Privacy Policy Bull88 – Personal Data Protection for Malaysian Players

This Privacy Policy ("Policy") is published by Bull88 and applies to all users who access or use the Bull88 digital entertainment platform via the website bull88.click and all associated subdomains. This Policy describes how we collect, use, store, protect, and in certain circumstances disclose your personal information.

Bull88 is an online casino, Sports Betting, digital lottery, and e-sports platform built specifically for the Malaysian market. In the course of our day-to-day operations, we process our players' personal data — and we take that responsibility very seriously. Player trust is our most valuable asset, and protecting your privacy is the foundation of that trust.

This policy should be read in conjunction with the Terms and Conditions Bull88 and Responsible Gaming Policy us. Together, these documents form the complete framework governing your relationship with Bull88.

Bull88 collects various types of information depending on how you interact with our platform. We only collect data that is genuinely necessary for the stated purposes and do not engage in excessive data collection.

Data you provide directly:

• Registration information: Full name (as per MyKad), email address, Malaysian phone number, date of birth and chosen password
• Identity verification (KYC): Copy of MyKad or passport, a selfie for biometric verification, and proof of address if required
• Financial information: Your chosen payment method (Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX Maybank2u, CIMB Clicks), associated e-wallet account IDs, and transaction history
• Communications: Messages you send to our customer support team, feedback submitted, and complaints filed

Automatically collected data:

• IP address and approximate geographic location (city/state level)
• Device type, operating system and web browser used
• Timestamp and duration of each login session
• Pages visited and actions taken within the platform
• Game history — games played, bets placed, wins and losses
• Technical data for troubleshooting and platform improvements

Bull88 uses your personal data for the following purposes, each of which has a valid legal basis:

• Service provision: Opening and managing your account, processing deposits and withdrawals, ensuring access to games and Sports Betting, and completing financial transactions
• Identity verification (KYC): To verify that you are 18 years of age or older, and to confirm your identity in compliance with anti-fraud and anti-money laundering (AML) laws
• Platform security: Detecting and preventing fraud, bonus abuse, multi-account usage and other suspicious activity that could compromise the fairness of the platform for all players
• Customer support: Addressing your inquiries, resolving complaints, and investigating disputes related to game outcomes or financial transactions
• Service communications: Sending important notifications regarding your account, changes to our terms, relevant promotions, and security information
• Platform improvements: Analysing usage patterns in aggregate (not at an individual level) to improve the functionality, performance and user experience of the Bull88 platform
• Legal compliance: Fulfil legal obligations under Malaysia's PDPA, anti-money laundering laws, and any other applicable regulatory requirements

Bull88 does not sell, rent, or trade players' personal data to any third party for their commercial purposes. This is our absolute commitment. However, in the course of running our operations, we do need to share certain data with the following parties under limited and controlled circumstances:

• Payment gateway providers: Required transaction details are shared with certified Malaysian payment gateway providers (Touch 'n Go, GrabPay, DuitNow, FPX, and others) solely for the purpose of processing your financial transactions. These providers maintain their own privacy policies in compliance with Malaysian financial regulations.
• KYC service providers: For identity verification, we may use the services of accredited third-party document verification providers. Such sharing is limited strictly to the information required for verification purposes.
• Relevant authorities: Bull88 will disclose data to Malaysian government authorities when required by law — for example, in investigations involving financial fraud or money laundering. We do not disclose data beyond what is legally required.
• Technical service providers: Companies that provide technical infrastructure to Bull88 (such as cloud computing services) may have limited access to data for technical maintenance purposes only, and are bound by strict confidentiality agreements.

In all cases where data is shared, Bull88 ensures that recipients are bound by confidentiality obligations equal to or greater than our own, and that data is used solely for its intended, authorised purpose.

Bull88 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure or destruction:

• 256-bit SSL Encryption: All data transmitted between your device and bull88's servers is encrypted using the latest SSL/TLS protocols — the same standard used by Malaysian banking institutions
• Data encryption at rest: Sensitive data stored in our databases is encrypted using industry-standard encryption algorithms
• Multi-layered access controls: Only authorised staff with a legitimate business need may access player data, and all access is logged for audit purposes
• Two-factor authentication (2FA): Our internal systems require 2FA for all staff access to player data
• Continuous monitoring: An intrusion detection system (IDS) operates around the clock to identify suspicious activity
• Regular security testing: bull88 conducts regular penetration testing and security audits carried out by independent security experts

Bull88 retains your personal data only for as long as necessary for the purposes described in this Policy, or as required by Malaysian law:

• Active account data: Retained for as long as your account remains active and in use
• KYC and identity verification records: Retained for a minimum of 7 years after account closure, as required under Malaysian anti-money laundering laws
• Financial transaction records: Retained for a minimum of 7 years for compliance with Malaysian accounting and tax laws
• Game history: Retained for a minimum of 3 years for audit and dispute resolution purposes
• Support communication logs: Retained for 2 years after the case is resolved
• Live dealer session recordings: Retained for a minimum of 90 days

Once the retention period expires or you request deletion of your data (and no legal obligation requires us to retain it), Bull88 will securely delete or anonymise the data in question.

Bull88 uses cookies and similar tracking technologies to enhance your experience on our platform. The following are the types of cookies we use:

• Essential cookies (required): Required for core platform functions such as maintaining your login session, remembering your language preference and other essential settings. These cookies cannot be disabled without affecting platform functionality.
• Performance cookies: Collects information on how pages are used to help us improve the platform. All data is aggregated and cannot be used to identify you individually.
• Functional cookies: Remembering your preferences (such as display settings and account configurations) to deliver a more personalised experience.

You can manage cookies through your web browser settings. However, disabling essential cookies may affect the functionality of the Bull88 platform. Bull88 does not use third-party cookies for cross-site advertising purposes.

Malaysia's Personal Data Protection Act 2010 (PDPA) grants you specific rights regarding your personal data. Bull88 respects and facilitates the exercise of all these rights:

• Right of access: Request a copy of the data we hold about you
• Right to rectification: Correct inaccurate or incomplete information
• Right to object: Object to the processing of your data for direct marketing purposes
• Right to erasure: Request deletion of your data under circumstances specified by law
• Right to portability: Receive your data in a machine-readable format

To exercise any of these rights, contact us at support@bull88.click with the subject line "PDPA Rights Request", along with your full name and account number. We will verify your identity and process the request within 14 business days.

In some cases, your personal data may be transferred to or stored on servers located outside Malaysia — for example, when we use cloud computing services that operate across multiple countries. Bull88 ensures that any such data transfers comply with Malaysia's PDPA requirements and are made only to countries or recipients that provide an equivalent or higher level of data protection.

For all cross-border data transfers, bull88 implements appropriate safeguards such as legally binding data processing agreements with service providers, ensuring data remains encrypted both in transit and at rest, and restricting data access strictly to personnel with a legitimate business need.

Bull88 may update this Privacy Policy from time to time to reflect changes in our practices, technological developments, new legal requirements or player feedback. When we make significant changes, we will:

• Displaying a clear notice on the Bull88 platform homepage
• Sending notification emails to all registered players
• Updating the "Last Updated" date at the top of this Policy

We encourage you to review this Privacy Policy periodically. Your continued use of the Bull88 platform after any changes take effect constitutes your acceptance of the updated version. If you do not agree with any changes, please close your account and contact us to request data deletion.

For any questions, concerns or requests regarding this Privacy Policy or how Bull88 handles your personal data, please contact us via:

• Live Chat: Within the bull88 platform — response within 5 minutes, 24 hours a day, 7 days a week
• Email: support@bull88.click — with the subject line "Privacy Policy Enquiry"

Our team communicates in both Bahasa Malaysia and English. For formal PDPA requests such as data access or erasure, please clearly state the type of request and include your Bull88 account number to help us process it faster.