Privacy Policy CMD77 – Malaysia User Data Protection

1 Policy Introduction & Scope

This Privacy Policy is issued by CMD77 and applies to all users who access or use the CMD77 online gaming platform via the website cmd77.onl or the official cmd77 mobile app on Android and iOS devices.

We understand that privacy is a matter of great importance to users in Malaysia. Your trust is our most valued asset, and we take this responsibility with the utmost seriousness. By using the CMD77 platform, you agree to the data collection and processing practices described in this document.

---

2 Personal Data We Collect

CMD77 collects users' personal data through several channels — during account registration, platform usage, identity verification (KYC), and interactions with our customer support team. Below is a summary of the types of data collected:

CMD77 only collects data that is strictly necessary for the stated purposes and does not collect excessive or irrelevant data beyond what is required for platform operations.

---

3 How We Use Your Data

Personal data collected by CMD77 is used solely for the following purposes:

• Account management — creates, verifies, and maintains your user account.
• Transaction processing — processes deposits, withdrawals, and bonus payments accurately and securely.
• Identity verification (KYC) — complies with legal requirements related to anti-money laundering (AML) and know your customer (KYC).
• Platform security — detects and prevents fraud, unauthorised access, and system abuse.
• Customer Support — helps you resolve technical issues, account enquiries, and complaints.
• Service improvement — analyses usage patterns to enhance the overall user experience.
• Account-related communications — sends important notices such as transaction confirmations, security updates, and promotional alerts (with your consent).
• Legal compliance — fulfils applicable reporting obligations and regulatory requirements.

---

4 Data Sharing with Third Parties

CMD77 does not share, sell, or disclose users' personal data to third parties except in the following limited circumstances:

• Payment service providers — approved payment gateway providers such as FPX, Touch 'n Go, GrabPay, and crypto providers that process your financial transactions. They are bound by strict data confidentiality agreements.
• Game software providers — licensed game software companies providing gaming content on the cmd77 platform may receive limited game transaction data for game integrity purposes.
• Competent authorities — cmd77 will disclose required data to legal or law enforcement authorities if ordered by a court or legitimate government agency.
• Internal technical services — cloud and technical infrastructure service providers supporting cmd77 platform operations, subject to strict data processing agreements.

All third parties granted access to cmd77 user data are required to comply with data protection standards at least equivalent to those we uphold.

---

5 Cookies & Tracking Technologies

CMD77 uses cookies and similar tracking technologies to enhance the user experience on our platform. Cookies are small text files stored on your device when you visit our website.

The types of cookies used by CMD77 are as follows:

• Essential Cookies — required for core platform functions such as login, session management, and security. These cookies cannot be disabled.
• Functional Cookies — stores user preferences such as language, time zone, and display settings for a more personalised experience.
• Analytics Cookies — helps us understand how users interact with the platform for service improvement purposes. This data is collected in aggregate and anonymised form.
• Security Cookies — used to detect suspicious activity, prevent fraud, and protect the integrity of user accounts.

You can manage your cookie settings through your web browser. However, disabling essential cookies may affect the functionality of the CMD77 platform.

---

6 Data Security & Protection Measures

CMD77 continuously invests in the latest cybersecurity infrastructure to ensure users' personal data is protected at all times. Key security measures we implement include:

• Data encryption in transit using TLS 1.3 and SSL 256-bit protocols.
• At-rest encryption for all sensitive data stored in our databases.
• Role-based access control (RBAC) ensuring only authorized personnel can access user data.
• Regular security audits by independent third parties to identify and address vulnerabilities.
• Real-time threat monitoring system operating 24/7.
• Two-factor authentication (2FA) available for all user accounts.
• A comprehensive incident response plan to address any data breaches promptly.

---

7 Data Retention Period

CMD77 retains users' personal data only for as long as necessary to fulfil the original purpose of collection or as required by law. Below are our data retention guidelines:

• Active account data — retained for the duration of the active account and up to 5 years after account closure for legal compliance purposes.
• Financial transaction records — retained for a minimum of 7 years in compliance with Malaysia's accounting and anti-money laundering legal requirements.
• KYC Documents — retained for the duration of the active account and 5 years after account closure.
• Support communication logs — retained for 2 years from the date of last interaction.
• Technical data and security logs — retained for 12 months for fraud detection and system security purposes.

Once the retention period expires, data will be securely deleted or anonymised using industry-recognised methods.

---

8 User Rights Regarding Personal Data

As a cmd77 user, you have several rights regarding your personal data guaranteed under Malaysia's Personal Data Protection Act 2010 (PDPA):

• Right of Access — you may request a copy of the personal data we hold about you at any time.
• Right to Rectification — you may request correction of inaccurate or incomplete data through account settings or by contacting our support team.
• Right to Erasure — you may request deletion of your personal data, subject to our legal obligations to retain certain records.
• Right to Restriction of Processing — you may request that we restrict the processing of your data under certain circumstances.
• Right to Object — you may object to the processing of your data for direct marketing purposes at any time.
• Right to Data Portability — you may request your data in a machine-readable format for transfer to another service provider.

To exercise any of the above rights, please contact the cmd77 support team via the platform's Live Chat or by email at [email protected]. We will process your request within 14 business days.

---

9 Children's Privacy

The cmd77 platform is exclusively for individuals aged 18 and above. cmd77 does not intentionally collect any personal data from minors. Should we become aware that a child's data has been inadvertently collected, we will take immediate steps to delete that data and close the associated account.

If you believe your child or any minor has registered an account at cmd77, please contact us immediately via email [email protected] so we can take the appropriate action.

---

10 Links to Third-Party Websites

The cmd77 platform may contain links to third-party websites or services that operate independently of cmd77. This Privacy Policy does not cover the privacy practices of those websites. cmd77 is not responsible for the content or privacy practices of any third-party website.

We recommend reading the privacy policy of any third-party website you visit before providing them with any personal information.

---

11 Contact Our Privacy Officer

For any enquiries, complaints, or requests related to cmd77's Privacy Policy or the processing of your personal data, you may reach us through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 on the cmd77 platform or app.
• FAQ: Visit FAQ page for an immediate response.

We are committed to responding to all privacy-related enquiries within 3 business days. For more complex complaints, the full response period is 14 business days.