Privacy Policy — asd123

1 Introduction

This Privacy Policy (hereinafter referred to as "the Policy") sets out the manner in which asd123 (hereinafter referred to as "asd123", "the Platform", "we", "us", or "our"), the operator of the website accessible at asd123.cam and all associated subdomains, mobile interfaces, and services (collectively, "the Services"), collects, processes, stores, shares, and protects the personal data of its users.

This Policy applies to all individuals who access or use the Services, including registered account holders, visitors who browse the Platform without registering, and individuals who communicate with asd123 through any channel (including live chat, email, and support ticketing systems).

By accessing or using the asd123 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read in conjunction with asd123's Terms & Conditions, which are incorporated herein by reference.

2 Definitions

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

3 Personal Data We Collect

asd123 collects and processes the following categories of Personal Data in connection with the provision of the Services:

• Full legal name as appearing on a government-issued identification document;
• Date of birth (used to verify the 21+ minimum age requirement);
• Gender (where provided voluntarily);
• Nationality and country of residence;
• Government-issued identification numbers (e.g., Malaysian MyKad number, passport number).

• Email address (primary account communication channel);
• Mobile phone number (used for account verification and security alerts);
• Residential address (required for KYC verification and correspondence).

• Deposit and withdrawal transaction records, including amounts, dates, and payment methods;
• Payment method details, including e-wallet account identifiers (Touch 'n Go eWallet, Boost, GrabPay), FPX bank account details, and partial payment card information where applicable;
• Cryptocurrency wallet addresses used for USDT or BTC transactions;
• Account balance history and betting transaction logs.

• IP address and approximate geolocation derived therefrom;
• Device type, operating system, and browser type;
• Session duration, pages visited, and clickstream data;
• Login timestamps and access logs;
• Betting and game activity logs, including game selections, wager amounts, and outcomes.

• Records of live chat, email, and support ticket communications with asd123 customer service;
• Any personal data voluntarily provided by the User in the course of such communications.

• Copies of government-issued identity documents (MyKad, passport, driving licence);
• Proof of address documents (utility bills, bank statements dated within 90 days);
• Source of funds declarations where required by AML compliance obligations.

4 How We Collect Personal Data

asd123 collects Personal Data through the following mechanisms:

• Direct provision by the User: Data entered during account registration, KYC submission, payment processing, form completion, or communication with support;
• Automated technical collection: Data collected passively as the User navigates the Platform, including via cookies, pixel tags, and server-side logging (see Section 9);
• Payment service providers: Transaction confirmation data shared by your e-wallet provider (Touch 'n Go, Boost, GrabPay), bank (Maybank, CIMB, Public Bank, Hong Leong), or card network (Visa/Mastercard) in connection with a deposit or withdrawal;
• Identity verification services: Third-party KYC and AML screening providers may share verification results and screening flags in connection with the identity verification process;
• Publicly available sources: Where required for AML compliance, asd123 may consult publicly available sanction lists, politically exposed person (PEP) databases, and adverse media sources.

5 How We Use Your Data (Data Processing)

asd123 processes Personal Data for the following purposes:

6 Legal Basis for Processing

asd123 processes Personal Data on the following legal bases:

• Contractual necessity: Processing required to fulfil the contract between asd123 and the User (e.g., account creation, payment processing, withdrawal fulfilment);
• Legal obligation: Processing required to comply with applicable AML, KYC, gaming regulatory, and data protection obligations;
• Legitimate interests: Processing for purposes of fraud prevention, platform security, responsible gambling monitoring, and service improvement, where such interests are not overridden by the User's rights and freedoms;
• Consent: Processing for direct marketing purposes and the placement of non-essential cookies, where the User has provided specific, informed, and freely given consent.

7 Data Sharing & Disclosure

asd123 does not sell, rent, or otherwise transfer Personal Data to unaffiliated third parties for their own commercial purposes. Personal Data may be shared in the following circumstances:

asd123 engages certain trusted third-party processors to assist in delivering the Services, including payment processors (facilitating transactions via Touch 'n Go, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, Visa/Mastercard, and cryptocurrency networks), identity verification and KYC service providers, cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and analytics vendors. All Third-Party Processors are contractually bound to process Personal Data only on asd123's documented instructions and to implement appropriate technical and organisational security measures.

asd123 may disclose Personal Data to competent regulatory authorities, law enforcement agencies, courts, or other governmental bodies where required to do so by applicable law, a valid legal process, or a binding order from a competent authority. Where legally permissible, asd123 will notify the affected User of such a disclosure prior to compliance.

In the event of a merger, acquisition, restructuring, or sale of all or part of asd123's business, Personal Data held by asd123 may be transferred to the acquiring or successor entity. Affected Users will be notified of any such transfer and of any material changes to data processing arrangements arising therefrom.

8 Data Retention

asd123 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulation.

• Account and transaction data: Retained for a minimum of five (5) years following account closure, in compliance with applicable AML record-keeping requirements;
• KYC documentation: Retained for a minimum of five (5) years from the date of verification, or longer if required by a competent authority;
• Communications data (live chat, email): Retained for up to three (3) years from the date of the communication, unless the content relates to an ongoing dispute or regulatory matter;
• Technical and usage data: Retained in anonymised or pseudonymised form for platform analytics purposes; identifiable session logs retained for up to twelve (12) months;
• Marketing consent records: Retained for the duration of the User's account plus two (2) years following closure.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised in a manner that prevents re-identification.

9 Cookies & Tracking Technologies

asd123 uses cookies and similar tracking technologies (including pixel tags and local storage) to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform.

• Strictly necessary cookies: Required for the Platform to function. These include session management cookies that keep you logged in during a gaming session. These cannot be disabled without impairing Platform functionality;
• Performance & analytics cookies: Used to collect anonymised data on how Users interact with the Platform, enabling us to identify and resolve technical issues and improve user experience;
• Functional cookies: Used to remember your preferences, such as language settings and deposit method selections, to enhance your experience on return visits;
• Marketing cookies: Used (only with your consent) to deliver relevant promotional content and measure the effectiveness of marketing campaigns.

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to refuse some or all cookies, or to be notified when a cookie is being set. Please note that disabling cookies may affect the functionality of the Platform, including your ability to log in and maintain an active session.

10 Data Security

asd123 implements a range of technical and organisational security measures to protect Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between the User's device and the asd123 platform;
• AES-256 encryption for Personal Data stored at rest in our databases;
• Role-based access controls ensuring that Personal Data is accessible only to employees and processors with a documented operational need;
• Two-factor authentication (2FA) available to all Users for enhanced account security;
• Regular security audits, penetration testing, and vulnerability assessments;
• Secure data centre infrastructure with physical access controls and redundancy measures.

Notwithstanding the foregoing, no electronic transmission or storage system can guarantee absolute security. In the event of a Personal Data breach that is likely to result in a high risk to the rights and freedoms of affected Users, asd123 will notify those Users without undue delay in accordance with its breach notification obligations.

11 Your Rights as a Data Subject

Subject to applicable data protection law, you have the following rights with respect to your Personal Data held by asd123. You may exercise these rights by contacting us as described in Section 15.

asd123 will respond to all valid data subject requests within 30 calendar days of receipt. Where a request is complex or numerous, this period may be extended by a further 60 days, with notice provided to the requestor.

12 Minors & Age Restrictions

The asd123 Services are strictly intended for individuals aged 21 years and above. asd123 does not knowingly collect or process Personal Data relating to individuals under the age of 21. Age verification forms a mandatory part of the KYC process for all account holders.

In the event that asd123 becomes aware that it has inadvertently collected Personal Data from an individual below the minimum age threshold, such data will be deleted without delay, the associated account will be closed, and any deposits will be returned to the originating payment method.

If you believe that a minor has registered on the asd123 platform, please notify us immediately at [email protected] so that we may take prompt remedial action.

13 International Data Transfers

asd123's servers and technical infrastructure may be located in jurisdictions outside Malaysia. Where Personal Data is transferred to a jurisdiction that does not provide an equivalent level of data protection to that applicable in Malaysia, asd123 will ensure that such transfers are subject to appropriate safeguards, including contractual data processing agreements incorporating standard data protection clauses, and will only be made to processors that demonstrate adequate security and compliance standards.

Users may request further information regarding the specific safeguards applied to any international transfer of their Personal Data by contacting us as described in Section 15.

14 Amendments to This Policy

asd123 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. Where a material change is proposed, asd123 will endeavour to provide reasonable advance notice to active account holders via the Platform or by email. The "Last updated" date at the top of this document will be revised accordingly.

Continued use of the Platform following notification of an amendment constitutes the User's acceptance of the revised Policy. Users who do not accept the revised Policy should discontinue use of the Services and contact support to request account closure.

15 Contact Us & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the manner in which asd123 processes your Personal Data, please contact our Data Protection team using the following channels:

• Email: [email protected] — mark the subject line "Privacy Enquiry" for prompt routing to the appropriate team;
• Live Chat: Available 24 hours a day, 7 days a week, via the asd123 platform — select "Privacy / Data Request" from the support menu;
• Data Subject Request Form: Available upon request through live chat or email. We will provide a structured form for formal access, rectification, erasure, or portability requests.

asd123 is committed to resolving all privacy-related enquiries promptly and in good faith. If you are not satisfied with our response to a complaint, you retain the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction.