Nego77 Privacy Policy – How We Protect the Personal Data of Every Malaysian Member

This Privacy Policy ("Policy") describes how nego77 ("we", "Platform") collects, uses, stores, and protects your personal information when you register for and use services at nego77.wine. This Policy applies to all members and visitors of the nego77 platform, regardless of how they access it — whether via web browser or mobile device.

Nego77 is committed to managing your personal data transparently, responsibly, and in line with industry best practices for data protection. We wrote this policy in plain, easy-to-understand language because we believe every member deserves to know exactly what happens with their information.

1. Personal Data We Collect

Nego77 collects various types of information depending on how you interact with our platform. Below are the categories of data we collect and the purposes for which they are used:

Nego77 collects this data through a variety of means: registration forms you complete, transactions you carry out, your interactions with the platform, cookies and similar tracking technologies, and in some cases, from legitimate third-party sources for identity verification purposes.

2. How nego77 Uses Your Personal Data

Nego77 uses the personal data collected for legitimate and specific purposes. We do not use your data for anything unrelated to the services you signed up for. The following are the primary purposes for which your data is used:

1. Platform Service Provision: To create and manage your nego77 account, process deposits and withdrawals, grant access to all game categories — Live Matches, E-Sports, Virtual Sports, Live Casino, and Jackpot Slots — and provide effective customer support.
2. Identity Verification & Fraud Prevention: To verify your identity in accordance with KYC requirements, and to detect and prevent fraudulent activity, money laundering, and any misuse of the platform that could compromise the safety of other members.
3. Payment Processing: To process deposit transactions via Touch 'n Go eWallet, DuitNow, FPX, GrabPay, Boost, ShopeePay, Maybank2u, and CIMB Clicks — and to handle your withdrawal requests quickly and securely.
4. Service Communications: To send you important account-related notifications such as deposit confirmations, withdrawal alerts, security updates, and changes to terms or policies that affect you.
5. Marketing Communications (with consent): To keep you informed about the latest promotions, new bonuses, and exclusive nego77 offers — but only where you have given your consent to receive such communications. You may withdraw this consent at any time.
6. Responsible Gaming: To monitor gaming patterns in order to identify potential issues related to unhealthy betting habits, and to provide appropriate tools and support to members who need them.
7. Legal Compliance: To fulfil legal and regulatory obligations and to comply with directives from relevant authorities in connection with the operation of the nego77 platform.

Nego77 only processes your personal data where there is a valid legal basis for doing so — whether that is contractual necessity, a legal obligation, legitimate interest, or your explicit consent.

3. Sharing Data with Third Parties

Nego77 does not share your personal data with third parties except in the limited circumstances set out below. In all cases, data sharing is restricted to what is strictly necessary and is subject to rigorous data protection agreements:

• Payment Service Providers: Required transaction details are shared with the payment provider used (Touch 'n Go, DuitNow, FPX, GrabPay, Boost, ShopeePay, Maybank2u, CIMB Clicks) to process your deposits and withdrawals. These providers are bound by strict confidentiality agreements and industry security standards.
• Game Providers: Minimal gaming information required is shared with slot and live casino providers such as PG Soft, Pragmatic Play, Spadegaming, and Microgaming to deliver a seamless gaming experience and to verify game outcomes.
• Identity Verification Provider: For KYC purposes, nego77 uses certified third-party identity verification services. Information shared is limited strictly to what is required for verification.
• Legal Authorities: nego77 may disclose personal data to law enforcement agencies, courts, or regulatory bodies where required by law or a valid court order.
• Independent Auditors: For fair game auditing and compliance purposes, certain technical information may be shared with certified auditors responsible for verifying the integrity of the nego77 platform.

4. nego77's Data Security Measures

Nego77 continually invests in security infrastructure to ensure members' personal data remains protected at the highest level. The following are the layers of protection we have in place:

• 256-bit SSL Encryption: All communication between your browser or app and the nego77 servers is encrypted using TLS 1.3 with a 256-bit encryption key. This means data transmitted from your phone or computer to our servers cannot be read by any unauthorised party, even if they manage to intercept the connection.
• Layered Access Controls: Access to members' personal data within the nego77 system is restricted to staff who genuinely require it to perform their duties. All access is logged and audited on a regular basis.
• 24/7 Security Monitoring: nego77's cybersecurity team monitors systems continuously around the clock to detect any suspicious activity, intrusion attempts, or anomalies that may indicate a security threat.
• Regular Security Testing: nego77 conducts regular penetration testing and vulnerability assessments by independent parties to identify and address any security weaknesses before they can be exploited.
• Two-Factor Authentication: nego77 offers two-factor authentication (2FA) as an added layer of security during login. We encourage all members to enable this feature in their account security settings.
• Incident Response Plan: nego77 has clear procedures in place for responding to data security incidents. In the event of a data breach affecting members, we are committed to notifying affected members within a reasonable timeframe.

While nego77 takes all reasonable steps to protect your data, no system can be guaranteed 100% secure against every possible threat. We therefore also encourage members to take their own security precautions — such as using strong passwords, not sharing login credentials, and keeping their devices up to date.

5. Cookies & Tracking Technologies

Nego77 uses cookies and similar tracking technologies to enhance your experience on the platform. The following are the types of cookies we use:

Cookies required for the security and core functionality of the platform are enabled by default and cannot be disabled without affecting platform performance. For analytics and preference cookies, you can manage your cookie settings through your web browser settings. Please note that disabling all cookies may affect your experience on the nego77 platform.

6. Your Rights as a Data Subject

As a nego77 member and the owner of your personal data, you have clear rights that we fully respect. These rights include:

• Right to Access: You have the right to request a copy of all personal data nego77 holds about you. Simply send an email to support@nego77.wine and we will provide your data in a readable format within 14 business days.
• Right to Rectification: If you believe the personal data we hold about you is inaccurate or out of date, you have the right to request a correction. For basic account details such as your phone number and email address, you can update these directly in your nego77 account settings. For all other information, please contact our support team.
• Right to Erasure: Under certain circumstances, you have the right to request the deletion of your personal data — commonly known as the "right to be forgotten". nego77 will assess such requests in accordance with applicable legal obligations. For instance, transaction records may need to be retained for a specified period for legal purposes, even after a deletion request has been made.
• Right to Object to Processing: You have the right to object to the processing of your personal data for direct marketing purposes at any time. Once your objection is received, nego77 will immediately cease using your data for that purpose.
• Right to Data Portability: You have the right to receive the personal data you have provided to nego77 in a structured, electronically readable format, and to transfer that data to another operator if you wish.
• Right to Withdraw Consent: Where data processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of any processing that took place prior to the withdrawal.

To exercise any of the rights above, please submit a written request to the nego77 privacy team at support@nego77.wine by clearly stating the right you wish to exercise and the relevant details. We will acknowledge receipt of your request within 2 business days.

7. Data Retention & Deletion

Nego77 retains your personal data only for as long as necessary for the purposes outlined in this policy, or as required by applicable law. The following are general guidelines on data retention periods:

• Active Account Data: For as long as your nego77 account remains active. After account closure, data is retained for an additional period as required by law.
• Financial Transaction Records: A minimum of 7 years from the transaction date, in line with Malaysian legal requirements governing financial records and anti-money laundering compliance.
• Identity Verification (KYC) Records: A minimum of 5 years after account closure, or longer if required by the relevant authorities.
• Communication & Support Logs: 3 years from the date of last interaction, for dispute resolution and service improvement purposes.
• Analytics & Statistical Data: Anonymised analytics data (i.e. data that cannot be traced back to any individual) may be retained for longer periods for research and platform improvement purposes.

Once the applicable retention period has expired, nego77 will securely delete or anonymise your data using certified data deletion procedures to ensure it cannot be recovered by any party.

8. Contact the nego77 Privacy Team

For any questions, concerns, or requests regarding this Privacy Policy or nego77's management of your personal data, you may reach our privacy team through the following channels:

• Email: support@nego77.wine (include "Data Privacy Request" in the email subject line for faster processing)
• Live Chat: Via the live chat button on the nego77 platform, available 24 hours a day, 7 days a week

Nego77 is committed to responding to all privacy-related enquiries within 5 business days and to resolving data requests within 14 business days from the date a complete request is received.

9. Children's Privacy & Protection of Young Users

Nego77's services are exclusively for individuals aged 18 and above. nego77 does not knowingly collect or process personal data from children or minors. We take active steps to prevent underage access through a strict age verification process during registration.

If nego77 discovers that personal data belonging to an individual under the age of 18 has been collected without proper age verification, the account in question will be closed immediately and all personal data belonging to that individual will be deleted from our systems as quickly as is reasonably practicable.

If you are a parent or guardian who believes your underage child has registered an account with nego77 without your knowledge, please contact our support or privacy team immediately at support@nego77.wine. We will act promptly to close the account and delete the associated data.

10. Amendments to This Privacy Policy

Nego77 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or member feedback. When we make material changes to this Policy:

• The "Updated" date at the top of this policy will be changed to reflect the date of the latest amendment.
• An email notification will be sent to all active members to inform them of any significant changes at least 7 days before those changes take effect.
• In-platform notifications will be displayed to ensure members are aware of upcoming amendments.
• The latest version of this Privacy Policy is always available at nego77.wine/privacy-policy.

Continued use of the nego77 platform after the effective date of any amendments constitutes acceptance of the updated policy. If you do not agree with any of the changes, you have the right to close your account and request data deletion before the effective date.