739 Privacy Policy — Malaysian User Personal Data Protection

1Privacy Policy Introduction and Scope

This Privacy Policy applies to all users who access or use the 739 platform, including visitors without an account, registered members, and users of the 739 mobile app. It covers all information collected through the website, app, customer support channels, and any other interactions with our platform.

739 acts as the responsible data controller for all personal information collected within the scope of this platform's operations. We appoint an internal Data Protection Officer (DPO) to ensure ongoing compliance with the PDPA and relevant privacy regulations.

• This Policy applies to all 739 digital platforms, including the website and iOS and Android apps.
• This Policy not apply to third-party websites or services that may be linked from the 739 platform.
• In the event of any conflict between the Bahasa Melayu version and other translations, the Bahasa Melayu version shall prevail.

2Personal Information We Collect

739 collects various types of personal information when you register, use the platform, or interact with our support team. We only collect information that is genuinely necessary to provide you with a safe and quality service.

We may also receive information about you from legitimate third-party sources, such as identity verification providers or anti-fraud agencies, for security and legal compliance purposes.

3How We Use Your Information

Every piece of information we collect has a clear and lawful purpose. 739 uses your personal information solely for the following purposes and will not use it beyond the defined scope without your consent:

• Account Management: Create and maintain your account, process registration and verify identity through the KYC process.
• Transaction Processing: Process deposits, fund withdrawals and all financial transactions related to your account on the 739 platform.
• Platform Security: Detect and prevent fraud, money laundering, unauthorised access and other suspicious activities that could compromise the security of the platform or other users.
• Service Communications: Send important notifications regarding your account, transactions, terms changes and security updates.
• Customer Support: Helps resolve inquiries, complaints and technical issues reported by you.
• Platform Improvement: Analyse usage patterns in aggregate (without identifying individuals) to improve features, performance and the overall user experience.
• Relevant Marketing: Send relevant promotional information and offers — only if you have given consent, and you may unsubscribe at any time.
• Legal Compliance: Fulfil legal obligations, financial regulations and directives from relevant authorities.

4Information Sharing and Disclosure

739 does not sell, rent, or trade your personal information to any third party for marketing purposes. However, there are specific situations where we need to share your information with selected and trusted parties:

• Service Providers: Payment providers (FPX, DuitNow, eWallet), KYC verification companies, and technical infrastructure providers that help us operate the platform — all subject to strict confidentiality agreements.
• Regulatory Authority: Law enforcement agencies, financial regulatory bodies, or courts when required by law or court order.
• Fraud Prevention: Anti-fraud agencies and industry security information-sharing platforms to protect the integrity of the online gaming ecosystem.
• Business Transfers: In the event of a merger, acquisition, or sale of company assets, user information may be transferred as part of the business assets — with appropriate notice provided to you.

5Data Security Measures

The security of your personal data is an absolute priority for 739. We implement multiple layers of technical and organisational security controls to protect your information from unauthorised access, loss, misuse or disclosure.

• Data Encryption: All sensitive data is encrypted using 256-bit SSL/TLS protocols during transmission and AES-256 during storage.
• Access Control: Access to users' personal data is restricted to authorised 739 staff only, on a need-to-know basis.
• Periodic Audits: Our security systems are regularly audited by independent third parties to identify and address any vulnerabilities.
• 24/7 Monitoring: Automated monitoring systems operate around the clock to detect suspicious activity and intrusion attempts.
• Two-Factor Authentication: Two-factor authentication (2FA) is available and encouraged for all user accounts as an added layer of security.

In the event of any security incident affecting your data, 739 is committed to notifying affected users within the timeframe required by applicable law.

6Cookies and Tracking Technologies

The 739 platform uses cookies and similar tracking technologies to enhance the user experience, maintain login session security, and understand overall platform usage patterns.

• Essential Cookies: Required for core platform functions such as login, session security, and language preferences. Cannot be disabled without affecting platform functionality.
• Analytics Cookies: Helps us understand how users interact with the platform — data is collected in aggregate and without identifying individuals.
• Preference Cookies: Save your settings and preferences so your experience is smoother every time you visit the platform.

You can control and manage cookies through your web browser settings. However, disabling essential cookies may affect certain functions of the 739 platform. Note: we do not use third-party cookies for targeted advertising.

7Your Rights as a User

Under Malaysia's PDPA and 739's Privacy Policy, you have several important rights regarding your personal data. We fully respect these rights and will handle every request with care:

8Data Storage and Retention Period

739 retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy or as required by applicable Malaysian law.

• Active Account Data: Retained for as long as your account remains active on the 739 platform.
• Financial Transaction Data: Retained for a minimum of seven (7) years as required by Malaysian financial regulations.
• Communication Records: Retained for two (2) years from the date of communication for dispute resolution purposes.
• Closed Account Data: Following account closure, the minimum data required for legal compliance is retained, while other data is deleted within 90 days.
• KYC Data: Retained for five (5) years after account closure in line with anti-money laundering (AML) requirements.

Once the retention period expires, your data will be securely deleted or dissociated from any personally identifiable information.

9Children's Privacy and Protection of Minors

The 739 platform is for individuals aged 18 years and above only. We do not intentionally collect or process personal data from children or individuals below the specified age limit.

If we determine that personal data of an individual under 18 has been collected without parental or guardian knowledge or consent, we will take immediate steps to delete that information and close the relevant account.

10Changes to This Privacy Policy

739 reserves the right to amend or update this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, or new platform features. Any changes will be published on this page along with the new effective date.

For significant changes, we will notify you via in-account notification or your registered email at least seven (7) days before the changes take effect. Continued use of the 739 platform after the effective date constitutes acceptance of the updated Privacy Policy.

11Contact Us Regarding Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 739, our data protection team is ready to assist you.

• Data Protection Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat icon on the 739 platform
• Response Time: We aim to respond to all privacy enquiries within three (3) business days.