Pana21 Privacy Policy — Member Personal Data Protection Malaysia

Pana21 takes data protection responsibility very seriously. This Privacy Policy is drafted to comply with the Personal Data Protection Act 2010 (PDPA) Malaysia and reflects transparent data management practices across the pana21 platform.

This policy applies to all individuals who access the pana21 website, register as a member, use our gaming services, or interact with our platform through any device or communication channel. By using the pana21 platform, you give your consent to the collection and processing of your personal data as described in this document.

Pana21 acts as the Data Controller for all personal information collected through our platform. This means we determine the purpose and method of processing your data, and we are fully responsible for ensuring your data is processed lawfully, fairly, and transparently at all times.

To provide a secure, personalised, and high-quality service, pana21 collects several categories of personal data from our members. Below is a detailed list of the types of data we collect and their sources:

We only collect data that is genuinely necessary for the stated purposes. This "minimum collection" principle ensures we do not gather information that is irrelevant or excessive about you.

Every piece of data collected by pana21 is used for specific and lawful purposes. We do not process your data for any purpose not stated here without first obtaining your additional consent.

• Account Management: Creating, verifying, and maintaining your member account, including mandatory KYC processes to ensure platform security.
• Transaction Processing: Processing all deposits, withdrawals, and other financial activities securely and efficiently through trusted payment providers.
• Service Delivery: Providing access to all pana21 platform games and features based on your preferences and usage history.
• Security & Fraud Prevention: Detecting and preventing fraud, money laundering, and other security threats that could affect you or our platform.
• Service Improvement: Analysing usage patterns in aggregate and anonymised form to improve platform design, performance, and features.
• Service Communications: Sending important notices related to your account, terms changes, security updates, and transaction information.
• Marketing (with consent): Sending promotional offers and bonus information only to members who have consented to receive marketing communications.
• Legal Compliance: Fulfilling applicable legal and regulatory obligations, including anti-money laundering reporting requirements.

Pana21 does not sell, rent, or trade your personal data to any third party for their own marketing purposes. However, in the course of operating the platform, we may share your data with a limited and trusted category of third parties, subject to strict data protection agreements:

• Payment Service Providers: DuitNow, FPX, TNG eWallet, GrabPay, Boost, and related financial institutions to process your transactions securely.
• Game Software Providers: Licensed game providers supplying slot, Live Casino, and other game content on our platform — only data required for game session verification is shared.
• KYC Verification Services: Accredited KYC service providers that help us verify member identities in accordance with legal compliance requirements.
• Regulatory Authority: Government agencies or regulatory bodies entitled to obtain information under applicable laws in Malaysia.
• Technical Service Providers: Cloud infrastructure and cybersecurity providers that help us operate the platform securely — all bound by strict confidentiality agreements.

In the event of a merger, acquisition, or sale of company assets, user data may be transferred as part of those assets. In such circumstances, pana21 will notify you via a prominent notice on our website before the transfer takes place, and you will be given the option to delete your account if you do not agree.

Your data security is pana21's top priority. We implement comprehensive technical and organisational security measures to protect your personal information from unauthorised access, loss, misuse, or unintended disclosure.

• 256-bit SSL/TLS Encryption: All data transmitted between your browser and pana21's servers is protected by 256-bit SSL/TLS encryption — the same security standard used by major banking institutions.
• Data Encryption at Rest: Sensitive data stored in our databases, including financial information and identity details, is encrypted using AES-256 encryption algorithm.
• Role-Based Access Control: Only authorised pana21 staff with a legitimate business need may access member personal data. All access is logged and continuously monitored.
• 24/7 Security Monitoring: Our real-time threat monitoring system operates around the clock to detect and respond to any suspicious activity immediately.
• Regular Security Testing: pana21 conducts regular penetration testing and security audits by independent experts to identify and address any vulnerabilities.
• Incident Response Plan: We have clear procedures in place to respond to any data breach. Should an incident occur that affects your data, we will notify you within 72 hours of the incident being detected.

Pana21 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

We use the following types of cookies:

• Essential Cookies: Required for core platform functionality — including login, game sessions, and security. These cookies cannot be disabled as they are essential for the platform to operate.
• Performance Cookies: Collecting anonymous information about how visitors use our website, such as the most frequently visited pages. This data helps us improve platform performance.
• Functional Cookies: Remembering your preferences such as language, display settings, and game choices to deliver a more personalised experience.
• Analytics Cookies: We use analytics tools to understand platform usage patterns on an aggregate basis. All such data is processed anonymously and cannot be used to identify you personally.

You can control and manage cookies through your web browser settings. However, disabling essential cookies may affect the functionality of the pana21 platform and you may be unable to log in or use certain features.

Pana21 retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law.

• Active Account Data: For as long as your account remains active, your account data will be retained to ensure continuity of service.
• Financial Transaction Data: Financial transaction records are retained for a minimum of 7 years in compliance with Malaysia's tax and anti-money laundering legal requirements.
• KYC Data: Identity verification documents are retained for 5 years after account closure in accordance with regulatory compliance requirements.
• Communication Records: Support chat logs and emails are retained for 2 years for dispute resolution and service improvement purposes.
• After Account Closure: Upon account closure, data no longer required for legal compliance will be deleted or anonymised within 90 days.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data held by pana21. We are committed to making it easy for you to exercise these rights:

To exercise any of the rights above, please contact our Privacy Officer by email at [email protected]. We will process your request within 30 calendar days from the date of receipt. In complex cases, we may extend this period by up to 60 days by providing you with prior notice.

Pana21 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service improvements. Each update will be accompanied by a new "Updated" date at the top of this document.

When there are material changes to how we process your data, we will:

• Displaying a clear notice on the pana21 platform homepage at least 14 days before any changes take effect.
• Sending email notices to all registered members with a valid email address on record.
• In cases of highly significant changes, may request your renewed consent before the changes take effect.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how pana21 handles your personal data, our privacy team is ready to assist:

• Privacy Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat icon within the pana21 platform
• Response Time: Privacy-related enquiries will be answered within 5 business days; data rights requests within 30 calendar days

If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia or the relevant regulatory body in your country.

For more information about your rights and how we handle your data, you may also refer to Terms and Conditions us or visit the page FAQ for frequently asked questions related to privacy and your account.