pavi88 Privacy Policy

1. Scope and Data Controller

1.1 This Privacy Policy applies to all personal data collected by pavi88 in connection with the operation of the pavi88 online gaming platform accessible at pavi88.com ("Platform"), including all registration, account management, gaming, payment, support, and marketing activities.

1.2 For the purposes of applicable data protection legislation, pavi88 is the data controller in respect of personal data collected through the Platform. All data controller responsibilities, including responding to data subject rights requests, are managed through the contact details provided in Section 13 of this Policy.

1.3 This Policy should be read in conjunction with the pavi88 Terms & Conditions. Capitalised terms used but not defined in this Policy have the meaning given to them in the pavi88 Terms & Conditions.

2. Personal Data We Collect

pavi88 collects the following categories of personal data:

2.1 Identity & Contact Data

• Full legal name as it appears on government-issued identification;
• Date of birth (used for age verification — pavi88 enforces a strict 21+ requirement);
• National identification number (e.g., Malaysian MyKad number) or passport number where required for KYC;
• Residential address, including postcode and state within Malaysia;
• Email address registered to your pavi88 account;
• Mobile phone number registered to your pavi88 account.

2.2 Financial Data

• Payment method details submitted during deposit or withdrawal — for e-wallet methods (Touch n Go eWallet, Boost) this consists of your registered mobile number; for bank transfers this consists of your bank account number and bank name;
• Transaction history including deposit amounts, withdrawal amounts, timestamps, and payment method references;
• Source of funds documentation submitted during enhanced KYC verification.

2.3 Gaming Activity Data

• Game session records including game titles played, wager amounts, outcomes, and session duration;
• Bonus claims, wagering progress, and promotional participation history;
• Sports betting selections, stake amounts, and settlement records.

2.4 Technical & Usage Data

• IP address and approximate geolocation at time of login and during active sessions;
• Device type, operating system, browser type, and screen resolution;
• Pages visited on pavi88.com, navigation paths, and time spent on platform sections;
• Session cookies and authentication tokens (see Section 8).

2.5 Communications Data

• Records of live chat conversations with pavi88 support;
• Email correspondence sent to or received from pavi88 support addresses;
• Complaint submissions and their resolution records.

3. How We Collect Your Data

3.1 Direct Collection. pavi88 collects data directly from you when you: register a pavi88 account; complete KYC verification; make deposits or withdrawal requests; contact customer support; participate in promotions; or complete any form or survey on the Platform.

3.2 Automated Collection. pavi88 automatically collects technical and usage data through server logs, session cookies, and analytics tools each time you access the Platform. This data is collected passively and does not require any action from you beyond accessing the Platform.

3.3 Third-Party Sources. pavi88 may receive data about you from third-party identity verification services engaged to assist with KYC compliance, from payment processors confirming transaction statuses, and from fraud prevention databases used to screen accounts and transactions.

4. Purposes and Legal Basis for Processing

pavi88 processes your personal data for the following purposes and on the following legal bases:

• Account Registration & Management — necessary for the performance of the contract between you and pavi88 (i.e., the pavi88 Terms & Conditions);
• Payment Processing — necessary for the performance of the contract and for compliance with anti-money laundering legal obligations;
• KYC & Age Verification — necessary for compliance with pavi88's legal obligations under its gaming licence, including the strict 21+ age requirement;
• Fraud Prevention & Security — legitimate interest in protecting pavi88 and its members from fraud, money laundering, and account takeover;
• Platform Improvement & Analytics — legitimate interest in improving the pavi88 platform experience for Malaysian users;
• Responsible Gaming Monitoring — legal obligation under pavi88's gaming licence to identify and assist members showing signs of problem gambling;
• Marketing Communications — consent provided by you at registration or subsequently, which you may withdraw at any time;
• Legal Compliance — compliance with applicable laws, court orders, and requests from regulatory authorities.

5. Data Sharing and Disclosure

5.1 pavi88 does not sell your personal data to third parties. pavi88 shares personal data only as necessary for the following purposes and only with parties bound by appropriate data protection obligations:

• Payment Processors: Financial data is shared with payment processing partners (including those facilitating Touch n Go eWallet, Boost, and FPX bank transfers) solely to process deposit and withdrawal transactions;
• KYC Verification Providers: Identity and document data is shared with third-party identity verification services engaged by pavi88 to fulfil its licence compliance obligations;
• Game Software Providers: Gaming session data is shared with pavi88's licensed game software providers (e.g., Pragmatic Play, PG Soft) to the extent technically necessary to deliver game functionality and maintain session integrity;
• Fraud Prevention Services: Account and technical data may be shared with fraud prevention databases to screen for known fraudulent actors;
• Regulatory Authorities: pavi88 will disclose personal data to its gaming licence regulator, financial intelligence units, or law enforcement authorities when required to do so by applicable law or legal process.

5.2 pavi88 will not share your personal data with third parties for their own marketing purposes without your explicit consent.

6. International Data Transfers

6.1 pavi88 operates with technology and service providers located in multiple jurisdictions. Some of the third parties with whom pavi88 shares data (as described in Section 5) may be located outside of Malaysia. Where personal data is transferred outside of Malaysia to countries that may not provide equivalent data protection standards, pavi88 implements appropriate safeguards including contractual data protection clauses with recipient entities.

6.2 By using the pavi88 Platform, you acknowledge and consent to the transfer of your personal data to third-party service providers in other jurisdictions where necessary for the delivery of pavi88 services, subject to the protections described in this Policy.

7. Data Retention

7.1 pavi88 retains personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, accounting, and reporting obligations.

7.2 As a general guideline, pavi88 retains account data and transaction records for a minimum of five (5) years following account closure, in order to satisfy anti-money laundering record-keeping requirements under pavi88's gaming licence and applicable financial regulations.

7.3 Marketing consent records are retained for the duration of the marketing relationship and for a reasonable period thereafter as evidence of consent.

7.4 Where a Member has self-excluded from pavi88, records of the self-exclusion are retained for the duration of the exclusion period plus an additional period thereafter in order to honour the exclusion and prevent re-registration during the exclusion period.

7.5 Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with pavi88's data disposal procedures.

8. Cookies and Tracking Technologies

8.1 pavi88 uses cookies and similar tracking technologies to operate the Platform. Cookies are small data files stored on your device by your browser at the instruction of the pavi88 website. pavi88 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that maintain your login state, security tokens, and cookies used to remember your preferences within a session. These cannot be disabled without preventing core Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised information about how Members use the Platform — which pages are visited most frequently, how navigation paths flow, and where users encounter issues. This data helps pavi88 improve the platform experience.
• Marketing Cookies: Used, where you have consented, to deliver relevant promotional content on the Platform based on your activity and preferences.

8.2 You may manage cookie preferences through your browser settings. Disabling analytics or marketing cookies will not prevent you from using the core pavi88 Platform but may affect the relevance of promotional content you see.

9. Security Measures

9.1 pavi88 implements technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and pavi88 servers;
• Encryption of sensitive data at rest on pavi88 database servers;
• Role-based access controls limiting internal access to personal data to staff with a legitimate operational need;
• Multi-factor authentication requirements for pavi88 staff accessing internal systems containing member data;
• Regular penetration testing and vulnerability assessments by independent security specialists;
• Anomaly detection systems monitoring for unusual login patterns or data access events.

9.2 Notwithstanding these measures, no data transmission over the internet or electronic storage system is completely secure. pavi88 cannot guarantee absolute security and accepts no liability for breaches resulting from circumstances outside its reasonable control. In the event of a data breach affecting your personal data, pavi88 will notify you and applicable regulatory authorities in accordance with its legal obligations.

10. Your Data Subject Rights

10.1 Subject to applicable law, you have the following rights in relation to your personal data held by pavi88:

• Right of Access: You may request confirmation of whether pavi88 holds personal data about you, and a copy of that data;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data held by pavi88;
• Right to Erasure: You may request deletion of your personal data where pavi88 no longer has a legal basis or legitimate purpose for retaining it — note that certain data must be retained for regulatory compliance regardless of erasure requests;
• Right to Restriction: You may request that pavi88 restrict processing of your personal data in certain circumstances, for example while the accuracy of data is being verified;
• Right to Object: You may object to pavi88's processing of your personal data on the basis of legitimate interest, including processing for direct marketing purposes;
• Right to Data Portability: You may request a copy of personal data you have provided to pavi88 in a structured, machine-readable format.

10.2 To exercise any of these rights, please contact pavi88 at [email protected] with the subject line "Data Rights Request." pavi88 will respond within 30 days of receiving a verified request.

11. Children and Minors

11.1 pavi88 is strictly prohibited to persons under the age of 21. pavi88 does not knowingly collect personal data from persons under 21 years of age. The pavi88 registration process includes age verification requirements, and pavi88 conducts KYC verification to confirm the age of members before processing withdrawals.

11.2 If pavi88 discovers that personal data has been collected from a person under 21, the associated account will be immediately suspended, all balances held pending investigation, and the personal data of the minor deleted to the extent permitted by pavi88's legal obligations.

11.3 If you are a parent or guardian and believe a minor has registered a pavi88 account, please contact pavi88 support immediately with relevant details so that the account can be reviewed and closed.

12. Changes to This Privacy Policy

12.1 pavi88 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, pavi88's data processing practices, or pavi88's services. Updated versions will be published at pavi88.com/privacy-policy with a revised "Last Updated" date.

12.2 Where amendments are material — for example, changes to the categories of data collected or new purposes for which data is processed — pavi88 will provide advance notice to Members via email or on-platform notification prior to the changes taking effect.

12.3 Continued use of the pavi88 Platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

13. Contact and Complaints

13.1 For any questions, concerns, or requests relating to this Privacy Policy or pavi88's data processing activities, please contact:

• Email: [email protected] (subject: "Privacy Policy Enquiry")
• Live Chat: Available 24/7 via the pavi88 Platform

13.2 pavi88 will acknowledge all written privacy enquiries within 48 hours and endeavour to provide a substantive response within 30 calendar days.

13.3 If you are not satisfied with pavi88's response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction or to the dispute resolution body specified under pavi88's gaming licence conditions.