Privacy Policy — palamis77

1 Introduction

This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal data by palamis77 ("we", "us", "our", "the Company") in connection with your access to and use of the palamis77 online gaming platform, accessible at palamis77.cam and any associated mobile applications or sub-domains (collectively, the "Platform").

palamis77 is committed to protecting the personal data of all registered users, including players based across Malaysia — from Kuala Lumpur and Petaling Jaya to Penang, Johor Bahru, Shah Alam, and beyond. We process personal data responsibly, transparently, and in accordance with applicable data protection legislation, including the Personal Data Protection Act 2010 (Malaysia) ("PDPA") and any other applicable regulations governing data processing in the jurisdictions in which we operate.

By registering an account or using the palamis77 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy was last revised on 1 January 2026 and supersedes all prior versions.

2 Definitions

In this Policy, the following definitions apply:

• "Personal Data" — any information relating to an identified or identifiable natural person ("Data Subject").
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, and deletion.
• "Data Controller" — palamis77, the entity that determines the purposes and means of Processing Personal Data.
• "Data Processor" — any third party that processes Personal Data on behalf of palamis77 under a contractual arrangement.
• "User" / "you" — any individual who accesses or registers an account on the palamis77 Platform.
• "KYC" — Know Your Customer verification procedures, including identity and age verification.
• "Cookies" — small text files placed on your device by the Platform to facilitate functionality and analytics.
• "PDPA" — Malaysia's Personal Data Protection Act 2010, which regulates the processing of personal data in commercial transactions.

3 Personal Data We Collect

palamis77 collects personal data in the following categories, depending on how you interact with the Platform:

3.1 Registration Data

When you create an Account, we collect the information you provide, including:

• Full legal name as it appears on your government-issued identity document;
• Date of birth (for age verification — 21+ policy strictly enforced);
• Email address and contact telephone number;
• Residential address, including postcode and state within Malaysia;
• Username and encrypted password credentials.

3.2 KYC and Verification Data

For Know Your Customer compliance, we collect documentary evidence including:

• Copy of government-issued photo identification (Malaysian MyKad, passport);
• Proof of residential address (utility bill, bank statement dated within 3 months);
• Proof of payment method (e-wallet screenshot, bank statement);
• Source of funds declaration where required by AML thresholds.

3.3 Transaction and Financial Data

When you make deposits or request withdrawals, we process transactional data including:

• Deposit and withdrawal amounts in Malaysian Ringgit (MYR);
• Payment method identifiers (e-wallet reference, bank account suffix — we do not store full payment credentials);
• Transaction timestamps and processing status;
• Bonus credits claimed and wagering activity records.

3.4 Technical and Usage Data

We automatically collect technical data during your use of the Platform:

• IP address and approximate geographic location;
• Browser type, version, and operating system;
• Device identifiers (for fraud prevention and session management);
• Pages visited, session duration, and interaction data;
• Game play history, betting patterns, and session logs.

3.5 Communications Data

When you contact our support team via live chat or email, we retain records of those communications, including the content, timestamps, and resolution outcomes, for quality assurance and dispute resolution purposes.

4 How We Use Your Personal Data

The table below summarises the primary purposes for which palamis77 processes your personal data and the lawful basis for each:

palamis77 does not use personal data for any purpose that is incompatible with those listed above. Where we intend to process data for a new purpose, we will update this Policy and, where required, seek fresh consent.

5 Legal Basis for Processing

palamis77 processes personal data on the following legal bases under applicable data protection law, including the Malaysian PDPA:

• Contractual Necessity: Processing required to perform the services you have registered for, including account management, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable laws, including AML, KYC, responsible gambling, and tax reporting obligations.
• Legitimate Interest: Processing necessary for our legitimate business interests — including fraud prevention, security, analytics, and platform improvement — where those interests are not overridden by your fundamental rights.
• Consent: Processing for purposes such as direct marketing communications, where we have obtained your prior explicit consent. You may withdraw consent at any time by contacting our support team.

6 Data Sharing and Disclosure

palamis77 does not sell, rent, or trade your personal data to third parties. We may share personal data in the following limited circumstances:

6.1 Service Providers and Data Processors

We engage third-party service providers who process personal data on our behalf under strict contractual data processing agreements. Categories include:

• Payment processing partners supporting Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, and related Malaysian financial service providers;
• KYC and identity verification service providers;
• Cloud infrastructure and hosting providers;
• Analytics and fraud detection platform providers (processing aggregated or pseudonymised data);
• Customer support platform providers.

All Data Processors are contractually bound to process personal data only on our documented instructions and to implement appropriate security measures.

6.2 Regulatory and Legal Disclosure

We may disclose personal data to regulatory authorities, law enforcement agencies, or courts where required by applicable law, court order, or regulatory directive. Such disclosures are made only to the extent strictly necessary to comply with the applicable obligation.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of palamis77's business, personal data held by the Company may be transferred to the acquiring entity as part of that transaction. We will notify registered users of any such transfer via the email address on file prior to completion where practicable.

7 Data Retention

palamis77 retains personal data for as long as is necessary to fulfil the purposes for which it was collected and to meet applicable legal, regulatory, and operational obligations. General retention guidelines are as follows:

• Account data and KYC records: Retained for a minimum of five (5) years following account closure, in accordance with AML and regulatory requirements.
• Transaction records: Retained for a minimum of seven (7) years for financial compliance and tax reporting purposes.
• Support communications: Retained for two (2) years from the date of last interaction, for quality assurance and dispute resolution purposes.
• Technical and usage data (non-aggregated): Retained for up to twelve (12) months, after which it is aggregated or deleted.
• Marketing preferences and consent records: Retained until you withdraw consent or request deletion, plus a short record-keeping period thereafter.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data destruction procedures.

8 Cookies and Tracking Technologies

palamis77 uses cookies and similar tracking technologies on the Platform to support functionality, improve performance, and analyse user behaviour. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for platform operation — session authentication, security tokens, load balancing. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences such as language settings, interface customisations, and game display preferences.
• Analytics Cookies: Collect aggregated, anonymised usage data to help us understand how users navigate the Platform and identify areas for improvement.
• Security Cookies: Used for fraud detection, suspicious activity monitoring, and session integrity validation.

You may manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality. palamis77 does not use third-party advertising or retargeting cookies.

9 Your Rights as a Data Subject

Under applicable data protection law, including the Malaysian PDPA, you have the following rights in relation to your personal data held by palamis77:

• Right of Access: You may request a copy of the personal data we hold about you. We will respond to such requests within thirty (30) days.
• Right to Correction: You may request correction of inaccurate or incomplete personal data. For account details, many corrections can be made by contacting our support team directly.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations (e.g., AML record-keeping requirements which may prevent full erasure for up to 7 years).
• Right to Restrict Processing: You may request that we restrict the processing of your data in certain circumstances, such as while a correction request is being assessed.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request a machine-readable copy of the personal data you provided to us.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Complain: If you believe your data has been processed unlawfully, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

To exercise any of the above rights, please contact us via live chat or email as set out in Section 13 of this Policy. We may request verification of your identity before processing a data subject request.

10 Data Security

palamis77 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, loss, destruction, or disclosure:

• All data transmitted between your device and the Platform is encrypted using industry-standard 256-bit TLS/SSL protocols;
• Account passwords are stored using one-way cryptographic hashing — palamis77 staff cannot view your password;
• Two-factor authentication (2FA) is available on all accounts and strongly recommended;
• Access to personal data within the Company is restricted on a need-to-know basis, with access logs maintained and reviewed regularly;
• Platform infrastructure undergoes regular independent security assessments and penetration testing;
• Our data breach response procedures comply with applicable notification timelines under PDPA and other applicable law.

11 Minors and Age Policy

palamis77 is strictly for adults. Our platform is available only to persons who are 21 years of age or older. We do not knowingly collect or process personal data from individuals under the age of 21.

Age verification is performed as part of our KYC process. If we become aware that personal data has been submitted by an individual under 21, we will promptly delete that data and close the associated account, retaining only such records as are required for legal compliance purposes.

If you are a parent or guardian and believe that a minor under your care has registered an account or submitted personal data to palamis77, please contact our support team immediately via live chat so we can investigate and take appropriate action.

12 Amendments to This Policy

palamis77 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or operational requirements. Material changes will be communicated to registered users via their registered email address or via a prominent notice on the Platform prior to taking effect.

The "Last updated" date at the top of this document will always reflect the date of the most recent revision. Your continued use of the Platform following notification of any amendment constitutes your acceptance of the revised Policy. If you do not agree with an amendment, you should discontinue use of the Platform and may request account closure through our support team.

13 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by palamis77, please contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly on the Platform. This is the fastest way to reach our data protection team.
• Email: [email protected] — please include "Privacy Request" in your subject line for fastest routing.

Data subject requests will be acknowledged within 3 business days and responded to in full within 30 days of receipt, in line with PDPA obligations. We may request proof of identity before processing any access, correction, or erasure request.