Privacy Policy — pulaujudi

This Privacy Policy (the "Policy") is issued by pulaujudi (hereinafter referred to as "pulaujudi", "We", "Us", or "Our"), the operator of the online casino and sports betting platform accessible at https://pulaujudi.cam (the "Platform").

This Policy describes how pulaujudi collects, uses, discloses, transfers, stores, and otherwise processes personal data belonging to individuals who register for and use the Platform ("Players", "Users", or "You"). It applies to all personal data collected through the Platform, through our customer support channels, and through any other interaction you have with pulaujudi.

By registering an account on the Platform or by continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

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

• "Personal Data" means any information that identifies, or could reasonably be used to identify, a natural person, directly or indirectly. This includes name, identification number, contact details, IP address, device identifiers, and financial information.
• "Processing" means any operation performed on Personal Data, including collection, recording, organisation, storage, alteration, retrieval, use, disclosure by transmission, dissemination, restriction, erasure, or destruction.
• "Data Controller" means pulaujudi, the entity that determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means a third-party entity that processes Personal Data on behalf of pulaujudi, strictly according to pulaujudi's instructions and this Policy.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• "KYC" means Know Your Customer — the identity verification process required by pulaujudi before processing withdrawals and as anti-fraud measure.
• "Cookies" means small text files placed on a User's device by the Platform to enable certain functionality and collect usage analytics.

pulaujudi collects the following categories of Personal Data from Players and Platform visitors. The data collected depends on your level of interaction with the Platform:

pulaujudi collects Personal Data through the following methods:

Direct Collection

You provide Personal Data directly to us when you:

• Register a Player account on the Platform.
• Submit identity documents for KYC verification.
• Make a deposit or request a withdrawal using Malaysian payment method.
• Contact our customer support team via live chat or email.
• Subscribe to promotional communications or claim a bonus.
• Respond to a survey or provide feedback about the Platform.

Automated Collection

We automatically collect certain Technical Data when you access the Platform, using cookies, web beacons, and server log files. This includes your IP address, device information, browser type, and pages you visit. See Clause 11 for more information about our use of cookies.

Third-Party Sources

In limited circumstances, we may receive Personal Data about you from third parties, including:

• Payment service providers (e.g., FPX, DuitNow gateway operators) confirming transaction status.
• Identity verification services used to assist with KYC compliance.
• Fraud prevention and anti-money laundering screening services.
• Responsible gambling self-exclusion registers, where applicable.

pulaujudi processes your Personal Data for the following specific purposes:

• Account Management: To create, maintain, and administer your Player account, including processing registration information and verifying your identity.
• Service Delivery: To provide access to all Platform features, including casino games, live dealer games, sports betting (EPL, Liga Super Malaysia, UFC, and other markets), and responsible gambling tools.
• Payment Processing: To process MYR deposits and withdrawals through your chosen Malaysian payment method (DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong) and to maintain accurate transaction records.
• KYC & Regulatory Compliance: To verify your identity and age (21+ requirement), comply with anti-money laundering obligations, and meet any other regulatory requirements applicable to our operations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, bonus abuse, account takeover attempts, and other security incidents on the Platform.
• Customer Support: To respond to enquiries, resolve disputes, and provide technical assistance to Players via live chat and email.
• Responsible Gambling: To monitor gaming activity for signs of problem gambling behaviour, apply Player-requested limits and self-exclusions, and ensure the Platform is not used by persons who are self-excluded.
• Marketing Communications: Where you have provided your consent, to send you information about promotions, bonuses, and Platform updates. You may withdraw this consent at any time.
• Platform Improvement: To analyse aggregated usage data, identify technical issues, and improve the performance and user experience of the Platform.
• Legal Compliance: To comply with applicable laws, court orders, regulatory directions, and law enforcement requests.

pulaujudi processes your Personal Data one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions), including providing access to the Platform and processing your deposits and withdrawals.
• Consent: Where you have given us explicit consent for a specific processing activity, such as receiving marketing communications or newsletters. You may withdraw your consent at any time without this affecting the lawfulness of processing carried out before withdrawal.
• Legal Obligation: Processing is necessary for pulaujudi to comply with applicable legal obligations, including KYC identity verification, anti-money laundering reporting obligations, and data retention requirements under applicable law.
• Legitimate Interests: Processing is necessary for pulaujudi's legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring, and improving our services — provided these interests are not overridden by your fundamental rights and freedoms.

pulaujudi does not sell, rent, or trade your Personal Data to third parties. We share your data only in the following circumstances and only to the extent necessary:

• Payment Service Providers: Transaction data is shared with licensed payment processors (including those operating FPX, DuitNow, and e-wallet platforms) solely to process your deposits and withdrawals.
• Identity Verification Partners: KYC documents may be processed by authorised identity verification service providers that assist with regulatory compliance. These providers are contractually bound to handle your data securely and confidentially.
• Game Software Providers: Technical session data (e.g., game round identifiers, bet amounts) may be shared with licensed game studios to resolve disputes, investigate technical errors, and confirm game outcomes.
• Fraud & AML Screening Services: We may share relevant transactional and identity data with screening services to meet our anti-money laundering obligations and detect fraudulent activity.
• Regulatory Authorities & Law Enforcement: pulaujudi will disclose Personal Data to competent regulatory authorities, courts, or law enforcement agencies where legally required or where we have a good-faith belief that disclosure is necessary to protect our legal rights, prevent fraud, or protect the safety of others.
• Corporate Transactions: In the event of a merger, acquisition, or sale of pulaujudi's business or assets, Personal Data may be transferred to the acquiring entity. You will be notified in advance of any such transfer.

Some of our service providers and technology infrastructure partners may be located in jurisdictions outside Malaysia. Where pulaujudi transfers your Personal Data to recipients in other countries, we take appropriate measures to ensure that the transfer is lawful and that your data receives a level of protection consistent with this Policy and applicable data protection law.

Such measures may include implementing standard contractual clauses approved by relevant data protection authorities, ensuring the recipient country provides an adequate level of data protection, or obtaining your explicit consent to the transfer where required.

Where we store or process data on servers located outside Malaysia, those servers are maintained in data centres that comply with internationally recognised information security standards.

pulaujudi retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, as described in this Policy, and to comply with our legal obligations. In general terms:

• Account Data: Retained for the duration of your active account relationship with pulaujudi and for a minimum of five (5) years after account closure, to meet regulatory and anti-money laundering record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of seven (7) years in accordance with applicable financial record-keeping obligations.
• KYC Documents: Retained for the duration of your account relationship and for a minimum of five (5) years after account closure, as required by applicable KYC regulations.
• Support Communications: Retained for up to three (3) years from the date of the last communication, to assist in resolving any future disputes.
• Marketing Data: Retained until you withdraw your consent to marketing communications or close your account, whichever is earlier.
• Technical / Log Data: Typically retained for up to twelve (12) months for security and platform improvement purposes.

When Personal Data is no longer required, pulaujudi will securely delete or anonymise it in accordance with our internal data disposal procedures.

Subject to applicable law and certain exceptions, you have the following rights in relation to your Personal Data held by pulaujudi:

To exercise any of the rights listed above, please submit a written request to our support team at the contact details provided in Clause 15. We will acknowledge your request within seven (7) business days and endeavour to respond in full within thirty (30) days of receipt. We may request proof of identity before processing your request to prevent unauthorised access to another person's data.

The pulaujudi Platform uses cookies and similar tracking technologies to ensure that the Platform functions correctly and to improve the experience for our Malaysian players. The following types of cookies may be set when you visit the Platform:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in, security tokens, and load-balancing cookies. These cookies cannot be disabled without preventing you from using the Platform.
• Functional Cookies: Enable enhanced functionality and personalisation, such as remembering your language preference, display settings, or responsible gambling limit configurations.
• Analytics Cookies: Allow us to measure and analyse traffic patterns, page performance, and user journeys across the Platform. This data is used in aggregated, anonymous form to improve the Platform. We do not use this data to identify individual users.
• Security Cookies: Used to detect and prevent fraudulent access, bot activity, and other security threats on the Platform.

pulaujudi does not use third-party advertising or tracking cookies that would allow external advertisers to build a profile of your behaviour across other websites.

You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may impair Platform functionality. For detailed guidance on managing cookies in your specific browser, consult your browser's help documentation.

The pulaujudi Platform is strictly for adults aged21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. Our registration process requires Players to confirm their age, and age verification is enforced as part of the KYC process.

If we become aware that we have inadvertently collected Personal Data from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage individual will be returned less any amounts already wagered, in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor in your care has registered an account on the Platform without your knowledge, please contact us immediately at the address provided in Clause 15.

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

• 256-bit SSL Encryption: All data transmitted between your device and the Platform is encrypted in transit using industry-standard SSL/TLS protocols. Look for the padlock icon in your browser's address bar when accessing pulaujudi.
• Two-Factor Authentication (2FA): Available for all Player accounts to provide an additional layer of login security beyond the standard username and password.
• Access Controls: Personal Data is accessible only to authorised pulaujudi staff who require it to perform their job functions. Access is logged and monitored.
• Encrypted Document Storage: KYC documents (MyKad copies, utility bills, photographs) are stored in an access-controlled, encrypted document management system separate from the primary database.
• Regular Security Audits: We conduct periodic internal and third-party security assessments to identify and remediate vulnerabilities in our systems.
• Incident Response Plan: pulaujudi maintains a documented data breach response procedure. In the event of a breach affecting your Personal Data, we will notify affected individuals and relevant authorities as required by applicable law.

While we take all reasonable precautions to protect your data, no digital system can be guaranteed completely secure. You are responsible for maintaining the confidentiality of your account credentials. If you suspect your account has been compromised, please contact our support team immediately.

pulaujudi reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable data protection legislation, regulatory guidance, business practices, or Platform features.

When we make material changes to this Policy, we will notify registered Players by email to the address associated with their account at leastseven (7) days before the changes take effect, except where immediate amendment is required for legal or security reasons. The updated Policy will be published on this page with a revisedEffective Date at the top of the document.

Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree with the revised terms, you should close your account before the effective date of the change.

We recommend that you periodically review this page to stay informed about how we protect your Personal Data. Previous versions of this Policy are available upon request from our support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which pulaujudi processes your Personal Data, please contact our Data Protection team through the following channel:

For responsible gambling enquiries — including requests to apply deposit limits, loss limits, or self-exclusion — please visit our Responsible Gambling page.

For all other Platform queries, please refer to our FAQ page or contact our 24/7 live chat support directly from the Platform.