Privacy Policy 222bd —
Protection of Your Personal Data

1 Personal Data We Collect

To provide a secure, integrated, and responsible service, 222bd collects several categories of personal data. Below is a summary of the data we collect and the purposes for which it is used:

We do not collect sensitive data such as medical information, religious beliefs, or political views unless required by law in specific cases relating to responsible gambling.

2 How We Collect Your Data

222bd collects your personal data through several different channels:

• Account Registration: Information you provide when registering a new account, including your name, email, phone number, and date of birth.
• KYC Process: Identity verification documents you upload, such as a copy of your national ID or passport, to fulfil the platform's KYC requirements.
• Platform Usage: Data automatically generated when you use the platform, including game records, transactions, and account activity.
• Devices & Browsers: Technical information automatically collected by our systems when you access the platform via a web browser or mobile app.
• Communications: Any information you share when contacting our customer support team via Live Chat, email, or other channels.
• Cookies and Similar Technologies: Data collected through cookies, web beacons, and other tracking technologies as you browse our platform.
• Third-Party Sources: In certain cases related to identity verification and fraud prevention, we may receive information from approved third-party verification service providers.

3 Purpose of Using Your Personal Data

222bd uses your personal data for the following purposes, and only for these purposes:

• Account Management: Creating, verifying, and managing your member account, including secure login processes and two-factor authentication.
• Transaction Processing: Processing deposits, withdrawals, and all financial transactions on the platform accurately and securely.
• Legal Compliance: Meeting applicable legal and regulatory requirements, including anti-money laundering (AML) compliance, KYC requirements, and mandatory financial reporting.
• Platform Security: Detecting and preventing fraud, unauthorised access, account abuse, and other illegal activities.
• Responsible Gaming: Monitoring gaming patterns to identify signs of problem gambling and provide appropriate support to members who need it.
• Service Communications: Sending important notifications relating to your account, such as transaction confirmations, security alerts, and policy updates.
• Marketing (with consent): Sending you relevant promotional information and special offers, subject to your consent which may be withdrawn at any time.
• Service Improvement: Analysing how members use the platform to improve the user experience, technical performance, and game content.
• Customer Support: Handling enquiries, complaints, and support requests effectively using prior interaction history.

We will not use your personal data for any purpose other than those stated above without obtaining your renewed consent or a valid legal basis.

4 Data Sharing with Third Parties

222bd takes a highly cautious approach to sharing member data. We only share your personal data under the following circumstances:

• Trusted Service Providers: Companies that help us operate the platform — including cloud infrastructure providers, payment service providers, and analytics providers — are all subject to strict data protection agreements.
• Game Providers: Gaming companies that provide games on our platform may receive the minimum technical data necessary to ensure the games function correctly and fairly.
• Law Enforcement Agencies: 222bd will disclose information to the relevant authorities when required by a valid court order or applicable law.
• Fraud Prevention: In suspected fraud cases, we may share relevant information with fraud prevention agencies or the financial institutions involved.
• Business Restructuring: Should 222bd be involved in any merger, acquisition, or asset sale, member data may be transferred as part of the transaction, with prior notice given to members.

All third-party service providers handling 222bd member data have undergone a thorough security assessment process and are required to comply with data protection standards equivalent to our own.

5 Cookies & Tracking Technologies

The 222bd platform uses cookies and similar tracking technologies to enhance your experience and ensure the platform functions properly. The following are the types of cookies we use:

• Essential Cookies (Required): These cookies are required for core platform operations such as login session authentication, account security, and payment functionality. The platform cannot function properly without them and they cannot be disabled.
• Performance Cookies: Used to gather information about how visitors use our platform — which pages are visited most frequently, error messages received, and page load performance. All information collected is anonymised.
• Functional Cookies: Enables the platform to remember your preferences such as language, currency, and display settings to deliver a more personalised and consistent experience.
• Marketing Cookies: Used to track your browsing activity for the purpose of displaying more relevant ads and promotions. These cookies require your active consent.

You can manage or disable cookies through your web browser settings at any time. However, disabling essential cookies may affect platform functionality and your gaming experience. Please refer to your browser's documentation for detailed instructions on managing cookies.

6 Data Storage & Security Measures

222bd implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, loss, alteration, or unlawful disclosure:

• 256-bit SSL Encryption: All communications between your device and 222bd's servers are protected with the same advanced encryption used by leading financial institutions.
• Secure Password Storage: Member passwords are never stored in plain text. We use a one-way hashing algorithm with a unique salt for each account.
• Two-Factor Authentication: 222bd provides two-factor authentication (2FA) that members can enable for additional protection during login.
• Internal Access Controls: Only staff with specific authorisation may access member data, and every access is recorded in a comprehensive audit log.
• Regular Security Testing: Our platform undergoes regular penetration testing and security audits conducted by qualified independent parties.
• Data Backup: Member data is automatically backed up to multiple secure locations to ensure service continuity and disaster recovery.

Data Retention Period: 222bd retains your personal data for as long as your account is active and for a specified period after account closure, as follows:

• Financial records and transactions: Minimum 7 years in accordance with Malaysian legal requirements
• KYC and identity verification data: 5 years after account closure
• Customer support communication logs: 3 years
• Anonymised analytics data: No time limit (as it cannot be identified)

7 Your Rights Regarding Personal Data

As a 222bd member, you have the following rights regarding your personal data. We respect and facilitate the exercise of these rights:

• Right of Access: You have the right to request a copy of all personal data we hold about you. This request will be processed within 30 business days.
• Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to request a correction. Basic account information can be updated directly through your profile settings.
• Right to Erasure: Under certain legally permitted circumstances, you may request that we delete your personal data. Please note that some data must be retained in accordance with legal requirements and cannot be deleted upon request.
• Right to Restrict Processing: You may ask us to restrict how we process your data in certain circumstances, for example while you are contesting the accuracy of that data.
• Right to Object: You have the right to object to the processing of your data for direct marketing purposes at any time. This includes opting out of our promotional communications.
• Right to Data Portability: You may request your personal data in a structured, machine-readable format for the purpose of transferring it to another service provider.

To exercise any of the above rights, please contact our customer support team via Live Chat within the 222bd platform or app. We will verify your identity before processing any data-related request to ensure the security of your account.

8 Children's Data & Protection of Minors

222bd strictly prohibits the use of our platform by individuals under the age of 18. This Privacy Policy and all 222bd services are intended for adults only.

• We do not knowingly collect personal data from children or minors.
• All registration applications go through a strict age verification process, including KYC checks.
• Should we discover that personal data has been collected from a minor, we will immediately delete that data and close the account in question.
• Parents or guardians who believe their child has registered or attempted to register on the 222bd platform are requested to contact our customer support immediately.

9 Third-Party Links & Services

The 222bd platform includes integrations with third-party services such as game providers, payment providers, and analytics tools. It is important that you understand the following:

• Each third-party provider integrated with the 222bd platform has its own privacy policy governing their use of data.
• 222bd is not responsible for the privacy practices of third-party providers, although we select partners who comply with strict security standards.
• For payments made via DuitNow, FPX, Touch 'n Go eWallet, GrabPay, and Boost — the respective providers will process your transaction information in accordance with their own privacy policies.
• Third-party game providers that supply games on the 222bd platform may receive the minimum technical data required to ensure smooth gameplay.

We encourage you to read the privacy policies of relevant third-party providers to fully understand how your data is handled within the broader service ecosystem.

10 Changes to This Privacy Policy

222bd reserves the right to update or modify this Privacy Policy at any time. Any changes will take effect immediately upon being posted on this page with the latest update date.

• For significant changes that materially affect how we handle your personal data, we will provide advance notice via email or in-platform notification at least 14 days before the changes take effect.
• Continued use of the 222bd platform after changes to the Privacy Policy are made constitutes your acceptance of the updated terms.
• We encourage you to review this page regularly to stay informed about how we protect your information.