Surg11 Privacy Policy — Data Protection Malaysia Users

To provide you with the best service, surg11 collects certain categories of personal information when you use our platform. This collection is carried out transparently and solely for the purposes stated in this policy.

We only collect information that is genuinely necessary for platform operations. You are not required to provide information beyond what is needed for basic registration.

The personal data we collect is used solely for legitimate purposes related to surg11's operations. The following is a complete list of the purposes for which your data is used:

• Creating and managing user accounts and identity verification (KYC).
• Processing deposits, withdrawals and all financial transactions securely.
• Providing effective customer support when you contact us.
• Sending important notifications relating to your account, transactions or policy changes.
• Monitoring and preventing fraudulent activity and money laundering.
• Improving the user experience based on platform usage patterns.
• Complying with applicable legal and regulatory obligations.
• Sending relevant promotional offers — only if you have consented to receive marketing communications.

Surg11 does not share your personal information with third parties for marketing or commercial purposes. However, there are limited situations where data sharing is necessary for platform operations:

• Payment Service Providers: Transaction information is shared with authorised payment gateways to process your deposits and withdrawals. These providers are bound by strict confidentiality agreements.
• Legal Authorities: surg11 will disclose information to the authorities if required by law or a valid court order.
• Technology Providers: Some third-party technology providers we use for platform operations may have limited access to the data required solely for their functions.
• Independent Audit: Independent audit bodies that verify the fairness of our games may have access to the technical data required for audit purposes only.

• surg11 does not sell your personal data to any third party.
• We do not share data for third-party advertising purposes.
• Your data will not be transferred without appropriate safeguards in place.

Surg11 continuously invests in security infrastructure to ensure your data is always protected. Below are the technical and organisational measures we practise:

• 256-bit SSL/TLS encryption for all communications between your browser and our servers.
• Encryption at rest for all sensitive information stored in the database.
• Two-factor authentication (2FA) is available for all user accounts.
• 24/7 real-time security monitoring to detect suspicious activity.
• Regular security audits conducted by internal and external security teams.
• Role-based access control — staff may only access data required for their specific duties.
• A clear incident response procedure to promptly address any data breaches.

Surg11 uses cookies and similar tracking technologies to enhance your experience and ensure the platform functions properly. Below are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login sessions and security. Cannot be disabled.
• Performance Cookies: Helping us understand how users interact with the platform for improvement purposes.
• Preference Cookies: Remembering your settings and preferences to provide a more personalised experience.
• Analytics Cookies: Collecting aggregated usage data (without identifying individuals) for platform analysis and improvement.

You can manage cookie settings through your browser preferences. Disabling certain cookies may affect the functionality of some platform features.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have various rights regarding your personal data held by surg11. These rights can be exercised by contacting our support team.

Surg11 does not retain your personal data for longer than necessary for the purposes stated in this policy. Retention periods vary according to the type of data and applicable legal requirements.

• Active Account Data: Retained for the duration your account remains active, plus the period required under Malaysian law.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with anti-money laundering legal requirements.
• Security Logs: Retained for 90 days for security monitoring and investigation purposes.
• Marketing Data: Retained until you choose to opt out of marketing communications.
• Account Closed: Data is retained for the period required by law before being securely deleted.

Surg11 is a platform intended exclusively for individuals aged 18 and above. We do not intentionally collect or process personal data of any individual under the age of 18.

Surg11 may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory changes, or service improvements. Each version will display the "Last Updated" date at the top of this page.

For significant changes that affect your privacy rights, we will provide clear notification via the email registered to your account or through an in-platform notice at least 14 days before the changes take effect.

Continued use of the surg11 platform after any changes to this policy constitutes your acceptance of the updated policy.

If you have any questions, concerns, or complaints regarding how we handle your personal data, the surg11 privacy team is ready to assist you.

You can also reach us via live chat, available 24/7 on the surg11 platform, for inquiries requiring an immediate response.