Privacy Policy Pavillion88 —
Our Commitment to Protecting Your Data

This Privacy Policy is published by Pavillion88 and applies to all users who access or register on our platform via pavillion88.site or any other interface we operate. It sets out transparently how we handle your personal data from the moment you first visit our platform until you stop using it.

Pavillion88 is a digital entertainment platform offering Live Casino games — including Baccarat, Roulette, and Blackjack — as well as Sports Betting covering EPL and Malaysia Super League football, badminton, e-sports, lottery, and a variety of other games. In operating this platform, we naturally need to collect and process certain personal information from our members.

We take this responsibility very seriously. Your trust is the foundation of everything Pavillion88 does, and we recognise that it can be quickly eroded if personal data is not handled with care and respect. This Privacy Policy is our written commitment to you on how we fulfil that responsibility.

By registering an account with Pavillion88 or continuing to use our platform after any updates, you are deemed to have read and agreed to all provisions of this Privacy Policy. If you do not agree, please stop using the platform and contact us to close your account.

Pavillion88 collects your personal data through several means — directly when you provide it to us, automatically as you use the platform, and in certain cases, from trusted third-party sources. The following are the categories of data we collect:

The personal data we collect is used solely for legitimate and necessary purposes in operating the Pavillion88 platform. We do not use your data for purposes unrelated to the services you have subscribed to. The specific purposes for which data is used are as follows:

• Account management: Creating, verifying, and maintaining your Pavillion88 account, including identity and age verification.
• Transaction processing: Processing deposits via Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow, and FPX Maybank2u; and processing withdrawal of winnings to verified accounts.
• Service provision: Giving you access to all games and features on the Pavillion88 platform, including Live Casino, Sports Betting, and Lottery.
• Customer support: Resolving enquiries, complaints, and technical issues that you report to the Pavillion88 support team.
• Security & fraud prevention: Identifying and investigating suspicious activity, preventing money laundering, and ensuring the platform is used lawfully.
• Responsible gambling: Monitoring gameplay patterns to identify potential gambling-related issues and provide appropriate assistance.
• Platform improvements: Analysing usage data in aggregated, non-identifiable form to understand how players use the platform and improve the overall user experience.
• Marketing communications (with consent): Sending promotions, bonus offers, and the latest news about Pavillion88 — only to members who have given their consent to receive such communications.
• Legal compliance: Meeting the legal and regulatory obligations applicable to Pavillion88 as a platform operator.

Pavillion88 upholds the principle of data minimisation — we only collect data that is genuinely necessary for the purposes stated above. We do not collect excessive data or data that lacks a clear and legitimate purpose.

Pavillion88 does not sell, rent, or disclose your personal data to any third party for their own marketing purposes. However, in operating a complex platform, we do need to share certain data with a limited range of partner categories:

• Payment service providers: Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow, FPX Maybank2u, and CIMB Clicks receive transaction information necessary to process deposits and withdrawals. They are bound by their own Privacy Policies and may not use your data for any other purpose.
• Game software providers: The Live Casino and gaming platforms we use may require minimal session data to function properly. All providers are required to meet privacy standards equivalent to our own.
• Identity verification services: As part of the KYC (Know Your Customer) process, we use trusted third-party services to securely verify your identity documents.
• Legal authorities: Pavillion88 will disclose the necessary data to Malaysian authorities or relevant regulatory bodies when required by law, court order, or a valid official investigation.

Pavillion88 implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, loss, alteration, or disclosure. These measures include:

• Data encryption in transit: All communications between your browser or app and Pavillion88's servers are protected by 256-bit TLS/SSL protocols. You can verify this by looking for the padlock icon and "https" in your browser's address bar.
• Data encryption at rest: Sensitive data stored in our databases is encrypted using industry-standard encryption, ensuring it remains unreadable even in the event of a physical breach.
• Internal access controls: A role-based access control system ensures that only staff who require access to specific data to perform their duties are able to do so. All access is logged and audited.
• 24/7 security monitoring: An automated security monitoring system operates around the clock to detect and respond to any suspicious activity or security threats.
• Regular security testing: Pavillion88 conducts regular penetration testing and vulnerability assessments to identify and address any system weaknesses.

While we take all reasonable steps to protect your data, no security system in the world can guarantee 100% protection under all circumstances. You also play an important role in securing your account — use a strong password, never share your login details with anyone, and contact us immediately if you suspect any unauthorised activity on your account.

Pavillion88 uses cookies and similar tracking technologies to ensure the platform functions correctly and to enhance your experience. The following are the types of cookies we use:

• Essential cookies: Required for core platform functions such as verifying your login session and maintaining account security. Without these cookies, the platform cannot function properly.
• Performance cookies: Collecting aggregated, non-personally identifiable information about how you use the platform — such as pages visited, time spent, and errors encountered. This helps us improve the overall platform experience.
• Functionality cookies: Remembering your preferences such as language, display settings, and login details to make repeat visits more convenient without having to sign in each time.
• Analytics cookies: Used to understand general platform usage patterns for the purposes of product improvement and business planning.

You can manage cookies through your browser settings. However, disabling essential cookies may affect the functionality of the Pavillion88 platform and your overall user experience. The cookies we use do not store sensitive financial information such as card numbers or passwords in any form.

Pavillion88 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. Our data retention principles are as follows:

• Active account data: Retained for the duration your account is active, plus any additional period required for legal compliance after account closure.
• Financial transaction records: Retained for a minimum of seven (7) years from the date of the transaction, in line with Malaysian legal requirements for financial records and anti-money laundering compliance.
• Customer support data: Retained for two (2) years after the issue is resolved to assist with any follow-up cases or disputes that may arise at a later stage.
• Technical & log data: Retained for ninety (90) days for security and technical troubleshooting purposes.

When data is no longer needed and there is no legal obligation to retain it, Pavillion88 will securely delete or anonymise that data using methods that ensure it cannot be recovered. You may request early deletion of your data, subject to limitations set by law, by contacting support@pavillion88.site.

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and Pavillion88's internal policies, you have the following rights regarding your personal data:

Pavillion88 is an entertainment platform for individuals aged Aged 18 and above only. We do not knowingly collect, store, or process any personal data from individuals under the age of 18.

Should we discover that we have inadvertently collected data from an individual under the age of 18, we will take immediate steps to delete that data and close the account in question. Any account found to belong to a minor will be closed immediately, and any legitimate balance will be refunded once the true account holder's identity has been verified.

If you become aware that someone under the age of 18 has registered on Pavillion88, please contact us immediately at support@pavillion88.site so we can take the appropriate action.

In certain situations, your personal data may be transferred to or processed in countries outside Malaysia — for example, when we use infrastructure or software services whose servers are located abroad.

Where such transfers occur, Pavillion88 ensures that:

• The recipient country or entity provides a level of data protection comparable to that required under Malaysian law.
• Appropriate data transfer agreements have been established between Pavillion88 and the receiving parties.
• Transfers are carried out solely for legitimate purposes as stated in this Privacy Policy.

Pavillion88 does not transfer personal data to any country that does not provide an adequate level of protection without appropriate additional safeguards in place.

We understand that financial data is among the most sensitive information there is. When you make a deposit via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX Maybank2u, or CIMB Clicks, your transaction is processed through a secure, encrypted payment system.

With regard to financial data specifically, Pavillion88 :

• We do not store your full credit or debit card number in our systems.
• Do not store your e-wallet or online banking PIN or password.
• Only storing payment method identifiers (e.g., the username or phone number associated with the method) to facilitate accurate verification of withdrawals to the correct payment method.
• Records the amount, date, and method of all transactions for accountability and legal compliance purposes.

Transaction records can be requested at any time through the "Transaction History" section of your account or by contacting Pavillion88 support. These records are useful for monitoring your own account activity and for personal tax purposes where applicable.

Pavillion88 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, technological developments, legal requirements, or other operational reasons.

When significant changes are made:

• The "Last Updated" date at the top of this page will be revised accordingly.
• We will endeavour to provide notice via email or in-platform notification to all active members at least 14 days before the changes take effect.
• For minor changes that do not materially affect your rights, a brief in-platform notice is sufficient.

Your continued use of the Pavillion88 platform after any changes to the Privacy Policy take effect will be considered your acceptance of those changes. We therefore encourage you to review this page periodically, especially after receiving a notice of changes from us.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way Pavillion88 handles your personal data, we are always ready to discuss them with you openly and transparently.

• Privacy Email: support@pavillion88.site (please include "Privacy Enquiry" in the email subject line)
• Live Chat: Available on the Pavillion88 platform, 24 hours a day, 7 days a week
• Support Language: Bahasa Melayu and English
• Response Time: Within 3 business days for general enquiries, and 30 days for formal data rights requests

We are committed to resolving all privacy concerns in a fair and transparent manner. If you are not satisfied with our response, you also have the right to lodge a complaint with the Personal Data Protection Department of Malaysia (PDPD) or the relevant regulatory authority.

For links to other related policy documents, please visit the Terms & Conditions and page Responsible Gaming page. Our FAQ is available at the FAQ.