Privacy Policy Warga123 –
Malaysian Personal Data Protection

This Privacy Policy ("Policy") is published by warga123 ("we", "warga123", or "the Company") and applies to all users ("Members", "you") who access or use our online platform at warga123.my and all related services.

Warga123 is an online sports betting and entertainment platform offering markets for football, badminton, e-sports, cricket, Live Casino, slots, and other sports to users in Malaysia. In the course of delivering these services, we collect and process certain member personal data. We recognise that this is a significant responsibility, and we are committed to handling it with the utmost care.

This Policy clearly sets out: the types of data we collect from you, why we need it, how we protect it, who we share it with (where applicable), how long we retain it, and the rights you hold over your personal data. This Policy should be read together with Terms & Conditions us.

Warga123 collects member personal data through several channels – account registration, platform usage, interactions with our support team, and through automated technologies within our platform. The data collected can be categorised as follows:

Identity and Contact Data:

• Full name as stated in your official identification document (MyKad)
• Date of birth and gender
• An active Malaysian mobile number
• A valid and active email address
• Current residential address
• MyKad number or relevant identification document (for the Know Your Customer (KYC) process)

Financial and Transaction Data:

• Deposit and withdrawal records (amount, date, method – DuitNow, Touch 'n Go eWallet, FPX, GrabPay, Boost, ShopeePay)
• Betting history and wagering activity on the platform
• Account balance and transaction records
• Malaysian bank account details for withdrawal purposes (bank name, account number — as provided by the member)

Technical and Usage Data:

• Your device's IP address when accessing the platform
• Device type, operating system, and browser version in use
• Access log data including date, time, and pages visited
• Cookie data and website tracking technologies (explained further in Section 7)
• Records of communications with the warga123 support team

Warga123 collects and processes members' personal data only for clearly defined and lawful purposes. We do not process data in any manner inconsistent with the original purpose of collection. These primary purposes are:

• Account Management: Creating, maintaining, and managing your Warga123 member account, including the registration process, identity verification (KYC), and secure login.
• Service Delivery: Enabling you to access all warga123 platform features including Sports Betting, Live Casino, slots, e-sports, and the VIP programme.
• Financial Transaction Processing: Processing deposits and withdrawals securely, maintaining accurate financial records, and verifying identity for transactions that exceed certain thresholds.
• Legal Compliance (AML/KYC): Meeting anti-money laundering (AML) obligations and Know Your Customer (KYC) requirements as mandated by applicable laws and regulations.
• Customer Support: Handling enquiries, complaints, and support requests efficiently, and maintaining communication records for reference purposes.
• Security and Fraud Prevention: Detecting and preventing fraudulent activity, multiple account ownership, money laundering, and any conduct that violates warga123's Terms & Conditions.
• Marketing Communications: Sending you information about relevant Warga123 promotions, bonuses, and offers — subject to your communication preferences.
• Platform Improvements: Analysing usage patterns in aggregate (without identifying individuals) to improve the performance, usability, and features of the warga123 platform.
• Responsible Gaming: Monitoring betting patterns to identify signs of problem gambling and providing appropriate self-control tools to members who need them.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), warga123 processes members' personal data on the following legal bases:

• Consent: When you register a warga123 account and agree to the Terms & Conditions and this Privacy Policy, you give us your consent to process your personal data for the stated purposes. You may withdraw your consent at any time, though this may affect our ability to deliver certain services.
• Contract Performance: Data processing necessary to fulfil the service agreement between you and Warga123, including transaction processing and account management.
• Legitimate Interest: Processing necessary for Warga123's legitimate business interests, such as fraud detection, platform security, and service improvement — subject to an assessment that those interests do not override your privacy rights.
• Legal Compliance: Processing necessary to comply with legal obligations, including AML and KYC requirements, as well as any lawful orders or directives from competent authorities.

Warga123 does not sell, rent, or disclose members' personal data to third parties for their own marketing purposes. However, in the course of platform operations, we may share members' personal data with the following categories of third parties, subject to strict confidentiality and data protection agreements:

• Payment Gateway Providers: DuitNow operators, Touch 'n Go eWallet, FPX (relevant Malaysian banks), GrabPay, Boost, and ShopeePay — only the data required to process your transactions.
• Technology Service Providers: Server infrastructure providers, cybersecurity services, and platform software vendors involved in Warga123's technical operations — subject to strict data processing agreements.
• Identity Verification Provider: Third-party services that assist us with KYC processing and identity document verification – data is shared solely for verification purposes.
• Government Authorities and Law Enforcement: We will disclose personal data to the relevant authorities when required by law, court order, or in cases involving investigations into financial crimes such as money laundering.

In all instances of data sharing with third parties, warga123 ensures that the receiving party maintains adequate data protection standards and that data is shared only to the extent necessary for legitimate purposes. We do not permit third parties to use warga123 members' data for their own purposes beyond what we have directed.

Warga123 retains members' personal data for as long as necessary to fulfil the purposes stated in this Policy or as required by applicable laws. Generally:

• Active account data is retained for the duration of active membership and for a period of seven (7) years following account closure, in line with Malaysia's financial record-keeping requirements.
• Financial transaction data is retained for a minimum of seven (7) years after the transaction date for audit purposes, AML compliance, and tax reporting requirements.
• Customer support communication logs are retained for three (3) years for reference and dispute resolution purposes.
• Technical data such as access logs is retained for 12 months for security purposes and technical troubleshooting.

On the technical security front, Warga123 employs the following layers of protection to safeguard member personal data:

• Data encryption in transit using TLS 1.3 and SSL 256-bit protocols
• Encryption of data stored in databases using AES-256 standards
• Strict internal access controls – only authorised personnel who require access to carry out their duties are permitted to access member data
• Around-the-clock security monitoring to detect and respond to cyber threats
• Regular security testing (penetration testing) conducted by independent third parties
• Data backup procedures and disaster recovery to ensure operational continuity

The warga123 platform uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions correctly. Cookies are small text files stored on your device when you visit our website.

We use the following types of cookies on the warga123 platform:

• Essential Cookies: Required for core platform functions such as login authentication, session management, and security. These cookies cannot be disabled as the platform will not function properly without them.
• Analytics Cookies: Helping us understand how members use the warga123 platform – which pages are visited most frequently, how long is spent on each, and so on. This data is collected in aggregate and does not identify individuals personally.
• Functional Cookies: Remembering your preferences such as language, display settings, and other choices so you don't have to configure them again on every visit.
• Security Cookies: Used to detect and prevent fraudulent activity, ensuring that only authorised users can access their accounts.

You can manage and delete cookies through your browser settings. However, disabling certain cookies may affect the functionality of the warga123 platform and your overall user experience. By continuing to use our platform, you consent to the use of cookies as described here.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you as a data subject have the following rights regarding the personal data we hold:

Warga123 will process all privacy rights requests within 30 business days from the date of receipt of a complete request. For more complex cases, we may require additional time of up to 60 days and will notify you accordingly.

Please note that these rights are subject to certain limitations. For example, we may be unable to delete specific data where we have a legal obligation to retain it, such as financial transaction records required under Malaysia's AML laws.

In the course of operating the Warga123 platform, some of our technical service providers may store or process data on servers located outside Malaysia. When this occurs, Warga123 ensures:

• Data transfers are made only to countries or entities that provide an adequate level of data protection equivalent to Malaysia's PDPA 2010.
• Detailed, legally binding data processing agreements are established with all vendors that process warga123 member data outside Malaysia.
• Appropriate technical safeguards, such as encryption of data in transit and at rest, are applied to all cross-border data transfers.
• Cross-border data transfers are carried out only where necessary for service delivery and do not occur for any other purpose without your consent.

The warga123 platform is intended exclusively for individuals aged 18 years of age and above. We do not intentionally collect or process personal data of individuals under the age of 18.

If Warga123 discovers that personal data of a minor has been collected without our knowledge — for example, through registration using false information — we will:

• Suspending the relevant account immediately upon becoming aware of the matter.
• Deleting all personal data associated with that account within a reasonable timeframe.
• Reporting the incident to the relevant authorities where required by law.

If you believe we may have a child's personal data in our systems, please contact us immediately at support@warga123.my so we can take the appropriate action.

The warga123 platform does not contain links to external third-party websites. Any third-party services we use (such as the DuitNow, Touch 'n Go eWallet, FPX, GrabPay, and Boost payment gateways) are accessed through interfaces integrated directly into the warga123 platform and are subject to their respective privacy policies.

When you use payment services such as Touch 'n Go eWallet or GrabPay to deposit funds into your Warga123 account, the processing of those transactions is also subject to the respective eWallet operator's privacy policy. Warga123 recommends that you read and understand the privacy policies of all third-party services you use.

Warga123 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, legal requirements, or new operational needs. When material amendments are made:

• The "Last Updated" date displayed at the top of this document will be revised accordingly.
• Email notifications will be sent to all registered Warga123 members informing them of material changes.
• A clear notice will be displayed on the platform upon login for a reasonable period after any amendments are made.

Continued use of the warga123 platform after an amended Privacy Policy takes effect constitutes acceptance of the latest version. It is each member's responsibility to review this Policy periodically. If you disagree with any changes made, you may close your account and all valid balances will be processed in accordance with standard procedures.

For any questions, concerns, or requests relating to this Privacy Policy or how warga123 handles your personal data, please contact our Privacy Officer through the following channels:

• Email: support@warga123.my – please include "Privacy Inquiry" in your email subject line.
• Live Chat: Available 24/7 on the Warga123 platform in Bahasa Melayu. Select the "Privacy & Data" category when starting a chat session.

We are committed to responding to all privacy-related inquiries within 3 business days. For formal requests relating to data subject rights (access, correction, erasure), processing time is up to 30 business days.

If you are not satisfied with our response to your privacy complaint, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia under the provisions of the PDPA 2010.