limiting employee access to Personal Data on a need-to-know basis.
• Documented incident response procedures for detecting, containing, and notifying affected players in the event of a data security incident.

Despite these measures, no digital platform can guarantee absolute security. In the event of a data security incident that is likely to result in a risk to your rights and freedoms, paus138 will notify you without undue delay in accordance with applicable notification obligations.

The paus138 platform may reference or integrate with third-party payment services, including the FPX payment gateway operated by Payments Network Malaysia (PayNet), DuitNow operated under Bank Negara Malaysia's regulatory framework, and electronic wallet services including Touch 'n Go eWallet, Boost, and GrabPay.

When you initiate a transaction using any of these third-party payment services, the data processing that occurs within those third-party systems is governed by the respective privacy policies and terms of service of those providers. paus138 is not responsible for the data practices of third-party payment service providers and encourages players to review the privacy documentation of any third-party service they use in connection with their paus138 account.

The paus138 platform is strictly intended for individuals who are 21 years of age or older. paus138 does not knowingly collect, process, or retain Personal Data from persons under the age of 21. Age verification is a mandatory component of the account registration and KYC process.

In the event that paus138 determines or has reasonable grounds to suspect that an account holder is under the age of 21, the account will be suspended immediately, any balance will be frozen pending investigation, and all Personal Data associated with the underage account will be handled in accordance with applicable law, including deletion where no legal retention obligation applies.

paus138 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is always indicated in the "Last Updated" field displayed at the top of this page.

Where amendments are material — for example, where we introduce a new category of data collection or a new processing purpose — paus138 will notify registered players via email or a prominent on-platform notification prior to the changes taking effect. Your continued use of the platform following the effective date of any amended Policy constitutes your acceptance of the revised terms.

We encourage all players to review this Privacy Policy periodically to remain informed of how paus138 protects and manages their personal information.

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data by paus138, please contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly on the paus138 platform. Our English-language support agents can handle data enquiries and rights requests in real time.
• Email: [email protected] — please include "Privacy Request" in the subject line for data rights enquiries. We respond within 24 business hours.
• Operating Hours: Our team operates on Malaysian Time (MYT, UTC+8), 24 hours a day, 365 days a year including Malaysian public holidays.

When submitting a data rights request, please provide your registered email address and account username to help our team locate your records and respond accurately. Identity verification may be required before certain data rights requests — such as access or erasure requests — can be processed, to ensure your data is not disclosed or deleted in response to an unauthorised request.