Privacy Policy — PJS138

Introduction

This Privacy Policy ("Policy") describes how PJS138 ("PJS138", "we", "us", "our"), the operator of the online casino and sports betting platform accessible at https://pjs138.click, collects, uses, stores, and discloses personal data relating to users of the Platform ("you", "User", "Player").

PJS138 takes its obligations under applicable data protection and privacy legislation seriously. We collect only the personal data that is necessary for the purposes described in this Policy, and we handle that data with appropriate care, security measures, and respect for your rights.

By registering an account on PJS138 or by continuing to use the Platform after this Policy has been communicated to you, you acknowledge that you have read and understood the terms of this Policy. Where your continued use of the Platform constitutes consent to specific forms of data processing, that consent is noted in the relevant section below.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall contractual relationship between you and PJS138.

Definitions

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

Data We Collect

PJS138 collects Personal Data through several channels in the course of providing our services. The categories of data we collect, and the contexts in which collection occurs, are described below.

3.1 Account Registration Data

When you create a PJS138 account, we collect:

• Full legal name;
• Date of birth (to verify you are aged 21 or above);
• Residential address (including city, state, and postcode);
• Email address;
• Mobile phone number;
• Chosen username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations, we collect:

• Copy of government-issued photo identification (Malaysian IC / MyKad, passport, or equivalent);
• Proof of residential address (utility bill, bank statement, or official correspondence dated within 90 days);
• Payment method verification documents (e.g., screenshot of e-wallet account or bank statement confirming account ownership);
• Selfie or live facial image for identity matching, where required.

3.3 Financial Transaction Data

In connection with deposits and withdrawals, we record:

• Transaction amounts in MYR and, where applicable, cryptocurrency equivalent values;
• Payment method type (e.g., DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, BTC, ETH, USDT, BNB);
• Transaction timestamps, reference numbers, and processing status;
• Masked payment identifiers (e.g., partial bank account or e-wallet numbers) — full card or account numbers are not stored by PJS138.

3.4 Platform Usage & Technical Data

We automatically collect certain technical data when you access the Platform:

• IP address and approximate geolocation derived therefrom;
• Device type, operating system, and browser version;
• Session duration, pages visited, game titles played, and betting activity;
• Cookie identifiers and session tokens (see Section 10);
• Referral source (the URL or channel from which you arrived at the Platform).

3.5 Communications Data

When you contact our support team via Live Chat or email, we retain records of those communications, including the content of messages, timestamps, and any attachments provided, for the purposes of service delivery, dispute resolution, and quality assurance.

How We Use Your Data

PJS138 uses collected Personal Data for the following purposes:

Legal Basis for Processing

PJS138 processes Personal Data on the following legal bases, depending on the specific purpose for which the data is used:

• Contractual Necessity: Processing required to enter into or perform the contract with you (i.e., the Terms & Conditions governing your Account), including account creation, transaction processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable law, including AML/CTF obligations, KYC requirements, age verification mandates, and responses to lawful requests from regulatory or law enforcement authorities.
• Legitimate Interests: Processing carried out in pursuit of PJS138's legitimate business interests where those interests are not overridden by your rights and freedoms — including fraud prevention, platform security, dispute resolution, and service improvement based on aggregated analytics.
• Consent: Processing based on your freely given, specific, and informed consent — primarily in relation to direct marketing communications. You may withdraw consent for marketing at any time by contacting our support team or using the unsubscribe mechanism in any marketing email received.

Data Sharing & Disclosure

PJS138 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We may share Personal Data with the following categories of recipient, and only to the extent necessary for the stated purpose:

• Payment Processors and Financial Service Providers: Malaysian payment gateway operators (including those facilitating DuitNow, FPX, Touch 'n Go eWallet, Boost, and bank transfers via Maybank, CIMB, Public Bank, Hong Leong), cryptocurrency payment processors, and fraud detection services — for the purpose of processing financial transactions.
• KYC and Identity Verification Providers: Third-party services engaged to verify the identity, age, and address of Players in compliance with AML obligations. These providers process only the minimum data necessary for verification.
• Game Content Providers: Licensed third-party game studios and software suppliers whose games are accessible on the Platform. Game providers receive session data necessary to deliver gameplay but are not provided with full account or financial data.
• IT and Hosting Providers: Infrastructure and cloud service providers engaged by PJS138 to host and maintain the Platform. These providers operate under data processing agreements that restrict their use of Personal Data.
• Regulatory and Law Enforcement Authorities: Where required or permitted by applicable law, PJS138 may disclose Personal Data to government agencies, regulators, police forces, or courts. We will notify you of any such disclosure where legally permitted to do so.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations, where disclosure is necessary for the conduct of their professional services.

International Data Transfers

In some cases, the Personal Data we collect may be transferred to, stored in, or processed in countries outside Malaysia. This may occur where our game content providers, KYC verification services, or IT infrastructure partners are based in other jurisdictions.

Where such transfers take place, PJS138 ensures that appropriate safeguards are in place to protect your Personal Data to a standard at least equivalent to that required under applicable Malaysian data protection law. Safeguards may include contractual data protection clauses, the use of providers operating in jurisdictions with recognised adequate data protection standards, or other lawful transfer mechanisms.

Data Retention

PJS138 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, and in any event no longer than required by applicable legal and regulatory obligations. The following indicative retention periods apply:

• Account and identity verification data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in compliance with AML record-keeping obligations.
• Financial transaction records: Retained for a minimum of seven (7) years from the date of the transaction, as required by financial record-keeping regulations.
• Customer support communications: Retained for three (3) years from the date of the communication, unless a longer period is required in connection with an ongoing dispute or legal proceeding.
• Platform usage and technical logs: Retained for up to twelve (12) months for operational and security monitoring purposes, after which logs are anonymised or deleted.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, to evidence compliance.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised in accordance with our internal data disposal procedures.

Your Rights

Subject to applicable law, you have the following rights in relation to the Personal Data PJS138 holds about you. To exercise any of these rights, please contact our support team via Live Chat or email (see Section 15).

PJS138 will respond to all rights requests within thirty (30) days of receipt. We may request additional information to verify your identity before processing any request. In certain circumstances, we may be unable to fulfil a request — for example, where retention is required by law — in which case we will explain the reasons in our response.

Cookies & Tracking Technologies

PJS138 uses cookies and similar technologies (including browser local storage and session tokens) to provide, maintain, and improve the Platform. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in during your visit. They cannot be disabled without preventing the Platform from working.
• Functional Cookies: Remember your preferences (such as language selection and display settings) to personalise your experience on return visits.
• Analytical Cookies: Collect aggregate, anonymised data about how users navigate and interact with the Platform, enabling us to identify and address usability issues and improve performance.
• Security Cookies: Used to detect and prevent fraudulent activity, including session hijacking and credential-stuffing attacks.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. PJS138 does not use third-party advertising or behavioural tracking cookies.

Minors & Age Restrictions

The PJS138 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect Personal Data from persons under the age of 21. Age verification is a mandatory step in our registration and KYC process.

If PJS138 becomes aware that Personal Data has been collected from a person under the age of 21, we will immediately suspend the relevant Account, delete the data in question to the extent permitted by applicable law, and — where required — report the matter to relevant authorities.

If you believe that a minor has registered an account on PJS138, please notify our support team immediately via Live Chat or by email at [email protected].

Data Security

PJS138 implements a comprehensive set of technical and organisational security measures to protect Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. Key measures include:

• Transport Layer Security (TLS): All data transmitted between your device and the Platform is encrypted in transit using current industry-standard TLS protocols;
• Encryption at Rest: Sensitive stored data, including KYC documents and account credentials, is encrypted at rest using appropriate encryption standards;
• Access Controls: Personal Data is accessible only to PJS138 personnel and authorised Data Processors with a demonstrated need for access in the course of their duties;
• Penetration Testing: The Platform undergoes regular independent security assessments to identify and remediate vulnerabilities;
• Two-Factor Authentication (2FA): Available to all Players as an additional layer of account security — we strongly encourage its use;
• Incident Response: PJS138 maintains a documented data breach response procedure. In the event of a breach likely to affect your rights and freedoms, we will notify you as required by applicable law.

Third-Party Services & Links

The Platform may display or reference third-party game providers, whose software runs within the PJS138 environment. These providers operate under their own privacy notices with respect to data generated within their game environments. Where a game session generates player-identifiable data, that data is processed under the applicable game provider's data processing agreement with PJS138.

PJS138 does not operate social media accounts linked directly from the Platform, nor does it embed third-party social sharing or advertising widgets that collect data independently from PJS138's own infrastructure.

PJS138 accepts no responsibility for the privacy practices of any third-party website or service that you access independently of the Platform, including any website you may navigate to after leaving https://pjs138.click.

Policy Amendments

PJS138 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, the services we offer, or applicable legal requirements. Where amendments are material, we will notify registered Players via email or through a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy reflects the date on which the most recent amendments were made. We recommend that you review this Policy periodically. Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the updated Policy.

Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a concern about our data practices, please contact our Data Privacy team through any of the following channels:

• Live Chat: Available 24/7 on the Platform. State that your enquiry relates to a data privacy or Personal Data matter so that it is routed to the appropriate team member. Average first response under 5 minutes.
• Email: [email protected] (plain text — not a clickable link). Please include "Privacy Request" in the subject line and provide your Account username for faster processing.
• Languages: Privacy requests are handled in English, Bahasa Melayu, and Chinese. We aim to respond to all privacy-related requests within thirty (30) days of receipt.

If you are dissatisfied with our handling of a privacy concern after contacting us directly, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. PJS138 will cooperate fully with any such regulatory inquiry.