Naga11 Privacy Policy – Personal Data Protection for Malaysian Members

Naga11 collects various types of data depending on how you interact with our platform. Below is a comprehensive summary of the data categories we collect:

Personal data collected by naga11 used solely for legitimate, stated purposes. We do not process your data for any other purpose without obtaining fresh consent from you. Those purposes are:

• Creating and managing member accounts, including identity and age verification.
• Processing deposits and withdrawals via Malaysian payment methods (TNG, DuitNow, GrabPay, Boost, ShopeePay, FPX).
• Providing sports betting, slots, live casino, roulette, and lottery services.
• Managing the VIP rewards programme and awarding appropriate bonuses to eligible members.
• Sending essential operational communications such as transaction confirmations, password resets, and security notices.
• Sending marketing communications (with your consent) regarding naga11 promotions, bonuses, and platform updates.
• Conducting internal analysis to improve user experience and platform products.
• Detecting and preventing fraud, money laundering, and other illegal activities.
• Complying with legal obligations, regulatory directives, and Malaysian court orders.
• Managing customer support and resolving member complaints.

naga11 processes your Personal Data on one or more lawful legal bases under Malaysia's PDPA 2010:

• Consent: By registering and using the platform, you give your consent to naga11 to process your data for the stated purposes.
• Contract Performance: Processing necessary to fulfil our contractual obligations to you — including payment processing and providing the services you signed up for.
• Legitimate Interests: Processing for fraud prevention, platform security enhancement, and internal analytics to improve our services.
• Legal Obligation: Processing required to comply with applicable Malaysian laws, including anti-money laundering legislation.

naga11 may share your Personal Data with a limited and controlled set of third-party categories, and only in the following circumstances:

• Payment Providers: Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and banks offering FPX services — only information necessary to process your transaction is shared.
• Gaming Software Providers: Gaming platform providers partnering with naga11 to deliver slots, live casino, and other games — data is shared in anonymised form wherever possible.
• Malaysian Authorities: Royal Malaysia Police, Bank Negara Malaysia, the Immigration Department, or any other authority when required by law or court order.
• Auditors & Professional Advisors: Accounting, legal, or cybersecurity firms bound by professional confidentiality obligations.

All third parties that receive Personal Data from naga11 are required to sign data processing agreements obligating them to protect that information using security standards at least equivalent to those of naga11. naga11 does not sell members' personal data for advertising or commercial purposes under any circumstances.

In certain operational situations, your Personal Data may be processed or stored on servers located outside Malaysia. This may occur when we use international cloud services or work with global game providers.

• Naga11 ensures that all cross-border data transfers occur only to countries that provide a level of data protection equivalent to or exceeding Malaysia's PDPA standards.
• Comprehensive data transfer agreements are in place with all overseas providers that receive naga11 members' Personal Data.
• Naga11 prioritises the use of servers located in Malaysia or ASEAN regions that maintain robust data protection frameworks.

naga11 retains your Personal Data only for as long as necessary for the stated purposes or as required by applicable law. Our data retention schedule is as follows:

• Active Account Data: Retained for the duration of the active account and 7 years after account closure (in line with Malaysia's financial record-keeping requirements).
• Financial Transaction Records: Minimum 7 years from the transaction date in accordance with the Companies Act and Malaysia's anti-money laundering requirements.
• Support Communication Logs: 3 years from the date of last interaction.
• Technical Log Data: Between 90 days and 12 months, depending on the log type and security requirements.
• Marketing Data: Until you withdraw consent or the account is closed, whichever comes first.

naga11 implements comprehensive technical and organisational security measures to protect your Personal Data against unauthorised access, use, disclosure, alteration, or destruction:

• SSL/TLS 1.3 encryption for all communications between your device and naga11 servers.
• At-rest data encryption using AES-256 for all stored data.
• A layered access control system built on the principle of least privilege — staff may only access data required for their specific job functions.
• Mandatory two-factor authentication (2FA) for all staff accounts with access to member data.
• Periodic security audits and penetration testing by independent third parties.
• 24/7 real-time threat monitoring with automated anomaly detection systems.
• Mandatory cybersecurity training programme for all naga11 staff.
• Documented incident response procedures that are tested on a regular basis.

While we take all reasonable steps to protect your data, no security system is 100% foolproof. In the event of a data breach involving your Personal Data, naga11 will notify you and the relevant authorities within the timeframe required under applicable Malaysian law.

Under Malaysia's PDPA 2010, you have the following rights regarding the Personal Data we hold about you:

To exercise any of the above rights, please contact the Privacy Officer naga11 at privacy@naga11.click or support@naga11.click. We will respond to your request within 21 business days of receipt. Complex requests may take longer, and we will notify you if this is the case.

naga11 uses cookies and similar tracking technologies to enhance your experience on the platform. The types of cookies we use are:

• Essential Cookies: Required for core platform functions such as login, game sessions, and security. Cannot be disabled.
• Performance Cookies: Collects anonymised data on how users interact with the platform for internal improvement purposes. Can be disabled via your browser settings.
• Functional Cookies: Saves your preferences such as language, theme, and display settings. Disabling these cookies may affect your user experience.

You can manage cookie settings through your web browser. Disabling all cookies may affect the functionality of certain parts of the platform naga11. For information on how to manage cookies in popular browsers, please refer to your browser's help documentation.

naga11 strictly does not provide services to individuals under the age of 18. Our platform is not designed for children, and we do not knowingly collect Personal Data from them.

• The registration process includes a strict age verification step — individuals under 18 are unable to complete registration.
• Should naga11 discover that a child's Personal Data has been collected inadvertently, we will delete it immediately.
• Parents or guardians who suspect their child is using the naga11 platform are urged to contact us immediately at support@naga11.click.

naga11 reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or technological developments. Our notification process is:

• Material changes will be notified via email to your registered address at least 30 days before taking effect.
• In-platform notices will be displayed to all active members upon login.
• The "Updated" date at the top of this document will be revised whenever an amendment is made.
• Continued use of the naga11 platform after the effective date of any amendment constitutes acceptance of the updated policy.

If you have any questions, concerns, or wish to exercise your privacy rights, please contact the Data Protection Officer (DPO) naga11 via:

• Privacy Email: privacy@naga11.click — dedicated to privacy and data protection enquiries.
• Support Email: support@naga11.click — for general enquiries including privacy.
• Live Chat: Available 24/7 within the naga11 platform — select the "Privacy & Security" category.

We are committed to responding to all privacy-related enquiries within 21 business days. If you are not satisfied with our response, you have the right to lodge a formal complaint with Department of Personal Data Protection Malaysia under the Ministry of Communications and Digital.