Privacy Policy surga11 — Malaysia User Data Protection

Surga11 collects users' personal information for lawful and specific purposes only. The types of data we collect depend on how you interact with our platform — whether during registration, active use, or through customer support.

Information you provide directly:

• Full name, date of birth, identification card number (MyKad) or passport during account registration.
• Email address, phone number, and residential address for verification and communication purposes.
• Financial information including bank account numbers, account holder names, and e-wallet details (TNG, GrabPay) during the deposit or withdrawal process.
• KYC (Know Your Customer) supporting documents such as MyKad photos, bank statements, or utility bills when requested.
• Communication records with the surga11 customer support team via live chat or email.

Information collected automatically:

• IP address, device type, operating system, browser type, and screen resolution.
• Session data includes login time, session duration, and pages visited within the platform.
• Gaming activity records: types of games played, wagering amounts, wins, and transaction history.
• Coarse location data based on IP address for geographical region verification purposes.

All data collection carried out by surga11 is based on operational requirements, compliance with applicable licensed online gambling laws, and the continuous improvement of the user experience.

Every piece of data collected by surga11 is used for clear and legitimate purposes. We do not process your personal data for purposes unrelated to the operation of the platform or the services you use.

Primary purposes of data use:

• Account management: Creating, verifying, and maintaining your surga11 account to keep it secure and fully functional.
• Transaction processing: Ensuring all deposits, withdrawals, and wagering are processed accurately and promptly.
• Identity verification (KYC): Meeting licensing compliance requirements by verifying user age and identity before authorising fund withdrawals.
• Fraud prevention: Detecting suspicious activity patterns, including multiple account usage, money laundering, or attempts to exploit the system.
• Customer support: Resolving complaints, responding to enquiries, and providing effective technical assistance to users.
• Experience Personalization: Personalising game recommendations, promotional offers, and the user interface based on your usage habits and preferences.
• Targeted marketing: Sending promotional notifications, bonus offers, and relevant platform updates — only if you have given your consent to receive them.
• Platform analytics: Understanding aggregate usage patterns to continuously improve the performance, usability, and security of the surga11 platform.

Surga11 does not sell or rent users' personal data to any third party for commercial purposes. However, there are specific situations where data sharing is necessary to ensure the platform operates properly and complies with applicable laws.

Third parties who may receive your data:

• Payment service providers: FPX, Touch 'n Go eWallet, GrabPay, Maybank2u, and cryptocurrency payment providers require specific transaction data to process your deposits and withdrawals.
• Game software providers: Third-party software providers operating games within the surga11 platform may receive game session data necessary to run the games properly.
• Regulatory authorities: surga11 is required to disclose user data to licensing regulatory bodies, law enforcement agencies, or courts when mandated by law or court order.
• Third-party identity verification: surga11 uses licensed third-party KYC verification services to securely process user identity document checks.
• Analytics services: Aggregated and anonymised data may be used for platform analytics via tools that help surga11 understand overall usage patterns.

All third parties working with surga11 are bound by strict data protection agreements and are only permitted to process user data in accordance with the instructions and purposes specified by surga11. They are not permitted to use such data for their own personal or commercial purposes.

The surga11 platform uses cookies and similar tracking technologies to enhance the user experience, maintain login session security, and understand how users interact with our platform.

Types of cookies we use:

• Essential cookies: Required for core platform operations — including login session management, security, and game cart functionality. These cookies cannot be disabled without affecting platform functionality.
• Performance cookies: Collecting information on how pages are used, errors that occur, and page load times to help us continuously improve the platform.
• Functional cookies: Saving your preferences such as language, text size, and display settings so you do not need to reconfigure them every time you log in.
• Analytics cookies: Used to understand overall platform usage patterns in aggregate. This data is not linked to your personal identity.

Surga11 does not use third-party cookies for cross-site advertising purposes or to build personalised advertising profiles of users.

User data protection is an absolute priority at surga11. We continuously invest in security infrastructure and adopt a multi-layered approach to ensure your data remains safe at all times.

• 256-bit SSL/TLS encryption: All communications between your device and surga11's servers are encrypted using industry-standard security protocols, making data virtually impossible to intercept during transmission.
• Data-at-rest encryption: Sensitive data stored in surga11's databases — including financial information and identity documents — is encrypted using AES-256 encryption.
• Two-factor authentication (2FA): Users are encouraged to enable 2FA, which adds an extra layer of security to their account beyond the standard password.
• Real-time threat monitoring: The surga11 system monitors platform activity 24/7 to detect and respond to unauthorised access attempts or suspicious activity.
• Regular penetration testing: surga11 conducts regular security testing by independent security experts to identify and patch system vulnerabilities before they can be exploited.
• Internal access controls: surga11 staff access to user data is restricted based on the principle of least privilege — only personnel who require the data for their specific duties are permitted to access it.

Surga11 fully respects your rights as the owner of your personal data. You have the right to act on your data at any time by contacting the surga11 support team or through your account settings.

Surga11 retains users' personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. Once the retention period has ended, data will be securely deleted or anonymised.

When data is no longer needed, surga11 uses secure deletion methods to ensure the data cannot be recovered. For data in physical format (where applicable), secure disposal procedures are applied.

The surga11 platform is an adult entertainment service strictly intended for users aged 18 years and above. Surga11 does not intentionally collect or process any personal data from individuals under the age of 18.

• All account registrations require age verification through a rigorous KYC process.
• If surga11 discovers that data belonging to an underage minor has been inadvertently collected, such data will be deleted immediately and the associated account will be closed.
• Parents or guardians who suspect their child has registered an account on surga11 should contact our support team immediately for prompt action.

Surga11 reserves the right to update or amend this privacy policy from time to time to reflect changes in our data practices, legal requirements, or service improvements. All material amendments will be communicated to users via:

• In-platform notification on surga11 within at least 7 days before the changes take effect.
• Notification email to your registered email address.
• Update the "Last Updated" date displayed prominently at the top of this privacy policy page.

Your continued use of the surga11 platform after any privacy policy amendments take effect constitutes your acceptance of and agreement to the updated terms. If you do not agree with the amendments, you have the right to close your account and request withdrawal of any remaining legitimate funds.

For any enquiries, concerns, or requests relating to this privacy policy, please contact the surga11 Data Protection Officer via live chat within the platform. Our team is available to assist you 24 hours a day, 7 days a week.