pace88 Privacy Policy

1. Data Controller

pace88 ("pace88", "we", "us", "our") is the data controller responsible for personal data collected through the pace88 website and platform accessible at https://pace88.app and all associated services (collectively, the "Platform"). As data controller, pace88 determines the purposes and means of processing personal data as described in this policy.

This Privacy Policy is issued in compliance with the Personal Data Protection Act 2010 (PDPA) of Malaysia and applicable data protection principles. By accessing or using the pace88 Platform, you acknowledge that you have read and understood this policy and consent to the collection and processing of your personal data as described herein.

2. Personal Data We Collect

pace88 collects the following categories of personal data from players and prospective players:

• Identity Data: Full legal name, date of birth, gender, nationality, government-issued identification number (e.g., MyKad number, passport number).
• Contact Data: Registered email address, mobile phone number, residential address (city, postcode, state, country).
• Financial Data: Payment method details (e.g., Touch 'n Go eWallet account reference, Boost account reference, bank account number associated with FPX transactions), deposit history, withdrawal history, transaction timestamps, and account balance records.
• KYC Verification Data: Copies of government-issued photo identification, proof of address documents, selfie verification images where required, and related correspondence.
• Account Data: Username, encrypted password hash, account registration date, account status, login history, session timestamps, and IP address logs.
• Gaming Activity Data: Game participation records, bet amounts, game outcomes, bonus usage, wagering activity, and responsible gaming settings applied to your account.
• Technical Data: Device type and operating system, browser type and version, screen resolution, referring URL, pages visited, click patterns, and other interaction data collected via cookies and analytics tools.
• Communications Data: Records of your communications with pace88 support, including chat transcripts, email correspondence, and any information you voluntarily provide in support interactions.

3. How We Collect Your Data

pace88 collects personal data through the following means:

• Direct Provision: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact support, or participate in a promotion, you provide data directly to us.
• Automated Collection: When you access and interact with the Platform, we automatically collect technical and usage data through server logs, cookies, pixels, and similar tracking technologies.
• Third-Party Sources: Where required for identity verification or fraud prevention, we may receive personal data from third-party identity verification providers, payment processors, or credit reference agencies. pace88 will only act on such data to the extent permitted by applicable law.
• Payment Processors: When you transact via Touch 'n Go eWallet, Boost, or bank FPX services, the relevant payment processor shares transaction confirmation data with pace88 to credit or debit your account.

4. Purpose of Processing

pace88 processes personal data for the following purposes:

• To establish, manage, and maintain your pace88 account, including processing deposits, withdrawals, and bonus claims.
• To perform Know Your Customer ("KYC") and age verification checks in compliance with applicable regulatory obligations. pace88 will not permit withdrawals from unverified accounts.
• To prevent, detect, and investigate fraud, money laundering, collusion, cheating, and other prohibited conduct as defined in our Terms & Conditions.
• To fulfil anti-money laundering ("AML") and counter-terrorist financing ("CTF") obligations under applicable law.
• To provide customer support and respond to player enquiries and complaints.
• To enforce our Terms & Conditions, Responsible Gaming policy, and other applicable policies.
• To personalise your experience on the Platform, including recommending games and promotions based on your activity history where you have not opted out of such personalisation.
• To send transactional communications (e.g., deposit confirmations, withdrawal updates, account security alerts). Transactional communications cannot be opted out of while your account is active.
• To send promotional and marketing communications where you have given explicit consent or where pace88 has a legitimate interest, subject to your right to opt out at any time.
• To analyse aggregate Platform usage for product improvement, security enhancement, and business planning purposes.

5. Legal Basis for Processing

pace88 processes personal data on the following legal bases under the PDPA and applicable data protection law:

• Consent: Where you have given clear, freely given, specific, and informed consent — for example, for marketing communications and optional analytics.
• Contractual Necessity: Processing required to fulfil our obligations to you as a registered player, including account management, payment processing, and support.
• Legal Obligation: Processing required to comply with AML, CTF, KYC, and other regulatory obligations applicable to pace88.
• Legitimate Interests: Processing conducted for pace88's legitimate business interests, including fraud prevention, platform security, and product improvement — provided such interests are not overridden by your privacy rights.

6. Data Sharing & Disclosure

pace88 does not sell personal data to third parties. We share data only in the following circumstances and only to the extent necessary:

• Payment Processors: Transaction data is shared with Touch 'n Go eWallet, Boost, Maybank, CIMB, and Public Bank solely to process deposits and withdrawals.
• Identity Verification Providers: KYC document data may be shared with certified third-party identity verification service providers for the sole purpose of verifying your identity and age.
• Game Providers: Your username and session token (not full identity data) are shared with game studios operating on the Platform to enable gameplay.
• Regulatory Authorities: pace88 may disclose personal data to law enforcement, regulatory authorities, or courts where required to do so by law, court order, or in response to a lawful request.
• Fraud & AML Networks: Where pace88 participates in industry-standard fraud prevention or AML information sharing networks, data may be shared in anonymised or aggregated form only.
• Professional Advisers: Lawyers, auditors, and insurers acting in a professional capacity may access data on a need-to-know basis subject to confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of pace88's assets, personal data may be transferred to the acquiring entity, subject to the same protections as described in this policy.

7. International Data Transfers

pace88 may transfer personal data to service providers or infrastructure located outside of Malaysia, including cloud hosting providers and game studio servers. Where such transfers occur, pace88 implements appropriate safeguards including contractual data protection clauses, data processing agreements, and — where applicable — adequacy assessments to ensure your data receives a level of protection equivalent to that afforded under the PDPA.

By using the pace88 Platform, you acknowledge that your personal data may be transferred to and processed in countries outside of Malaysia. pace88 will take all reasonable steps to ensure that any such transfers comply with applicable law and that your data is handled securely.

8. Data Retention

pace88 retains personal data only for as long as necessary for the purposes set out in this policy or as required by applicable law, whichever is longer. The following indicative retention periods apply:

• Account and KYC data: Retained for a minimum of 6 years following account closure, in line with AML and regulatory record-keeping obligations.
• Transaction records: Retained for a minimum of 6 years from the date of the relevant transaction.
• Support communications: Retained for 3 years from the date of the communication, or longer where relevant to an open dispute.
• Technical and analytics data: Retained in aggregated form for up to 2 years. Individually identifiable technical logs are retained for up to 12 months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with pace88's data disposal procedures.

9. Your Rights

Subject to applicable law and pace88's legal obligations, you have the following rights in relation to your personal data:

• Right of Access: You may request a copy of the personal data pace88 holds about you.
• Right to Correction: You may request that inaccurate or incomplete personal data be corrected. For registered players, most account details can be updated via your account dashboard.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing. pace88 will honour opt-out requests for marketing communications promptly.
• Right to Restriction: In certain circumstances, you may request that pace88 restrict the processing of your personal data pending resolution of a query or complaint.

To exercise any of the above rights, please contact pace88 via 24/7 live support in your account dashboard or at the email address set out in Section 15. pace88 will respond to verifiable requests within 21 days. Identity verification will be required before any personal data access request is fulfilled.

10. Cookies & Tracking Technologies

pace88 uses cookies and similar tracking technologies (pixels, local storage, session storage) to operate the Platform, maintain your session state, prevent fraud, and analyse usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential to the operation of the Platform. These cannot be disabled as they are required for login session management, security tokens, and fraud prevention.
• Functional Cookies: Remember your preferences and settings (e.g., preferred language, last visited game category) to improve your experience.
• Analytics Cookies: Collect aggregated data about how players interact with the Platform to help pace88 improve usability and performance. These are disabled if you opt out of analytics.
• Marketing Cookies: Used to deliver relevant pace88 promotions. These are only placed with your consent.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair or prevent your ability to use the Platform.

11. Data Security

pace88 implements technical and organisational security measures commensurate with the sensitivity of the personal data processed and the risks involved, including:

• 256-bit SSL/TLS encryption for all data in transit between your browser and pace88 servers.
• Encryption at rest for sensitive personal and financial data stored on pace88 infrastructure.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments by independent security firms.
• Two-factor authentication (2FA) available to players for account-level security.
• Automated fraud and anomaly detection systems monitoring for unauthorised account access.

No data transmission over the internet is wholly secure. While pace88 takes all reasonable measures to protect your data, we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pace88 will notify affected players in accordance with applicable law.

12. Minors

The pace88 Platform is strictly intended for individuals aged 21 and above. pace88 does not knowingly collect personal data from anyone under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

If you have reason to believe that a minor has registered a pace88 account, please notify us immediately via live support or the contact details in Section 15.

13. Third-Party Links

The pace88 Platform may contain links to third-party websites, including game provider microsites, responsible gaming organisations, and payment processor portals. These third-party sites operate under their own privacy policies, which pace88 does not control and is not responsible for. We encourage you to review the privacy policies of any third-party site you visit via a link on the pace88 Platform.

14. Updates to This Privacy Policy

pace88 reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered players via the email address on file and/or via a prominent notice on the Platform. The effective date at the top of this page indicates when the current version was last updated.

Your continued use of the pace88 Platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the updated policy, you must cease using the Platform and contact support to close your account.

15. Contact & Data Enquiries

For any privacy-related enquiries, data access requests, complaints, or to exercise your rights under this policy, please contact pace88 via:

• Live Support: Available 24/7 via your pace88 account dashboard. This is the fastest route for most queries.
• Email: [email protected] — please include "Privacy Enquiry" in your subject line. This is displayed as plain text only and is not a clickable link.

pace88 will acknowledge receipt of formal privacy enquiries within 3 business days and respond substantively within 21 calendar days. Where requests are complex or numerous, pace88 may extend this period by a further 30 days, with written notice provided within the initial 21-day window.