Privacy Policy

1 Introduction

This Privacy Policy (hereinafter "Policy") describes how mm3377 (hereinafter "mm3377", "we", "us", or "our") collects, processes, stores, and protects the personal data of individuals (hereinafter "Player", "User", "you", or "your") who access and use the mm3377 platform at https://mm3377.cam (the "Platform") and any associated services.

mm3377 recognises that your personal data belongs to you. We are committed to processing it lawfully, fairly, and transparently in accordance with applicable data protection legislation, including the principles set out under Malaysia's Personal Data Protection Act 2010 (PDPA) and relevant international data protection standards where applicable.

By creating an mm3377 account or using our Services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform immediately.

2 Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, and behavioural data.
• "Data Controller" means mm3377, as the entity that determines the purposes and means of processing Personal Data collected via the Platform.
• "Data Processor" means any third-party entity that processes Personal Data on behalf of mm3377 under a documented instruction from mm3377.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Sensitive Data" means a subset of Personal Data warranting heightened protection, such as payment account details, identity document numbers, and transaction records.
• "KYC" means the Know Your Customer verification process used to confirm the identity, age eligibility, and lawful status of Players on the Platform.
• "Services" means all products, features, and functions available on the mm3377 Platform, including sports betting markets, live casino games, RNG slots, and customer support.

3 Personal Data We Collect

mm3377 collects Personal Data in several distinct categories depending on how you interact with the Platform. The following table summarises the categories of data we collect and their typical sources:

mm3377 does not collect Special Category Data (such as biometric or health data) unless legally required and with your explicit prior consent.

4 Lawful Basis for Processing

mm3377 processes your Personal Data only where a lawful basis exists. Depending on the purpose of processing, we rely on one or more of the following bases:

• Contractual necessity: Processing required to fulfil your Account registration, execute wagers, process MYR deposits and withdrawals, and provide customer support.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering (AML) regulations, KYC requirements, and reporting obligations to relevant regulatory authorities.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gambling monitoring, and platform analytics — provided our interests are not overridden by your rights.
• Consent: Where you have provided explicit consent, for example to receive promotional communications or to permit non-essential cookies.

5 How We Use Your Personal Data

mm3377 uses the Personal Data we collect for the following specific purposes:

5.1 Account Management

Identity and contact data collected at registration is used to create and maintain your Account, authenticate your identity at login, and communicate account-related notifications such as transaction confirmations, security alerts, and password reset requests.

5.2 Transaction Processing

Financial data is processed to execute deposit and withdrawal requests via supported Malaysian payment channels, including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency wallets. All financial processing is conducted in MYR unless otherwise stipulated.

5.3 Identity Verification (KYC)

Verification data submitted during KYC is processed to confirm your identity, verify your age eligibility (minimum 21 years), validate your source of funds, and comply with our AML and counter-terrorist financing obligations.

5.4 Service Delivery & Improvement

Usage data and cookie data are analysed to monitor Platform performance, identify and resolve technical issues, optimise the user experience across devices and browsers, and develop new features responsive to Malaysian player preferences.

5.5 Responsible Gambling

mm3377 uses betting history and usage pattern data to identify potential indicators of problem gambling behaviour. Where such indicators are detected, we may proactively reach out with responsible gambling resources or apply account restrictions in accordance with our Responsible Gambling Policy.

5.6 Fraud Prevention & Security

IP address data, device fingerprinting, login records, and transaction patterns are monitored to detect and prevent fraudulent activity, unauthorised account access, and prohibited conduct as defined in our Terms & Conditions.

5.7 Marketing Communications

Where you have opted in, we may use your contact data to send promotional emails, SMS notifications, or in-platform messages about bonuses, new game launches, and special offers relevant to Malaysian players. You may unsubscribe from marketing communications at any time via the link in any marketing email or by contacting customer support.

6 Data Sharing & Third-Party Disclosure

mm3377 does not sell your Personal Data. We may share your data with third parties only in the following limited circumstances:

• Payment service providers: To process MYR transactions, your financial data is shared with the relevant payment gateway operators (including FPX, DuitNow, and e-wallet providers) under strict data processing agreements.
• KYC and AML service providers: Identity and verification data may be shared with licensed third-party KYC platforms to facilitate automated identity verification in compliance with AML obligations.
• Game content providers: For live casino and slot games, limited gameplay data may be shared with the relevant game studio provider to resolve disputes and validate round outcomes.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory direction, mm3377 will disclose Personal Data to the relevant authority. We will notify you of such disclosures where legally permissible.
• Professional advisors: Legal counsel, auditors, and insurance providers who process data under professional secrecy obligations where necessary for mm3377's business operations.

All third parties with whom mm3377 shares Personal Data are contractually obligated to process that data only in accordance with mm3377's instructions and applicable data protection laws.

7 Cookies & Tracking Technologies

mm3377 uses cookies and similar tracking technologies to operate core Platform functions and understand how players use our services. Cookies are small text files placed on your device by your browser when you visit the Platform.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for Platform functionality, including maintaining your login session and processing transactions. These cannot be disabled without affecting Platform operation.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method display, and previously viewed sports markets.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate the Platform, enabling us to identify popular features and improve the user experience.
• Security Cookies: Used for fraud detection, bot prevention, and session integrity verification.

7.2 Managing Cookies

You may configure your browser to refuse all or certain cookies, or to alert you when cookies are set. Please note that disabling strictly necessary cookies will impair your ability to log in, place wagers, or process transactions on the Platform. Most major browsers — including Chrome, Firefox, Safari, and Edge — provide cookie management controls in their settings menus.

8 Data Retention

mm3377 retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, tax, accounting, or reporting obligations. The following general retention standards apply:

• Account and KYC data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in line with AML record-keeping requirements.
• Transaction records: Financial transaction data in MYR is retained for a minimum of seven (7) years to comply with applicable accounting and tax regulations.
• Customer support communications: Retained for three (3) years from the date of the last interaction, or longer where the matter is subject to ongoing dispute or legal proceedings.
• Usage and analytics data: Retained in anonymised or aggregated form for up to two (2) years for statistical and platform improvement purposes.
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter to demonstrate lawful basis.

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

9 Data Security

mm3377 implements appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encrypted storage of sensitive data including payment identifiers and identity documents.
• Role-based access controls limiting data access to authorised personnel on a need-to-know basis.
• Regular penetration testing and vulnerability assessments by qualified information security professionals.
• Anomaly detection systems monitoring for unusual access patterns or potential breaches in real time.
• Incident response procedures ensuring timely notification of affected players and authorities in the event of a confirmed data breach, where required by law.

10 Your Data Rights

Subject to applicable law and reasonable verification of your identity, you have the following rights in relation to your Personal Data held by mm3377:

To exercise any of the above rights, please submit a written request to our support team at the contact details provided in Clause 14. We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days. We do not charge a fee for valid data rights requests.

11 International Data Transfers

Some of mm3377's service providers and technology partners — including game studio providers and cloud infrastructure operators — may be located outside Malaysia. Where Personal Data is transferred to jurisdictions that do not provide equivalent data protection standards, mm3377 ensures that appropriate safeguards are in place, such as standard contractual clauses, before any such transfer is made.

mm3377 will not transfer your Personal Data to any country or territory unless the transfer is compliant with applicable data protection law and the recipient provides an adequate level of protection for your Personal Data.

12 Minors & Age Restrictions

The mm3377 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect or process Personal Data from persons under the age of 21.

If we discover or are notified that an Account has been registered by a person under the age of 21, we will immediately suspend the Account, erase all associated Personal Data to the extent legally permissible, void all wagers placed through the Account, and forfeit any associated balances. Parents and guardians who believe their child may have registered on our Platform are encouraged to contact us immediately at the details provided in Clause 14.

13 Updates to This Policy

mm3377 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable legislation, or the Services we offer. The revised Policy will be published on this page with an updated effective date at the top of the document.

Where changes are material — for example, a new category of data being collected or a new processing purpose being introduced — we will provide advance notice to registered Players via the email address associated with their Account, where reasonably practicable. We recommend reviewing this Policy periodically to remain informed of how we protect your data.

14 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by mm3377, please contact our Data Protection team using the details below:

If you believe that mm3377 has not adequately addressed your data protection concern, you have the right to lodge a complaint with the relevant supervisory authority in Malaysia, namely the Department of Personal Data Protection (Jabatan Perlindungan Data Peribadi) under the Ministry of Communications and Digital.