Bull98 Privacy Policy – Malaysia Member Personal Data Protection

1 Introduction and Scope of This Policy

Bull98 ("we", "the Company" or "the Platform") takes our responsibility to protect the privacy and personal data of every member seriously. This Privacy Policy explains in detail how we collect, use, store, disclose, and protect your personal information when you use the bull98.pro platform and all related services.

This policy applies to all registered members, users browsing our website, and any party interacting with the bull98 platform in any capacity. By using our services, you consent to the collection and use of personal data as described in this policy.

We may update this Privacy Policy from time to time. Any material changes will be communicated to you via email or in-platform notification at least 7 days before the changes take effect.

2 Information We Collect

Bull98 collects your personal information through several different methods depending on your interactions with our platform. The following are the types of data we collect:

2.1 Information You Provide Directly

• Registration Information: Full name, date of birth, email address, phone number and the password you set when opening your account.
• Identity Verification Information (KYC): Copies of your identity card, passport, driver's licence, or other identification documents requested during the account verification process.
• Financial Information: Bank account number, credit or debit card details used for deposits and withdrawals – stored in securely encrypted format.
• Profile Information: Display name, language preference, profile picture and other account settings you have chosen.
• Communications: Any messages, feedback, or complaints you submit to our support team.

2.2 Information Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version.
• Usage Data: Pages you visit, time spent on each page, navigation patterns and features used.
• Transaction Data: Deposit history, withdrawals, wagering activity, and all financial transactions within your account.
• Cookie Data: Session information, saved preferences and analytics data collected through cookies and similar tracking technologies.

3 How We Use Your Data

Every piece of data we collect has a specific and legitimate purpose. We do not use your data for purposes unrelated to the provision of bull98's services.

We will not use your data for automated decision-making that has a significant impact on you without appropriate human oversight. Should we need to use your data for any new purpose not mentioned above, we will obtain your consent beforehand.

4 Data Sharing and Disclosure

Bull98 does not sell, rent, or trade your personal data to any third party for their marketing purposes. However, in the course of operating our platform, we may share your data with the following parties:

• Payment Service Providers: DuitNow, FPX, Touch 'n Go, Boost, GrabPay and credit/debit card processors that handle your financial transactions. This sharing is minimal and limited only to the information required to complete the transaction.
• Game Providers: Third-party game software providers that supply game content on the bull98 platform. They may receive session and in-game transaction data necessary to operate the games correctly.
• Cloud Service Providers: Server infrastructure that stores and processes your data under strict confidentiality agreements.
• Legal Authorities: Your information may be disclosed to the relevant authorities if required by law, court order or official investigation relating to financial crime.
• Audit & Compliance Services: Independent auditors who verify the fairness of our games and our operational compliance with industry standards.

5 Data Storage and Retention Period

Bull98 retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy or as required by applicable law.

• Active Account Data: Retained for as long as your account is active and you continue using bull98's services.
• Data After Account Closure: Identity information and transaction records are retained for a minimum of 7 years after account closure to meet anti-money laundering legal requirements and tax obligations.
• Communication Logs: Customer support records and communications are retained for 3 years for reference and dispute resolution purposes.
• Analytics Data: Anonymised usage data is retained for a longer period for analytics and platform improvement purposes.

All data is stored on secure servers with strict access controls. Only authorised personnel have access to members' personal data, and every access is logged for audit purposes.

6 Cookies and Tracking Technologies

Bull98 uses cookies and similar tracking technologies to enhance your experience on our platform, understand how the platform is used, and deliver more relevant features.

Types of Cookies Used:

• Essential Cookies (Required): Required for core platform functions such as login sessions, security, and language preferences. Cannot be disabled.
• Performance Cookies: Collects information on how you use our website (pages visited, time on page) to help us improve the platform. This data is anonymised.
• Functional Cookies: Saves your preferences such as selected language, region and display settings to provide a more personalised experience.
• Analytics Cookies: Used to analyse traffic and usage patterns in aggregate, helping us make data-driven decisions about product development.

You can manage cookie settings through your browser. However, disabling essential cookies may affect the functionality of the bull98 platform. For more information on managing cookies in your browser, refer to your browser's help documentation.

7 Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and bull98's policy, you have the following rights regarding your personal data:

8 Technical Security Measures

Bull98 implements a comprehensive range of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or loss.

• Data Encryption: All sensitive data is encrypted using AES-256 encryption for data at rest and TLS 1.3 for data in transit.
• Two-Factor Authentication (2FA): Available for all accounts as an additional layer of protection during login.
• 24/7 Monitoring: An intrusion detection system (IDS) continuously monitors platform activity to identify any security threats.
• Penetration Testing: Regular security audits are conducted by accredited independent third parties to identify and address vulnerabilities.
• Internal Access Controls: The principle of least privilege applies — staff only have access to the data required for their specific role.
• Data Backup: Automated daily backups across geographically separate locations ensure your data remains safe even in the event of a system failure.

9 Contact Us About Privacy

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer:

• Email: [email protected] (please state "Privacy Inquiry" in the message subject line)
• Live Chat: Available 24 hours a day, 7 days a week on the bull98.pro platform
• Response Time: We are committed to responding to all privacy inquiries within 5 business days

If you are not satisfied with our response, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia through the official channels designated by that authority.