Privacy Policy Hugo77 – Data Protection Malaysian Users

Welcome to the hugo77 Privacy Policy. This document transparently and clearly explains how the hugo77 platform ("we", "hugo77", "Platform") collects, uses, discloses, stores, and protects your personal information when you use our website, mobile app, or any services we provide.

User privacy is hugo77's highest priority. We understand that your trust in us depends largely on how we handle your personal information. We are therefore committed to ensuring every aspect of your data handling complies with Malaysia's Personal Data Protection Act 2010 (PDPA) and the highest international standards.

By registering a hugo77 account, using our app, or browsing our website, you agree to acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the hugo77 platform immediately.

Hugo77 collects various categories of information depending on how you interact with our platform. This data collection is necessary to provide you with a secure, seamless, and personalized experience.

Information you provide directly:

• Full name as it appears on your official identification document.
• Date of birth and age information for eligibility verification purposes.
• Mobile number and email address for communication and verification.
• Bank account or digital wallet information for deposit and withdrawal purposes.
• Copies of identity documents (KYC) such as a national ID or passport.
• Financial transaction history within the platform, including deposits, bets, and withdrawals.

Information collected automatically:

• IP address and geographic location information (city/country level).
• Device type, operating system, web browser version, and screen size.
• Platform usage data including pages visited, session duration, and interaction patterns.
• Cookie information and device identifiers for account verification and security.
• Error logs and technical diagnostic reports for platform improvement purposes.

Every piece of information collected by hugo77 is used solely for legitimate and necessary purposes to provide you with a high-quality service. We do not use your data for purposes you would not expect.

• Service Provision: Processing registrations, verifying identity, enabling deposits and withdrawals, and granting access to all platform games.
• Security and verification: Identifying unauthorized access attempts, preventing fraud, and protecting the integrity of your account.
• Legal compliance: Meeting KYC, AML (anti-money laundering) obligations and applicable regulatory reporting requirements.
• Customer support: Helping resolve inquiries, complaints, and technical issues you encounter.
• Platform improvements: Analyzing usage patterns to improve the interface, performance, and overall user experience.
• Important communications: Sending notifications related to account security, terms updates, transaction information, and promotions you have opted in to receive.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling and offer appropriate support.

Hugo77 does not sell, rent, or transfer your personal information to third parties for marketing purposes. However, under certain limited and controlled circumstances, we may share your information with the following parties:

• Payment providers: Registered and approved payment gateway providers such as FPX, DuitNow, and digital wallet providers to securely process your financial transactions.
• Game providers: Game software companies partnering with hugo77 may receive the minimum information required to deliver a smooth gaming experience.
• Technical service providers: Cloud infrastructure, analytics, and security providers that help us operate the platform — all bound by strict data protection agreements.
• Regulatory authorities: When required by law, court order, or a valid request from a relevant law enforcement agency.
• Fraud investigation: Sharing of necessary information with industry bodies or security agencies to address suspected fraudulent activity.

Protecting your personal information from unauthorized access, loss, or disclosure is an absolute priority for hugo77. We continuously invest in the latest security infrastructure to ensure your data remains protected at all times.

Technical security measures we implement:

• 256-bit SSL/TLS Encryption: All communications between your device and hugo77's servers are encrypted using the highest industry standards.
• Data-at-rest encryption: Sensitive data stored in our databases is encrypted using AES-256 for layered protection.
• Two-Factor Authentication (2FA): An additional security layer is available and recommended for all user accounts.
• 24/7 Monitoring: Our security team and automated systems monitor platform activity around the clock to proactively detect threats.
• Regular security audits: Penetration testing and security audits are conducted regularly by certified independent experts.
• Role-based access control: Only authorised personnel with a legitimate business need may access specific categories of user data.

While we take all reasonable precautions, no security system is completely impenetrable. In the event of any data breach affecting your information, we will notify you and the relevant authorities within the timeframe required by law.

Hugo77 uses cookies and similar tracking technologies to ensure the platform operates smoothly and to deliver a better user experience. Cookies are small text files stored in your web browser or on your device.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login authentication, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: Storing your preferences such as language, display settings, and game preferences to deliver a personalized experience.
• Analytics Cookies: Helping us understand how users interact with the platform so we can make meaningful improvements. This data is collected in aggregate and does not identify individuals.
• Security Cookies: Used to detect suspicious access attempts, prevent fraud, and protect the integrity of your session.

You can manage and delete cookies through your web browser settings at any time. Please note that disabling essential cookies may affect your ability to use certain features of the hugo77 platform.

As a hugo77 user and under the provisions of Malaysia's Personal Data Protection Act 2010, you hold the following rights regarding your personal information:

To exercise any of the above rights, please contact the hugo77 privacy team by email at [email protected]. We will process your request within 30 business days. In complex cases, this period may be extended up to 60 days with notice to you.

Hugo77 retains your personal information only for as long as needed to fulfil the original purpose of collection or to comply with applicable legal requirements. Our data retention policy is as follows:

• Active account data: Retained for the duration your account remains active, plus the defined retention period following account closure.
• Financial transaction records: Retained for a minimum of 7 years in compliance with Malaysia's financial and tax legal requirements.
• KYC and identity verification records: Retained for 5 years after the termination of the business relationship, in line with AML requirements.
• Security and access logs: Retained for 12 months for security incident investigation purposes.
• Support communication records: Retained for 3 years for reference and dispute resolution.
• Analytics data: Anonymised aggregate data is retained for a maximum of 2 years for trend analysis and platform improvement purposes.

When data is no longer needed and there is no legal obligation to retain it, we will securely delete it using methods that ensure it cannot be recovered.

Hugo77 integrates with several third-party services necessary to deliver a complete user experience. While we select our partners with care, the hugo77 Privacy Policy applies only to our own platform.

Third-party services integrated with hugo77 include:

• Payment gateway providers for processing deposits and withdrawals.
• Gaming software providers and live casino content providers.
• Digital identity verification services for the KYC process.
• Cloud infrastructure and cybersecurity providers.

Each of these third-party providers has its own privacy policy. Hugo77 is not responsible for the privacy practices or content of any third party. We encourage you to read the privacy policies of those providers when interacting with their services.

The hugo77 platform is strictly for individuals aged 18 and above. We do not knowingly collect, process, or store personal information from underage individuals.

Child protection measures we implement:

• The registration process requires date-of-birth verification and a valid identity document.
• Rigorous KYC checks ensure that only individuals aged 18 and above can complete full registration.
• Any account suspected of belonging to an underage individual will be suspended immediately pending verification.
• If we discover that we have inadvertently collected information from a child, we will delete it immediately.

Hugo77 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological developments. Any amendments made are intended to ensure your data protection remains relevant and adequate.

When we make significant amendments, we will:

• Updating the "Last Updated" date shown at the top of this page.
• Displaying a clear notice on the hugo77 platform homepage for a minimum of 14 days.
• Sending email notifications to all registered users to inform them of important changes.
• In the case of highly significant amendments, we may request renewed consent from users before the changes take effect.

Your continued use of the hugo77 platform after the effective date of any amendments will be considered your acceptance of the updated Privacy Policy. If you do not agree with the changes, you have the right to close your account.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal information, the hugo77 privacy team is always ready to assist.

You may reach us via:

• Privacy Email: [email protected]
• Response Time: We aim to respond to all privacy inquiries within 3–5 business days.
• Language: You may contact us in Malay or English.

For official complaints or requests relating to your rights under PDPA, you may also contact the Department of Personal Data Protection Malaysia (JPDP) through their official channels.