Privacy Policy — SGA123

This Privacy Policy ("Policy") describes how SGA123 ("SGA123", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at https://sga123.click ("the Platform"), collects, processes, stores, and protects the personal data of users ("you", "your", "Player") who access or use our services.

SGA123 is committed to handling personal data responsibly and in compliance with applicable data protection legislation, including the Personal Data Protection Act 2010 (PDPA) of Malaysia and any other applicable data privacy frameworks.

By registering an account, accessing the Platform, or otherwise engaging with any of our services, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with any part of this Policy, please discontinue your use of the Platform.

The following terms carry the meanings assigned below throughout this Policy:

SGA123 collects Personal Data through multiple channels, including account registration, identity verification, payment processing, customer support interactions, and your general use of the Platform. The categories of data we collect include the following:

SGA123 processes your Personal Data for the following specific, lawful purposes:

• Account Management: To create, maintain, and administer your player account, including verifying your identity, managing your balance, and processing your login credentials.
• Service Delivery: To provide access to our casino games, live casino tables, sportsbook, and all other Platform services, including processing your bets and game transactions.
• Payment Processing: To facilitate deposits and withdrawals via your chosen payment methods — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX bank transfers, and cryptocurrency — and to maintain accurate financial records.
• Identity Verification (KYC): To verify that you meet the Platform's eligibility requirements, including age verification (21+), fraud prevention, and compliance with anti-money laundering obligations.
• Customer Support: To respond to your queries, complaints, and support requests through live chat, email, and other communication channels.
• Legal and Regulatory Compliance: To meet our obligations under applicable laws, including anti-money laundering (AML) regulations, responsible gambling requirements, and data protection legislation.
• Platform Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, collusion, and other forms of platform abuse.
• Responsible Gambling: To monitor gameplay patterns that may indicate problem gambling behaviour, implement player-requested limits and self-exclusion measures, and fulfil our responsible gaming obligations.
• Marketing Communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications, and seasonal campaign updates (such as Hari Raya promotions). You may withdraw this consent at any time by updating your account preferences or contacting our support team.
• Platform Improvement: To analyse usage data and technical metrics to improve the performance, stability, and user experience of the Platform.

SGA123 processes your Personal Data on one or more of the following legal bases, depending on the nature and purpose of each processing activity:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you, including account administration, service delivery, and payment processing.
• Legal Obligation: Processing required for us to comply with applicable laws and regulatory requirements, including KYC, AML obligations, and responsible gambling mandates.
• Legitimate Interests: Processing carried out for purposes that are in our legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing activities for which you have provided express prior consent, including marketing communications and the use of non-essential cookies. You may withdraw your consent at any time without detriment to your access to the Platform's core services.

SGA123 uses cookies and similar tracking technologies to operate the Platform effectively, personalise your experience, and gather analytical data. Cookies are small data files stored on your device by your browser. The types of cookies we use include:

• Essential Cookies: Necessary for the Platform to function correctly. These include session authentication cookies, security tokens, and preference settings. These cannot be disabled without impairing core Platform functionality.
• Analytical Cookies: Used to understand how players interact with the Platform — including pages visited, time spent, and features used — to identify areas for improvement. These are anonymised where possible.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Marketing Cookies: Used, where you have consented, to deliver promotional content relevant to your interests. These cookies may track your activity across sessions to measure the effectiveness of our campaigns.

You may control your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of parts of the Platform. By continuing to use the Platform after being presented with our cookie notice, you consent to the use of cookies as described in this section.

SGA123 does not sell, rent, or trade your Personal Data to any third party for their independent marketing or commercial purposes. We may share your data only in the following limited and specific circumstances:

• Payment Service Providers: We share transaction data with payment processors and financial institutions necessary to process your deposits and withdrawals. This includes e-wallet providers (Touch 'n Go, Boost, GrabPay), FPX banking partners (Maybank, CIMB, Public Bank, Hong Leong Bank), DuitNow infrastructure providers, and cryptocurrency payment gateways.
• Identity Verification Providers: We engage third-party KYC and AML screening services to assist with identity verification and fraud prevention. These providers process your KYC documents under binding data processing agreements.
• Game Content Providers: Where you access games provided by third-party software studios (e.g., live casino operators), limited technical data may be shared with those providers to facilitate gameplay. These providers operate under their own privacy policies and data processing agreements with SGA123.
• Legal Authorities: We may disclose your Personal Data to law enforcement agencies, regulatory bodies, or judicial authorities where required to do so by applicable law, valid legal process, or to protect the rights and safety of SGA123, our players, or the public.
• Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of all or part of SGA123's business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection obligations.

SGA123 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal and regulatory obligations. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of your active account plus five (5) years following account closure, to comply with AML and financial record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the date of the last transaction, in accordance with anti-money laundering regulations.
• Financial Transaction Records: Retained for seven (7) years from the date of each transaction, as required by financial record-keeping regulations.
• Customer Support Records: Retained for three (3) years from the date of the last support interaction, to facilitate dispute resolution and service improvement.
• Technical and Usage Data: Typically retained in identifiable form for up to twelve (12) months, after which it may be anonymised and retained indefinitely for aggregate analytical purposes.
• Marketing Consent Records: Retained for the duration of your consent and for a period of three (3) years thereafter, to demonstrate compliance with consent-based marketing obligations.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with our internal data lifecycle management procedures.

SGA123 implements a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction:

• Encryption in Transit: All data transmitted between your device and our Platform is encrypted using industry-standard 256-bit Transport Layer Security (TLS). Our Platform is accessible via HTTPS only.
• Encryption at Rest: Sensitive data stored on our servers, including financial records and KYC documents, is encrypted using AES-256 encryption.
• Access Controls: Access to Personal Data within SGA123 is strictly limited to authorised personnel on a need-to-know basis. All internal access is governed by role-based access controls and logged for audit purposes.
• Two-Factor Authentication: SGA123 offers two-factor authentication (2FA) for Player accounts and mandates it for all internal administrative access.
• Regular Security Audits: Our systems and infrastructure undergo periodic security assessments, penetration testing, and vulnerability scanning to identify and remediate risks proactively.
• Incident Response: In the event of a data breach that poses a risk to your rights and freedoms, SGA123 has a documented incident response procedure in place, including timely notification to affected players and relevant authorities where required.

As a player and data subject, you hold the following rights in respect of your Personal Data held by SGA123. To exercise any of these rights, please contact our Data Protection contact at [email protected]. We will respond to all verifiable requests within thirty (30) calendar days.

SGA123 does not knowingly collect or process Personal Data from individuals under the age of 21. Our Platform and services are strictly intended for adult players aged 21 and above. We deploy age-verification mechanisms at the point of registration and as part of our KYC process to enforce this restriction.

If SGA123 discovers or is made aware that Personal Data has been collected from a person under the age of 21 without appropriate verification, we will take immediate steps to delete that data, close the associated Account, and return any verifiable Real Money Funds deposited, in accordance with our Responsible Gambling Policy.

If you are a parent or guardian and believe that a minor in your care has registered on SGA123 or submitted Personal Data to our Platform, please contact us immediately at [email protected] so that we can take prompt corrective action.

SGA123 primarily processes and stores Personal Data within the region in which our primary infrastructure operates. However, some of our third-party service providers — including KYC verification providers, payment processors, and game content suppliers — may be located in jurisdictions outside Malaysia.

Where Personal Data is transferred to a jurisdiction that does not provide an equivalent level of data protection to that afforded under Malaysian law, SGA123 ensures that appropriate safeguards are in place before any such transfer takes place. These safeguards include:

• Contractual clauses that bind the recipient to data protection standards equivalent to those applicable in Malaysia.
• Ensuring that the recipient entity is certified under a recognised data protection framework or is subject to equivalent regulatory oversight.
• Conducting data transfer impact assessments where required to evaluate and mitigate the risks associated with the transfer.

SGA123 reserves the right to update, revise, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform services. The date of the most recent revision is indicated at the top of this document.

Material changes to this Policy will be communicated to registered Players via email and/or a prominent notice on the Platform at least fourteen (14) days before the amended Policy takes effect, where practicable. For non-material changes, the revised Policy will be posted on this page with an updated effective date, and your continued use of the Platform will constitute acceptance of the revised terms.

We encourage you to review this Policy periodically to stay informed about how SGA123 protects your personal information.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way SGA123 handles your Personal Data, please contact us using the details below:

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week, directly on the Platform (average response time: 3–5 minutes)
• Support Languages: English, Bahasa Melayu, Mandarin Chinese

When submitting a data rights request, please include your full name, registered email address, and a clear description of your request so that we can verify your identity and respond efficiently. We will acknowledge all data rights requests within five (5) business days and aim to resolve them within thirty (30) calendar days.