Privacy Policy

pavi88 ("we", "us", "our", or "the Platform") is committed to protecting and respecting the privacy of all individuals who access and use the pavi88 website at pavi88.cam and any associated services.

This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. It describes what personal information we gather, the purposes for which we use it, the lawful basis on which we rely to process it, and the rights available to you in respect of your personal data.

This Policy applies to all Players who register an account with pavi88, visitors who browse the Platform without registering, and individuals who contact us through any support or communication channel. By using the Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read alongside our Terms & Conditions, which govern the overall use of the pavi88 Platform and are incorporated by reference into this Policy.

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

• "Personal Data" — Any information that identifies or could reasonably identify a living individual, either on its own or when combined with other information. This includes names, email addresses, financial data, device identifiers, and IP addresses.
• "Processing" — Any operation performed on Personal Data, including collection, storage, organisation, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" — pavi88, as the entity that determines the purposes and means by which Personal Data is processed.
• "Data Processor" — A third party that processes Personal Data on behalf of pavi88 strictly in accordance with pavi88's documented instructions.
• "Player" / "User" / "You" — Any individual who accesses, registers with, or uses the pavi88 Platform.
• "KYC Data" — Identity and age verification documentation submitted by a Player in fulfilment of Know Your Customer requirements.
• "Cookies" — Small data files stored on a User's device by a web browser, used to retain session information, preferences, and usage analytics.
• "Sensitive Personal Data" — A subset of Personal Data that warrants additional protection, including financial records, identity documents, and transaction histories.

pavi88 collects only the Personal Data that is necessary for the operation of the Platform, the provision of its services, and compliance with applicable regulatory obligations. The categories of data we may collect include:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information, unless expressly required for a specific regulatory compliance purpose and only with your explicit consent where required.

pavi88 collects Personal Data through several direct and automated methods:

• Account Registration: When you create a pavi88 account, you directly provide us with identity, contact, and credential information.
• KYC Verification: When fulfilling identity verification requirements, you upload identity documents and supporting records which form part of your Player profile.
• Deposits and Withdrawals: When you conduct financial transactions on the Platform, payment method details and transaction data are captured and associated with your Account.
• Gameplay: Your interactions with games, live dealer tables, and sports betting markets generate a continuous record of gaming activity linked to your Account.
• Customer Support: When you contact our live chat team or send an email enquiry, the content of that communication is recorded for quality assurance, training, and dispute resolution purposes.
• Cookies and Tracking Technologies: Automated data collection tools gather technical and usage data each time you interact with the Platform. See Section 8 for full details on cookies.
• Third-Party Sources: We may receive supplementary data from identity verification providers, fraud detection services, and payment processing partners where this is necessary for compliance purposes.

pavi88 processes your Personal Data only where there is a lawful basis to do so. The primary purposes for which we process your data, along with the corresponding legal basis, are set out below:

• Account Management and Service Delivery: Processing is necessary for the performance of the contract between you and pavi88. This includes maintaining your Account, processing transactions, delivering game services, and handling withdrawal requests.
• Identity and Age Verification (KYC): Processing is necessary for compliance with our legal obligations. We are required to verify that all Players are aged 21 or above and to prevent access by excluded individuals.
• Anti-Money Laundering (AML) Compliance: Processing is necessary for compliance with applicable financial crime prevention obligations. Transaction monitoring and source-of-funds checks fall within this category.
• Fraud Prevention and Security: Processing is necessary for our legitimate interests in preventing fraud, protecting the Platform from abuse, and maintaining the integrity of our services.
• Customer Support and Dispute Resolution: Processing is necessary for the performance of the contract and our legitimate interest in resolving player disputes fairly and maintaining service quality records.
• Responsible Gambling Monitoring: Processing is necessary for compliance with responsible gambling obligations and to fulfil our duty of care toward Players who may be at risk of harm.
• Marketing Communications: Where you have opted in to receive promotional communications from pavi88, we process your contact data on the basis of your consent. You may withdraw this consent at any time.
• Platform Analytics and Improvement: Processing of aggregated usage data is based on our legitimate interest in improving the Platform experience and optimising service delivery.

pavi88 does not sell your Personal Data to any third party. We may share your data with carefully selected third parties only in the following circumstances, and only to the extent strictly necessary for the specified purpose:

• Payment Service Providers: To process deposits and withdrawals, we share relevant financial and identity data with our payment partners, including providers of Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and Hong Leong Bank integrations. These providers operate under their own privacy frameworks and data protection obligations.
• KYC and Identity Verification Providers: To fulfil our age and identity verification obligations, we engage regulated third-party verification services that process identity documents and biometric data on our behalf, acting as Data Processors under contract.
• Fraud Detection and Security Services: We share technical and transactional data with fraud prevention platforms to identify and mitigate suspicious activity, multi-accounting, and financial crime risks.
• Game and Software Providers: Game content providers may receive limited gaming session data necessary for game functionality, result verification, and RNG auditing. No identity data is shared with game providers beyond what is technically required.
• Regulatory and Legal Authorities: We may disclose Personal Data to regulatory bodies, law enforcement agencies, or courts where we are required to do so by law, court order, or binding regulatory direction.
• Responsible Gambling Organisations: Where a Player has applied for self-exclusion or where pavi88 has identified a Player at risk of harm, we may share relevant data with recognised responsible gambling networks to give effect to exclusion requests across participating platforms.

All third parties with whom pavi88 shares Personal Data are required to implement appropriate technical and organisational security measures and to process data strictly in accordance with pavi88's documented instructions and applicable data protection requirements.

pavi88 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or for such longer period as is required by applicable law, regulation, or our legitimate operational interests. The following general retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Anonymised or aggregated data may be retained indefinitely for statistical and analytical purposes.

The pavi88 Platform uses cookies and similar tracking technologies to enhance your experience, maintain session continuity, and collect usage analytics. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They maintain your login session, store your currency and language preferences, and facilitate secure payment processing. These cookies cannot be disabled without impairing core Platform functionality.
• Performance and Analytics Cookies: These cookies collect aggregated, anonymised data about how Players use the Platform — pages visited, time on page, navigation paths, and error occurrences. This data helps pavi88 identify areas for improvement and optimise the user experience.
• Functional Cookies: These cookies remember your preferences and settings — such as game display configurations, deposit amount defaults, and notification preferences — so that they persist across sessions.
• Security Cookies: These cookies support fraud detection, bot mitigation, and account security functions. They help us identify unusual login patterns and prevent unauthorised access to player accounts.

Most web browsers allow you to manage your cookie preferences through the browser's settings. You may choose to disable non-essential cookies; however, doing so may affect the functionality and performance of the Platform. Disabling strictly necessary cookies will prevent you from logging in and using the Platform.

pavi88 implements a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the pavi88 Platform is encrypted using industry-standard Transport Layer Security protocols.
• Data Encryption at Rest: Sensitive Personal Data and financial records stored on pavi88 servers are encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data is restricted to authorised pavi88 personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: Player accounts support two-factor authentication to provide an additional layer of protection against unauthorised access.
• Regular Security Audits: The Platform undergoes periodic security assessments, penetration testing, and vulnerability scans conducted by qualified information security professionals.
• Incident Response: In the event of a personal data breach that poses a risk to Player rights and freedoms, pavi88 maintains a documented incident response procedure and will notify affected individuals in accordance with applicable requirements.

As an internationally operated platform serving Malaysian players, some of the Personal Data we process may be transferred to, stored in, or accessed from jurisdictions outside of Malaysia. This may occur where our payment processing partners, KYC verification providers, or cloud infrastructure providers operate data centres or processing facilities in other countries.

In all cases where Personal Data is transferred internationally, pavi88 takes appropriate steps to ensure that adequate levels of data protection are maintained, including through the use of contractual safeguards and data processing agreements with all third-party recipients.

pavi88 does not transfer Personal Data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards to ensure the continued protection of your rights.

Subject to applicable law, you have the following rights in respect of your Personal Data held by pavi88. You may exercise any of these rights by contacting our support team and specifying "Privacy Request" in your communication:

pavi88 will respond to all data rights requests within 30 calendar days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it. Responding to data rights requests is provided free of charge in the majority of cases.

The pavi88 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect or process Personal Data from any person under the age of 21, and we actively employ age verification procedures to prevent underage access.

If pavi88 discovers or has reasonable grounds to believe that Personal Data has been collected from an individual under the age of 21, all associated data will be deleted promptly, the Account will be closed, and any deposited funds will be returned or handled in accordance with applicable regulatory requirements.

Parents or guardians who believe that a minor may have registered an account with pavi88 should contact our support team immediately via live chat or at [email protected] so that appropriate action can be taken without delay.

The pavi88 Platform does not contain links to external third-party websites for general browsing purposes. Where references are made to third-party payment providers, regulatory bodies, or responsible gambling support services within the Platform's content, these references are provided for informational purposes only.

pavi88 accepts no responsibility for the privacy practices, data handling policies, or content of any external websites or services that are not operated by pavi88. Users who navigate to any external resource do so at their own risk and should review the relevant privacy policy of that resource independently.

pavi88 reserves the right to update or amend this Privacy Policy at any time. Where changes are material — that is, where they significantly affect how your Personal Data is collected, used, or shared — pavi88 will provide reasonable advance notice by displaying a prominent notification on the Platform for a period of not less than seven (7) calendar days before the changes take effect.

Your continued use of the Platform following the effective date of any amended Policy constitutes your acknowledgement of the updated version. We therefore encourage you to review this Policy periodically. The date of the most recent update is clearly displayed at the top of this page.

Where changes require your fresh consent — for example, where we wish to process your Personal Data for a new purpose not previously disclosed — we will request that consent explicitly before proceeding with such processing.

If you have any questions, concerns, or requests in relation to this Privacy Policy or the processing of your Personal Data by pavi88, please contact our team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week directly on the pavi88 Platform. For data-related enquiries, please begin your chat message with "Privacy Request" so that your query is directed to the appropriate team.
• Email: [email protected] — please include "Privacy Request" in the subject line of your email. This address is displayed as plain text only and is not a clickable link.

pavi88 will acknowledge receipt of all privacy-related requests within 48 hours and will endeavour to provide a substantive response within 30 calendar days in accordance with the timeframes set out in Section 11.