Privacy Policy surga11 – Malaysian Member Data Protection

This Privacy Policy is published by surga11, an online betting and gaming platform operator accessible via surga11-jit.com. This document sets out surga11's commitment to protecting the personal data of all members and visitors who use our platform in Malaysia.

We understand that privacy is more than a legal requirement — it is a trust you place in surga11 every time you register, make a deposit, or enjoy games on our platform. We do not take that trust lightly. This Privacy Policy is written clearly in English so that every Malaysian member can understand exactly what happens to their information.

This Policy applies to all personal data collected through:

• The website surga11-jit.com and all pages under it.
• Any surga11 mobile applications that may be developed in the future.
• All communications between surga11 and its members, including email, live chat, and WhatsApp.
• Any service or product offered by surga11 to its members.

Surga11 collects various types of personal data depending on how you interact with our platform. Below is a comprehensive overview of the data categories we collect:

Surga11 does not collect data that is irrelevant or beyond what is required for the stated purpose. Each data category is collected on the basis of a specific and legitimate need.

Your personal data is collected by surga11 through various methods that occur during your interactions with our platform:

• During Account Registration: When you complete the surga11 registration form, you provide your identity and contact details directly to us.
• During Identity Verification (KYC): When we request verification documents such as a copy of your MyKad or passport to confirm your identity before processing large withdrawals.
• During Deposits and Withdrawals: Payment method details such as Touch 'n Go eWallet account numbers, GrabPay, DuitNow, or FPX details are collected to process your transactions.
• During Platform Use: Usage and technical data are collected automatically via server logs, cookies and similar tracking technologies when you browse the surga11 website.
• Via Support Interactions: When you contact the surga11 support team via live chat, email or WhatsApp, those communications are recorded for quality assurance and complaint record purposes.
• Via Authorised Third Parties: In some cases, we may receive data from payment service providers (such as banks or e-wallet operators) to verify your identity or transactions.

Surga11 uses the personal data collected for the following purposes, all of which are necessary for delivering our services properly and responsibly:

• Account Management: Creating, maintaining, and securing your surga11 account, including processing logins, verifying your identity, and ensuring account security.
• Transaction Processing: Processing deposits via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX, as well as handling your winnings withdrawals promptly and accurately.
• Service Provision: Giving you full access to everything surga11 has to offer — including Malaysia Super League and EPL Sports Betting, Live Casino, slots, cricket, badminton, e-sports, and live in-play matches.
• Fraud Prevention & Security: To detect and prevent unauthorised access, identity fraud, money laundering, and any misuse of the surga11 platform.
• Legal Compliance: To meet applicable legal obligations, including Know Your Customer (KYC) and anti-money laundering (AML) requirements.
• Service Communications: Sending important notifications about your account, changes to terms, promotions you are eligible for, and relevant platform updates.
• Platform Improvements: Analysing usage patterns in aggregate (not at the individual level) to understand how members interact with surga11 and to make meaningful improvements.
• Responsible Gambling: Monitoring gameplay patterns to identify risk indicators and ensure responsible gaming tools are functioning effectively to protect members.

Protecting your personal data is surga11's highest technical priority. We continually invest in security infrastructure to ensure your data is always safeguarded against both internal and external threats.

Technical security measures employed by surga11:

• 256-bit SSL Encryption: All data transmitted between your browser or app and surga11's servers is encrypted using TLS with AES-256 encryption — the same level of security used by major Malaysian banking institutions.
• Stored Data Encryption: Personal and financial data stored in surga11's databases is also encrypted to protect against unauthorised access, even in the event of a physical breach.
• Internal Access Controls: Access to members' personal data is restricted to surga11 staff with a legitimate need only, based on the principle of least privilege access.
• Intrusion Detection System: An active monitoring system operates 24/7 to detect and respond to any suspicious or unauthorised access attempts.
• Periodic Security Audits: surga11 conducts regular security audits and penetration testing to identify and address vulnerabilities before they can be exploited.
• Secure Data Backups: Member data is regularly backed up to secure, encrypted locations to ensure service continuity and data recovery in the event of a technical incident.

While surga11 takes all reasonable steps to protect your data, no security system can be guaranteed to be 100% foolproof. You also play an important role in safeguarding your account by using a strong password, not sharing your login credentials, and contacting us promptly if you suspect any unauthorised activity.

Surga11 does not sell your personal data to any third party. However, in the course of delivering our services, it is necessary to share certain data with selected third parties in the following circumstances:

• Payment Service Providers: Required transaction data is shared with e-wallet providers (Touch 'n Go, GrabPay, Boost, ShopeePay), DuitNow and FPX banks (Maybank, CIMB and others) to process your deposits and withdrawals. This sharing is limited strictly to the data necessary to complete the transaction.
• Game Providers: Limited game session data is shared with licensed casino and slots game providers partnering with surga11 to ensure the games function correctly.
• Technology Service Providers: surga11 uses reputable cloud service and infrastructure providers to store and process data. All such providers are bound by strict confidentiality agreements and are not permitted to use your data for their own purposes.
• Legal Requirements: surga11 may be required to disclose personal data to the relevant authorities where mandated by law, court order, or in the course of a legitimate criminal investigation.
• Business Transfers: In the event of a merger, acquisition, or transfer of surga11's assets, member data may be transferred to the relevant new entity — provided that entity is bound by the same or stricter Privacy Policy.

Surga11 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit the surga11 website.

Types of cookies used by surga11:

• Essential Cookies: Required for core platform functions such as login authentication, session management, and security. These cookies cannot be disabled, as the platform will not function properly without them.
• Performance Cookies: Collects information on how you use the surga11 platform — pages visited, time spent, and any errors encountered — to help us improve platform performance.
• Functional Cookies: Saves your preferences such as language settings, display options, and account information to make your experience smoother on future visits.
• Analytics Cookies: Collects aggregate statistical data on overall platform usage patterns. This data is not linked to any individual's personal identity.

You can manage cookie settings through your web browser preferences. However, disabling essential cookies may affect the functionality of the surga11 platform and your overall experience.

As a surga11 member, you have certain rights regarding your personal data. surga11 is committed to respecting and facilitating the exercise of these rights:

• Access Rights: You have the right to request a copy of the personal data we hold about you. surga11 will provide this information in a readable format within 30 days of your request.
• Right to Rectification: If the personal data we hold about you is inaccurate or out of date, you may request a correction. You can also update much of your account information directly through your surga11 account settings.
• Right to Erasure: Under certain circumstances, you may request that surga11 delete your personal data. However, this right may be limited by our legal obligations to retain specific records (such as transaction records for tax and AML purposes).
• Right to Object to Processing: You may object to the use of your data for direct marketing purposes at any time, without needing to provide any reason.
• Right to Data Portability: You may request surga11 to provide your personal data in a structured, machine-readable format for transfer to another service provider.
• Right to Withdraw Consent: Where the processing of certain data is based on your consent, you may withdraw that consent at any time — though this does not affect the validity of any processing carried out prior to the withdrawal.

To exercise any of the rights above, please contact the surga11 support team by email at support@surga11-jit.com, stating the right you wish to exercise along with your account details. surga11 will respond within 30 days of receiving your request.

The surga11 platform is exclusively for individuals aged 18 years and above. surga11 does not knowingly collect personal data from children or individuals under the age of 18.

If we discover that we have collected personal data from an individual under the age of 18 without proper age verification, we will:

• Immediately suspending the account in question pending further investigation.
• Permanently deleting all personal data associated with that account from our systems.
• Freezing and returning account balances in accordance with established procedures.
• Taking the necessary steps to prevent underage individuals from accessing the platform in the future.

If you have reason to believe that an individual under the age of 18 is using the surga11 platform, please contact us immediately at support@surga11-jit.com so that we may take appropriate action.

Surga11 retains your personal data only for as long as necessary for the purpose it was collected, or as required by applicable laws and regulations. The following is a general guide to data retention periods by category:

• Active Account Data: Retained for as long as your account remains active, and for a reasonable period following account closure.
• Financial Transaction Records: Retained for a minimum of 7 years from the date of transaction, in accordance with applicable financial and tax laws in Malaysia.
• Support Communication Records: Retained for 2 years from the date of communication for quality control and dispute resolution purposes.
• Technical & Security Logs: Retained for 6 to 12 months for security analysis and threat detection purposes.
• Identity Verification (KYC) Data: Retained for the duration of the active account and for a minimum of 5 years after account closure, based on AML compliance requirements.

When data is no longer needed and there is no legal obligation to retain it, surga11 will securely delete or anonymise it in accordance with established procedures.

The surga11 platform may contain links or integrations to third-party services such as payment providers (bank websites for FPX, e-wallet interfaces) or game providers. This Privacy Policy applies only to data collected directly by surga11.

Surga11 is not responsible for the privacy practices or content of any third-party websites you may visit through our platform. We recommend reading the privacy policy of each third-party website before providing them with any personal information.

Surga11 reserves the right to amend this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or updates to the services we offer. When we make material changes, we will:

• Updating the "Last Updated" date at the top of this document.
• Displaying a clear notice on the surga11 platform regarding the amendments made.
• Send notifications via email or in-platform notices to members affected by the amendment, where the change involves a significant update to how we use your data.

We encourage you to review this Privacy Policy page periodically to stay informed of how surga11 manages your data. Your continued use of the surga11 platform after any amendments are published constitutes your acceptance of the latest version of the Privacy Policy.

If you have any questions, concerns or wish to exercise your rights regarding the personal data surga11 holds about you, please contact us through the following channels:

• Email (Recommended for Privacy Enquiries): support@surga11-jit.com — please include the subject line "Privacy Inquiry" and your account number to help us respond more efficiently. Response time is within 30 calendar days of receipt.
• Live Chat: Available on the surga11 platform 24 hours a day, 7 days a week. Ideal for general enquiries or urgent account-related issues.

Surga11 will handle all privacy-related enquiries seriously and within a reasonable timeframe. Any information you provide when contacting us for privacy purposes will be used solely to address your enquiry or request and will not be used for any other purpose.