Privacy Policy

This Privacy Policy ("Policy") is issued by PAV88 ("PAV88", "we", "us", "our"), the operator of the online gaming platform accessible at https://pav88.cam (the "Platform"). It describes how we collect, use, store, process, and disclose personal data relating to individuals who access or use our Platform ("you", "User", "Data Subject").

PAV88 is committed to protecting your personal data and to processing it in a lawful, fair, and transparent manner. This Policy has been drafted in accordance with applicable data protection and privacy legislation, including Malaysia's Personal Data Protection Act 2010 (PDPA) and relevant international standards where applicable to cross-border data processing activities.

This Policy applies to all data processing activities carried out by PAV88 in connection with your use of the Platform, including account registration, game play, financial transactions, customer support interactions, and marketing communications. Please read this Policy carefully before using the Platform. By registering an Account or using the Platform, you acknowledge that you have read and understood this Policy.

For the purposes of this Policy, the following terms carry the meanings set out below:

PAV88 collects the following categories of Personal Data in the course of operating the Platform and providing services to registered Users:

• Full legal name as it appears on official identification documents (MyKad, Passport, or Driver's Licence)
• Date of birth (for age verification purposes — PAV88 is a strictly 21+ platform)
• Gender (where provided voluntarily during registration)
• Government-issued identification number (MyKad IC number or Passport number)
• Nationality and country of residence

• Email address (primary method of account communication)
• Malaysian mobile phone number
• Residential address (city, state, postcode — e.g., Kuala Lumpur, Petaling Jaya, Shah Alam, Penang, Johor Bahru)

• Bank account details registered for withdrawals (account holder name, bank name, account number) — e.g., Maybank, CIMB, Public Bank, Hong Leong
• E-wallet identifiers (Touch 'n Go eWallet, Boost, GrabPay, DuitNow account references)
• Deposit and withdrawal transaction history including amounts (MYR/RM), timestamps, and payment method used
• Bonus and promotional credit history
• Cryptocurrency wallet addresses where applicable (BTC, USDT)

• Scanned or photographed copies of government-issued identification documents
• Proof of residential address documents (utility bills, bank statements dated within three months)
• Selfie images submitted alongside identification documents

• Game play history, session durations, wager amounts, and outcomes
• Sports betting market selections and stake history
• Responsible gambling settings (deposit limits, session timers, self-exclusion status)
• Bonus utilisation and wagering requirement progress

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Session logs, access timestamps, and Platform navigation data
• Cookie identifiers and tracking pixel data (see Section 10)

PAV88 collects Personal Data through the following channels and methods:

• Direct collection: Information you provide when creating an Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including IP addresses, cookies, device identifiers, and navigation logs.
• Third-party sources: Identity and address verification data obtained from licensed KYC providers during the verification process; fraud and sanctions screening results from compliance database partners.
• Payment processors: Transaction confirmation data relayed by payment service providers including e-wallet operators (Touch 'n Go, Boost, GrabPay), FPX, DuitNow, and participating Malaysian banks.

PAV88 processes your Personal Data for the following specific, explicit, and legitimate purposes:

PAV88 processes your Personal Data under the following lawful bases as recognised under the PDPA and applicable data protection frameworks:

• Contractual necessity: Processing required to fulfil the Terms & Conditions governing your use of the Platform — including account management, financial transactions, and game provision.
• Legal obligation: Processing necessary to comply with applicable law — including AML legislation, age verification mandates, regulatory reporting requirements, and court orders.
• Legitimate interests: Processing required for PAV88's legitimate operational interests — including fraud prevention, platform security, and responsible gambling monitoring — provided such interests are not overridden by your fundamental rights.
• Consent: Where you have given explicit, freely-given, specific consent for processing — in particular, for receiving direct marketing communications. You may withdraw consent at any time without affecting prior lawful processing.

PAV88 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data only in the circumstances described below, and only to the extent strictly necessary for the stated purpose:

We engage licensed third-party processors who handle Personal Data on our behalf under binding data processing agreements — including KYC identity verification providers, payment gateway operators (e-wallet providers, banks, FPX, DuitNow), IT infrastructure and cloud hosting partners, and cybersecurity service providers. All processors are contractually bound to process data only as instructed by PAV88 and to maintain appropriate security standards.

PAV88 may disclose Personal Data to government agencies, financial intelligence units, regulatory bodies, law enforcement authorities, and courts where required by applicable law — including mandatory AML/CFT reporting obligations — or in response to a lawful order or subpoena.

In the event of a merger, acquisition, restructuring, or sale of all or part of PAV88's business, Personal Data may be transferred to the acquirer or successor entity, subject to equivalent privacy protections. Affected Users will be notified prior to any such transfer where practicable.

In the course of providing the Platform, some Personal Data may be transferred to, stored in, or processed in countries outside Malaysia. PAV88 ensures that any such transfers are conducted in accordance with applicable data protection legislation and are protected by appropriate safeguards — including contractual data protection clauses with the receiving entity, adequacy assessments of the destination jurisdiction, and technical security controls.

Where Personal Data is transferred to third-party game studio partners or technology providers located outside Malaysia, such transfers are governed by written data processing agreements that require the recipient to maintain data protection standards equivalent to those required under Malaysian law.

PAV88 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal retention obligations, or to resolve disputes and enforce our agreements. The following indicative retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be linked to an identifiable individual.

The PAV88 Platform uses cookies and similar tracking technologies to operate core Platform functions, maintain session security, analyse usage patterns, and improve the user experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function — including session authentication, secure login management, and fraud prevention. These cannot be disabled without impacting core functionality.
• Functional Cookies: Store your preferences such as language settings, game display preferences, and previously used payment methods to personalise your experience.
• Analytical Cookies: Collect anonymised data about Platform usage — including pages visited, session duration, and navigation paths — to help us improve the Platform's performance and content.
• Session Cookies: Temporary cookies that expire when you close your browser, used to maintain your login state during a Platform session.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookie categories may affect the functionality of the Platform. PAV88 does not use third-party advertising or behavioural targeting cookies for the benefit of external advertisers.

As a Data Subject, you hold the following rights with respect to your Personal Data processed by PAV88. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request". PAV88 will respond to valid requests within 21 days of receipt.

• Right of Access: You may request a copy of the Personal Data PAV88 holds about you, along with information about how it is processed.
• Right to Correction: You may request that inaccurate or incomplete Personal Data be corrected without undue delay.
• Right to Erasure: In certain circumstances, you may request deletion of your Personal Data — subject to legal retention obligations and legitimate interests (e.g., AML record-keeping) that may override this right.
• Right to Restrict Processing: You may request a limitation on how PAV88 processes your data while a correction request or objection is being reviewed.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request a structured, machine-readable copy of your Personal Data.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. Processing for direct marketing will cease immediately upon a valid objection.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of prior processing.

The PAV88 Platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect, process, or retain any Personal Data relating to individuals under the age of 21. Age verification is conducted as part of the KYC process applied to all registered Users.

If PAV88 becomes aware that Personal Data has been collected from a person under the age of 21 without appropriate verification, we will take immediate steps to suspend the associated Account, delete the collected data, and investigate the circumstances of the registration.

PAV88 implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Industry-standard Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform.
• Encrypted storage of sensitive Personal Data and financial information at rest.
• Role-based access controls limiting staff access to Personal Data on a strict need-to-know basis.
• Two-factor authentication (2FA) available to all registered Users and enforced internally for staff accessing data systems.
• Regular penetration testing and security audits of the Platform's technical infrastructure.
• Data breach response procedures aligned with applicable notification obligations.

Notwithstanding these measures, no method of electronic transmission or storage is completely secure. PAV88 cannot guarantee the absolute security of data transmitted over the internet. Users are strongly encouraged to maintain strong, unique passwords and to enable 2FA on their Accounts.

PAV88 may update this Privacy Policy periodically to reflect changes in our data processing practices, applicable legislation, or Platform services. Material changes — those that significantly affect your rights or how your data is used — will be communicated to registered Users by email to the address on file at least 14 days before the changes take effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the Platform following any update constitutes your acceptance of the revised Policy. If you do not agree to the updated terms, you must discontinue use of the Platform and may request account closure by contacting our support team.

For any queries, concerns, or requests relating to this Privacy Policy or to the processing of your Personal Data by PAV88, please use the following contact details. Note that email addresses below are provided as plain text for reference only and are not clickable links.