Privacy Policy

Introduction

This Privacy Policy ("Policy") is published by Sirap77 ("we", "us", "our", "the Platform") and applies to all personal data collected from users ("you", "User", "Player") who access or use the website located at sirap77.cam and all associated services, features, and content made available therein (collectively, the "Services").

We take your privacy seriously. This Policy is designed to provide you with clear and transparent information about our data processing practices in accordance with applicable data protection laws and regulations. We encourage you to read this Policy in full before using our Services.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which contain additional information relevant to how we manage your account and protect your interests as a player on the Sirap77 Platform.

Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings ascribed to them below:

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, including but not limited to name, email address, identification number, device identifier, or financial account details.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" means Sirap77, which determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of Sirap77 in accordance with our instructions and this Policy.
• "Cookies" means small text files placed on your device by the Platform for the purposes described in Section 9 of this Policy.
• "KYC Data" means identity verification documents and associated information collected as part of the Know Your Customer process.
• "Sensitive Data" means a special category of Personal Data that warrants heightened protection, such as financial details, identification documents, and account security credentials.

Data We Collect

Sirap77 collects Personal Data that you provide directly to us, data that is generated automatically through your use of the Platform, and data received from third-party sources where applicable. The categories of data we may collect are set out below.

3.1 Data You Provide Directly

• Full name and date of birth (to verify your identity and confirm you are aged 21 or above)
• Email address and contact number
• Residential address, including city (e.g., Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam)
• Malaysian National Identity Card (MyKad) number or passport number (for KYC verification)
• Bank account details, e-wallet identifiers (e.g., Touch 'n Go eWallet, Boost, GrabPay), or cryptocurrency wallet addresses used for deposits and withdrawals via Maybank, CIMB, Public Bank, Hong Leong Bank, DuitNow, or FPX
• Username, password, and security question responses
• Communications sent to our customer support team via live chat or email

3.2 Data Collected Automatically

• IP address and approximate geographic location
• Device type, operating system, browser type, and version
• Session data including login timestamps, session duration, and pages visited
• Transaction history including deposit amounts, withdrawal requests, game stakes, and outcomes
• Clickstream and navigation data
• Cookie and tracking technology data (see Section 9)

3.3 Data from Third Parties

We may receive Personal Data from third-party sources including payment processors, identity verification service providers, fraud detection agencies, and regulatory compliance partners where such receipt is necessary for the provision of our Services or for legal compliance purposes.

Purposes of Data Processing

Sirap77 processes your Personal Data for the following specific purposes:

Legal Basis for Processing

Sirap77 processes your Personal Data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is necessary to perform our contractual obligations to you under the Terms & Conditions, including providing access to games, processing payments, and managing your account.
• Legal Obligation: Processing that is required to comply with applicable laws, including KYC/AML requirements, age verification, and regulatory reporting obligations.
• Legitimate Interests: Processing that is necessary for Sirap77's legitimate business interests, including fraud prevention, security monitoring, and internal analytics, where these interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing purposes where your prior consent has been obtained. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

Data Sharing & Disclosure

Sirap77 does not sell your Personal Data to third parties. We may share your data only in the following circumstances, and only to the extent necessary for the identified purpose:

6.1 Service Providers & Data Processors

We engage third-party service providers who process data on our behalf, including payment gateway operators, KYC identity verification services, fraud detection platforms, data hosting and cloud infrastructure providers, and customer support software vendors. All such providers are bound by data processing agreements that prohibit them from using your data for any purpose other than those specified by Sirap77.

6.2 Legal and Regulatory Authorities

We may disclose your Personal Data to regulatory bodies, law enforcement agencies, courts, or other governmental authorities where required by applicable law, or where such disclosure is necessary to protect the rights, property, or safety of Sirap77, our users, or the public.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of Sirap77's business, your Personal Data may be transferred to the relevant successor entity. You will be notified of any such transfer and the applicable privacy terms.

Data Retention

Sirap77 retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting obligations. The following general retention principles apply:

• Account and transaction data is retained for a minimum period required under applicable anti-money laundering and financial regulations from the date of the last transaction or account closure, whichever is later.
• KYC verification documents are retained for the period mandated by applicable regulatory requirements following account closure.
• Customer support communications are retained for a reasonable period to facilitate follow-up and dispute resolution.
• Marketing consent records are retained until you withdraw consent or request deletion, subject to legal retention obligations.
• Where data is no longer required for any lawful purpose, it is securely deleted or anonymised.

Data Security

Sirap77 implements comprehensive technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. Our security programme includes:

• SSL/TLS encryption for all data transmitted between your device and the Platform
• Encryption of sensitive data at rest using AES-256 or equivalent standards
• Two-factor authentication (2FA) options for account access
• Strict access controls limiting data access to authorised personnel on a need-to-know basis
• Regular security audits, penetration testing, and vulnerability assessments
• Real-time monitoring for suspicious account activity and potential data breaches
• Staff training on data protection obligations and security best practices

While we implement robust security measures, no system is entirely immune to risk. In the event of a data breach that is likely to result in a risk to your rights and freedoms, Sirap77 will notify affected users and relevant authorities in accordance with applicable legal requirements.

Cookies & Tracking Technologies

Sirap77 uses cookies and similar tracking technologies (such as web beacons and local storage objects) to operate and improve the Platform, maintain your session, and provide a personalised experience. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display options, and account configurations.
• Analytical Cookies: Used to collect anonymised data about how users interact with the Platform, enabling us to identify performance issues and improve user experience.
• Marketing Cookies: Used to identify and track users who have interacted with promotional content, enabling us to deliver more relevant offers. These cookies are only activated with your consent.

Most browsers allow you to manage your cookie preferences through their settings. Please note that disabling certain cookies may affect the functionality of the Platform. For full details on our cookie practices, please contact our support team.

International Data Transfers

In the course of providing our Services, your Personal Data may be transferred to and processed in countries other than Malaysia. These transfers may occur where our third-party service providers operate infrastructure or support services from other jurisdictions.

Where such transfers occur, Sirap77 ensures that appropriate safeguards are in place to protect your data in accordance with applicable data protection standards. This includes contractual provisions with service providers that impose data protection obligations equivalent to those applicable in Malaysia.

Your Rights as a Data Subject

Subject to applicable law, you have the following rights in relation to the Personal Data that Sirap77 holds about you. To exercise any of these rights, please contact us using the details provided in Section 15.

Minors & Age Verification Policy

The Sirap77 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is conducted as part of our registration and KYC process for all users.

If we become aware that we have inadvertently collected Personal Data from a person under the age of 21, we will take immediate steps to delete that data, close the associated account, and — where required by law — report the incident to the appropriate authorities.

If you believe that a minor has registered on the Platform or that we hold data relating to an individual under the age of 21, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

Third-Party Services & Links

The Sirap77 Platform may contain references to third-party services, including but not limited to payment providers such as Maybank, CIMB, Public Bank, Hong Leong Bank, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, and FPX. These services operate under their own privacy policies and terms, and Sirap77 is not responsible for the privacy practices of third-party providers.

We encourage you to review the privacy policies of any third-party service providers you interact with in connection with your use of the Sirap77 Platform, particularly with regard to how they handle your financial and personal data during payment processing.

Amendments to This Policy

Sirap77 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material, we will notify you via the Platform or by email to your registered address. Your continued use of the Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you should discontinue use of the Platform and may close your account.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact the Sirap77 Data Protection team using the details below. We take all privacy-related enquiries seriously and will respond in a timely and professional manner.