123 av Privacy Policy – Personal Data Protection for Malaysian Players

1 Introduction

123 av takes the privacy of our players seriously. As a sports betting and online casino platform serving hundreds of thousands of Malaysian players, we recognise that your trust is the most valuable asset we hold. This Privacy Policy has been carefully prepared to ensure you have a full understanding of how your personal information is managed from start to finish.

This 123 av Privacy Policy applies to all services provided through the website 123av-app.com, including account registration, deposits and withdrawals via Touch 'n Go eWallet, GrabPay, DuitNow, and other Malaysian payment methods, as well as all betting activities conducted through our platform.

This policy is drafted in accordance with the requirements of Personal Data Protection Act 2010 (PDPA) Malaysia. We are committed to complying with all provisions of the Act and ensuring your rights as a data subject are fully protected.

2 Personal Information We Collect

123 av collects various types of personal information when you register and use our platform. We only collect what is strictly necessary for legitimate purposes.

Information You Provide Directly

• Full name as shown on your Malaysian MyKad or passport.
• Identity card number (MyKad) or passport number.
• Date of birth for age verification (must be 21 or above).
• An active email address for account communications.
• Malaysian phone number for SMS verification and communications.
• Residential address in Malaysia.
• Payment method details – bank account number, TnG eWallet account name, GrabPay, or other payment methods.
• Identity verification (KYC) documents such as a photo of your MyKad, utility bill, or bank statement.

Automatically Collected Information

• IP address and geographical location information.
• Device type, operating system, and web browser used.
• Platform usage data including pages visited, time of visit, and actions taken.
• Betting history and financial transaction records within the 123 av platform.
• Cookie data and session identifiers.
• Technical logs and system access records.

3 How We Use Your Personal Data

123 av uses your personal data solely for legitimate and necessary purposes. Below is a full explanation of how your information is used on the 123 av platform:

• Account Management: Creating, verifying, and maintaining your 123 av account, including the KYC process and age verification.
• Transaction Processing: Processing deposits via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX, and withdrawals to your Malaysian bank account.
• Service Delivery: Gives you access to all 123 av products including Sports Betting, Baccarat, Live Casino, slots, e-sports, and Virtual Sports.
• Platform Security: Detecting and preventing fraud, money laundering, bot activity, and any suspicious behaviour that could compromise the integrity of the platform.
• Legal Compliance: Meeting compliance obligations under Malaysia's PDPA 2010 and fulfilling reporting requirements to relevant authorities when required by law.
• Service Communications: Sending important notifications regarding your account, transactions, security, and platform updates via email or SMS.
• Marketing (with consent): Sending you promotional information, bonuses, and exclusive 123 av offers — only if you have opted in to receive marketing communications.
• Platform Improvements: Analysing usage patterns to improve the betting experience, platform speed, and customer service quality at 123 av.

4 Sharing Data with Third Parties

123 av does not sell or rent your personal data to any third party. However, in the course of operating the platform, we may need to share certain information with the following parties under limited and controlled circumstances:

Trusted Service Providers

We work with third-party service providers that help us operate the 123 av platform, including payment processors (such as FPX and DuitNow gateways), cloud service providers, data analytics companies, and identity verification providers. All such providers are required to comply with strict data security standards and may only use your data in accordance with our instructions.

Authorities & Regulatory Bodies

123 av may be required to disclose your personal information to Malaysian government authorities, regulatory bodies, or law enforcement when mandated by law, court order, or in the context of a legitimate investigation. In such circumstances, we will endeavour to notify you in advance unless prohibited by law.

Business Transfer

In the event that 123 av is involved in any merger, acquisition, or sale of assets, player personal data may be transferred as part of that transaction. You will be notified in advance and will have the right to delete your account before any transfer takes place.

5 Personal Data Security

Protecting your personal data is a responsibility we take very seriously at 123 av. We implement multiple layers of technical and organisational security measures to ensure your information is always kept safe:

• Data Encryption: All data in transit is protected with 256-bit TLS/SSL encryption. Sensitive data at rest, such as passwords and payment information, is also encrypted using the latest industry-standard encryption algorithms.
• Access Controls: Access to players' personal data is restricted solely to 123 av staff who require it to carry out their duties. All access is logged and audited on a regular basis.
• Two-Factor Authentication (2FA): 123 av's internal systems require two-factor authentication for all staff access to databases containing player information.
• Threat Detection System: We operate a 24/7 security monitoring system with intrusion detection and prevention (IDS/IPS) to identify and respond to cyber threats in real time.
• Regular Security Testing: The 123 av infrastructure undergoes regular penetration testing and vulnerability assessments conducted by independent security experts.
• Data Backup: Player data is automatically and periodically backed up to a secure, separate location to ensure service continuity in the event of any system failure.

While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage can be guaranteed to be 100% secure. You also play an important role in keeping your account safe by using a strong password and never sharing your login details with anyone.

6 Use of Cookies

123 av 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.

Types of Cookies We Use

You can manage and delete cookies through your web browser settings. Please note, however, that disabling certain cookies may affect the functionality and user experience of the 123 av platform.

7 Data Retention & Deletion

123 av retains your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required under applicable Malaysian law.

• Active Account Data: Retained for the lifetime of your active account at 123 av and for a minimum of 7 years after account closure to meet anti-money laundering (AML) compliance requirements.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with Malaysian accounting and tax legal requirements.
• Communication Logs: Customer support communication records are retained for 3 years.
• Marketing Data: Retained until you withdraw your marketing consent, after which it will be deleted within 30 days.
• KYC Documents: Retained for the period required by law, typically no less than 5 years after the business relationship ends.

Once the retention period has expired and there is no legal requirement to keep the data, 123 av will securely delete or anonymise your personal data using industry-recognised methods.

8 Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010, you have certain rights regarding your personal data held by 123 av. We fully respect these rights:

To exercise any of the rights above, please contact the 123 av privacy team by email at support@123av-app.com or via our platform's live chat. Requests will be processed within 30 days of receipt. We may require identity verification before processing your request.

9 Children's Privacy

The 123 av platform is exclusively for individuals aged 21 and above. We do not knowingly collect or process personal data from individuals under the age of 21. If we discover that personal data of an underage individual has been collected without our knowledge, we will take immediate steps to delete that data and close the relevant account.

10 Links to Third-Party Sites

The 123 av platform may contain links to third-party websites related to our services. Please be aware that 123 av's Privacy Policy does not apply to any such third-party websites. We are not responsible for the privacy practices or content of third-party sites.

We encourage you to read the privacy policy of every website you visit. Links to third-party sites are provided solely for your convenience and do not constitute an endorsement or approval by 123 av of their content or privacy practices.

11 Amendments to This Privacy Policy

123 av reserves the right to modify, add to, or remove any part of this Privacy Policy at any time. Any material amendments will be communicated to you through one or more of the following methods:

• Email notifications sent to the address registered on your account.
• A prominent notice on the 123 av platform homepage.
• An in-app notification pop-up upon login after the amendment takes effect.

Amendments take effect on the date stated in the notice. Your continued use of the 123 av platform after that date constitutes your acceptance of the amended Privacy Policy. The "Last Updated" date at the top of this page will always reflect the latest version.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12 Contact Us – Privacy Enquiries

If you have any questions, concerns, or complaints regarding this Privacy Policy or how 123 av handles your personal data, we strongly encourage you to reach out to us. Our dedicated privacy team is ready to assist you:

• Privacy Email: support@123av-app.com
• Live Chat: Available 24/7 at the bottom-right corner of the 123 av platform
• Target Response Time: Within 2 hours via live chat, within 24 hours via email
• Support Operating Hours: 24 hours a day, 7 days a week, including Malaysian public holidays

We are committed to handling every privacy inquiry and complaint with seriousness, fairness, and transparency. Your satisfaction and trust are 123 av's top priorities.

You may also refer to the website of Malaysia's Personal Data Protection Department for more information about your rights under the PDPA 2010.