Ald1 Privacy Policy — Personal Data Protection for Malaysian Members

1. Introduction & ald1's Privacy Commitment

Ald1 ("we", "platform", or "ald1") treats every member's privacy as non-negotiable. As an online entertainment platform operating in Malaysia, ald1 is fully bound by the Personal Data Protection Act 2010 (PDPA) — the primary legislation governing how private organisations collect, use, disclose, store, and manage individuals' personal data in this country.

This Privacy Policy is designed to give you complete clarity on every aspect of how ald1 handles your personal data — from the moment you first visit the ald1 website to long after you use our services. We believe an informed member is a safer member, which is why we take the time to explain our privacy practices in clear, straightforward language that any Malaysian user can understand.

This Privacy Policy applies to all personal information collected through the ald1 website, the ald1 mobile application (where applicable), and all interaction channels ald1 provides to members — including customer support via live chat, email, and phone. This Policy forms part of ald1 Terms & Conditions and should be read together with that document.

2. Types of Personal Data Collected by ald1

Ald1 only collects personal data that is strictly necessary to deliver our platform services safely, fairly, and in accordance with applicable legal requirements. We do not collect data that is excessive or unrelated to the operational purposes of the ald1 platform.

Identity Data:

• Full name as stated on your official Malaysian identity document (MyKad or passport).
• MyKad number or passport number for KYC (Know Your Customer) verification purposes.
• Date of birth to verify age eligibility (18 years and above).
• Current residential address in Malaysia.
• Photos of your identity document when KYC verification is required.

Contact Details:

• An active Malaysian mobile number for account verification and communications.
• An active email address for account notifications and promotions (with consent).

Financial Data:

• Information relating to the payment method used — whether Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, or FPX via Maybank2u and CIMB Clicks. ald1 does not store full credit or debit card numbers.
• Records of deposit and withdrawal transactions made through the ald1 platform.
• The name of the bank account or digital wallet holder for withdrawal verification.

Platform Usage Data:

• Records of games played, total bets placed, winnings, and losses.
• IP address, device type, operating system, and web browser used.
• Account login and logout records, including timestamps and location (estimated based on IP).
• Preferences and account settings you have configured on the ald1 platform.

3. How ald1 Collects Your Personal Data

Ald1 collects your personal data through several different channels, depending on how you interact with our platform. Understanding these channels helps you better manage and control the information you share with ald1.

4. How ald1 Uses Your Personal Data

Ald1 uses collected personal data solely for legitimate purposes necessary to operate the platform. We do not use your data for unrelated purposes or for anything you have not consented to. The following are the primary purposes for which ald1 uses your data:

• Account Management: Creating and maintaining your ald1 account, processing logins and identity verification, and enabling access to all platform features.
• Payment Processing: Securely processing your deposits and withdrawals via your preferred payment method — Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, Maybank2u, CIMB Clicks, or FPX — and ensuring funds are settled correctly to the right account.
• Legal Compliance & KYC: Fulfilling legal obligations including KYC requirements, anti-money laundering (AML) compliance, and adherence to applicable Malaysian financial regulations.
• Platform Security: Detecting and preventing fraud, unauthorised access, account misuse, and other security threats that could compromise the ald1 platform or its members.
• Service Improvement: Analysing aggregated, anonymised usage data to understand user behaviour and improve the features, performance, and overall experience of the ald1 platform.
• Service Communications: Sending important account-related notifications such as deposit confirmations, withdrawal alerts, security notices, and ald1 policy updates.
• Marketing (With Consent): Sending you promotional information, bonus offers, and the latest ald1 news — but only if you have given explicit consent to receive such marketing communications. You may withdraw this consent at any time.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and provide appropriate support to members who may need assistance, as part of ald1's commitment to responsible gaming.

5. Sharing Data with Third Parties

Ald1 does not sell, rent, or transfer your personal data to third parties for their own marketing purposes. This is a non-negotiable commitment under ald1's Privacy Policy. However, there are specific circumstances in which ald1 may share your data with certain parties in order to deliver our services more effectively:

• Payment Service Providers: ald1 shares necessary transaction information with payment processors and financial institutions — including Touch 'n Go eWallet, GrabPay, DuitNow, and Malaysian banks such as Maybank and CIMB — to ensure your deposits and withdrawals are processed securely and accurately.
• Game Providers: ald1 shares the minimum technical data necessary with game providers to ensure games function correctly and betting records are accurately synchronised.
• Legal Authorities: ald1 will disclose personal data to the relevant Malaysian authorities — including the PDRM, Bank Negara Malaysia, or other regulatory bodies — when required by law or a valid court order, or when ald1 has reasonable grounds to believe that disclosure is necessary to protect public safety or prevent unlawful activity.
• Technical Service Providers: ald1 works with trusted third-party technical service providers — such as cloud hosting providers, analytics systems, and fraud prevention tools — who may process certain data on our behalf as part of the services they provide to ald1. All such providers are bound by strict data protection agreements.

6. Data Security & Technical Protection

Ald1 continually invests in up-to-date technical security infrastructure to keep your personal data protected from threats and unauthorised access. Our security approach is multi-layered — meaning we do not rely on a single protective mechanism, but instead combine multiple complementary security measures.

• 256-bit SSL Encryption: All communications between your browser and ald1's servers are encrypted using 256-bit SSL — the same encryption standard used by Malaysia's leading banking institutions, including Maybank and CIMB, to protect their customers' transactions.
• Stored Data Encryption: Sensitive personal data stored in ald1's databases — including identity and financial information — is kept in encrypted form. Even in the event of unauthorised database access, the data cannot be read without the appropriate decryption key.
• Two-Factor Authentication (2FA): ald1 provides and encourages the use of two-factor authentication for account access, adding an extra layer of protection beyond your password alone.
• 24/7 Security Monitoring: ald1's security monitoring system operates around the clock to detect suspicious activity, unusual login attempts, and any indicators of a potential security breach — with automated measures in place to block threats before they can cause harm.
• Regular Penetration Testing: The ald1 security team conducts regular penetration testing using independent third-party specialists to identify and address any security vulnerabilities before they can be exploited.
• Internal Access Controls: Access to members' personal data within ald1's internal systems is restricted to staff who genuinely require it to perform their duties, based on a strict need-to-know basis.

While ald1 takes all reasonable steps to protect your data, no security system can guarantee 100% absolute protection. In the event of any data security breach involving your personal data, ald1 will notify you and the relevant authorities in accordance with PDPA requirements within the legally prescribed timeframe.

7. Cookies & Tracking Technologies

Ald1 uses cookies and similar tracking technologies on our platform. Cookies are small text files stored on your device when you visit the ald1 website. These technologies help ald1 deliver a better and more personalised user experience.

Types of cookies used by ald1:

• Essential Cookies (Kuki Perlu): Cookies required for core ald1 platform functions such as login authentication, session management, and security. These cookies cannot be disabled, as the platform cannot operate properly without them.
• Functional Cookies: Cookies that remember your preferences on ald1 — such as your preferred language, display settings, and game preferences — so you don't have to reconfigure them every time you log in.
• Analytics Cookies: Cookies that help ald1 understand how members use the platform — which pages are most popular, how long users spend in each section, and where they encounter difficulties. This data is aggregated and anonymised to improve the overall ald1 platform experience.
• Marketing Cookies (Kuki Pemasaran): Cookies that allow ald1 to show you more relevant ads and promotions based on your interests and activity. These cookies are only activated if you have given consent to receive marketing communications.

You can control or delete cookies through your web browser settings at any time. Please note that disabling certain cookies may affect the functionality of some ald1 platform features.

8. Data Retention Period

Ald1 retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable Malaysian law — whichever is longer. ald1's data retention policy is as follows:

• Active Account Data: For as long as your ald1 account remains active, ald1 retains all account-related data to enable us to deliver uninterrupted service and meet our legal obligations.
• Data After Account Closure: After you close your ald1 account, we retain certain data — primarily financial transaction records and KYC documents — for the minimum period required under Malaysian financial law, typically no less than seven (7) years, for audit, compliance, and dispute resolution purposes.
• Log & Security Data: Activity logs and security data are retained for as long as necessary to detect and investigate any security incidents or fraudulent activity.
• Marketing Data: Data collected for marketing purposes is retained until you withdraw your consent or request its deletion.

Once the relevant retention period has expired, ald1 will securely delete or anonymise your personal data in a manner that is safe and irreversible, ensuring it can no longer be linked to you personally.

9. Your Rights Under the PDPA

As an individual whose data is processed by ald1, you have certain rights under the Personal Data Protection Act 2010 (PDPA) Malaysia. ald1 respects and facilitates the exercise of these rights by its members. Your rights are as follows:

• Right to Access: You have the right to request and obtain a copy of the personal data ald1 holds about you. ald1 will process access requests within a reasonable timeframe and provide the information in an understandable format.
• Right to Rectification: If the personal data ald1 holds about you is inaccurate, incomplete, or out of date, you have the right to request a correction. ald1 will update the record promptly upon receiving the necessary supporting evidence.
• Right to Withdraw Consent: You may withdraw any consent you have given ald1 to process your data for specific purposes — particularly for marketing communications — at any time and without providing a reason.
• Right to Object: You have the right to object to ald1's processing of your personal data in certain circumstances, particularly for direct marketing purposes.
• Right to Restrict Processing: Under certain circumstances, you have the right to request that ald1 restrict the processing of your personal data — for example, while you are disputing the accuracy of the data we hold.

To exercise any of the above rights, please contact ald1's customer support team through the available channels. ald1 will process your request within 21 business days in accordance with PDPA requirements. Please note that the exercise of certain rights may be subject to ald1's legal obligations relating to financial record-keeping and regulatory compliance.

10. Protection of Children's Data

The ald1 platform is strictly for individuals aged 18 and above. ald1 does not knowingly collect or process personal data from individuals under the age of 18. Should ald1 discover that a child's personal data has been collected without our knowledge, we will take immediate action to delete that data and close the associated account.

If you are a parent or guardian who believes your underage child has registered for or used the ald1 platform without your knowledge, please contact the ald1 support team immediately so we can take appropriate action without delay.

11. Amendments to ald1's Privacy Policy

Ald1 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, applicable legislation, or the way we operate the platform. Any material changes to this Privacy Policy will be communicated to members via:

• A clear notice is displayed on the ald1 platform homepage and on this Privacy Policy page.
• Email notification to the member's registered address for any significant changes.
• In-account notifications on your next login to ald1.

The "Last Updated" date shown at the top of this page reflects when this Privacy Policy was most recently revised. Your continued use of the ald1 platform after any amendments take effect constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about how ald1 safeguards your information.

12. Contact ald1 About Privacy

If you have any questions, concerns, or complaints regarding ald1's Privacy Policy or how we handle your personal data, the ald1 team is here to listen and assist. We are committed to addressing every privacy-related enquiry seriously and promptly.

You can reach ald1 through the following channels:

• Support Email: [email protected] — the ald1 support team will respond to privacy-related enquiries within 3 business days.
• Live Chat: Via the live chat function available on the ald1 platform, operating 24/7.
• Via Your ald1 Account: Log in to your ald1 account and use the Support or Contact Us section to submit privacy-related enquiries securely.

If you are dissatisfied with ald1's response to your privacy complaint, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia, which is responsible for enforcing the PDPA 2010 in this country.