Hugo77 Privacy Policy – Malaysian User Data Protection

1 Introduction

Hugo77 ("we", "Platform") is fully committed to protecting the privacy of every user who uses our services at hugo77.onl and through the Hugo77 mobile app. This Privacy Policy ("Policy") describes our practices regarding the collection, use, disclosure and protection of your personal information.

We understand that trust is the foundation of the relationship between users and a platform. That is why we ensure every action involving your data is carried out with full responsibility, transparency and in compliance with applicable laws in Malaysia — in particular, the Personal Data Protection Act 2010 (PDPA).

2 Information We Collect

Hugo77 collects your personal information through several methods depending on how you interact with our platform. The following are the main categories of information we collect:

We may also receive information about you from trusted third-party sources, such as identity verification service providers and payment providers, solely for the purpose of verifying the accuracy of the information you have provided to us.

3 How We Use Your Data

Every piece of information collected by hugo77 is used for clear and legitimate purposes. We do not use your data for any other purpose without informing you in advance. Below are the primary purposes for which data is used:

• Account management — to securely create, verify, and manage your user account.
• Transaction processing — to process deposits, withdrawals, and all financial transactions made through the platform.
• Identity verification (KYC) — to fulfil legal obligations related to anti-money laundering and age verification.
• Customer Support — to respond to enquiries, resolve complaints, and provide technical assistance to users.
• Platform Security — to detect and prevent fraudulent activity, hacking attempts, and other security threats.
• Service improvement — to analyse usage patterns and improve overall game quality and platform features.
• Marketing communications — to send promotional information, exclusive offers, and the latest hugo77 news, subject to your communication preferences.
• Responsible gaming — to monitor betting patterns and identify users who may need support.

4 Information Sharing and Disclosure

Hugo77 does not sell or rent your personal data to any third party. However, we may share your information in limited and controlled situations as follows:

• Payment service providers — to process deposits and withdrawals via FPX, Touch 'n Go eWallet, GrabPay, and other supported payment methods.
• Identity verification service providers — for KYC and age verification purposes as required by law.
• Technology service providers — companies that help us operate the platform, store data, and provide technical services, all bound by strict confidentiality agreements.
• Competent authorities — when required by law, court order, or a legitimate request from law enforcement authorities.
• Protection of hugo77's rights — in cases where disclosure is necessary to prevent fraud, protect user safety, or defend legal claims.

Any third party receiving your data from hugo77 is required to uphold the same high data protection standards that we maintain. Data sharing is carried out only to the extent necessary for the stated purpose.

5 Data Security

Hugo77 continually invests in the latest security infrastructure to protect your personal data. The security measures we employ include:

• 256-bit SSL/TLS encryption for all data transmissions between users and our servers.
• Data-at-rest encryption on all databases storing personal information.
• Two-factor authentication (2FA) available for all user accounts.
• 24/7 monitoring of suspicious activity and cyber threats.
• Regular penetration testing conducted by independent security experts.
• Regular information security training for all staff with access to user data.
• Tested incident response procedures to address any data breach swiftly and effectively.

6 Cookies and Tracking Technologies

Hugo77 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

Types of cookies we use:

• Essential Cookies — required for core platform functions such as login session verification and security. These cookies cannot be disabled.
• Performance Cookies — collects anonymous information about how users interact with the platform to help us improve it.
• Functional Cookies — stores user preferences such as language, display settings, and personalised configurations.
• Analytics Cookies — helps us understand aggregate user behaviour for service improvement.

You may manage your cookie settings through your web browser at any time. Please note, however, that disabling certain cookies may affect the functionality or user experience of the Hugo77 platform.

7 Your Rights as a User

As a hugo77 user and as an individual protected under Malaysia's Personal Data Protection Act 2010, you have the following rights regarding your personal data:

8 Children's Data Protection

The hugo77 platform is strictly for individuals aged 18 and above. We do not knowingly collect, store or process any personal data from children or minors.

If we discover that personal data of an individual under the age of 18 has been collected without our knowledge, we will immediately take the following steps:

• Suspending the relevant account immediately.
• Deleting all personal data relating to that individual from our systems.
• Reporting the incident to the relevant authorities where required.

If you believe that your child or a minor you know has registered a Hugo77 account, please contact our support team immediately so that appropriate action can be taken.

9 International Data Transfers

Some of your personal data may be stored or processed on servers located outside Malaysia. When this occurs, hugo77 ensures that such data transfers are carried out with adequate safeguards, including:

• Data Processing Agreements compliant with international standards.
• Ensuring that data recipients outside Malaysia comply with data protection standards equivalent to Malaysia's PDPA.
• Using internationally recognised standard contractual clauses for cross-border data transfers.

Hugo77 only uses cloud and infrastructure service providers that hold internationally recognised security certifications such as ISO 27001 and SOC 2.

10 Data Retention Period

Hugo77 retains your personal data only for as long as necessary to fulfil the purposes set out in this Policy, or as required by applicable law. Generally:

• Active account data — retained for the duration your account is active and up to 7 years after account closure for legal compliance purposes.
• Financial transaction records — retained for 7 years from the transaction date in accordance with Malaysian legal requirements.
• Communication logs — retained for 2 years for customer support and dispute resolution purposes.
• Analytics cookie data — retained for no more than 13 months from the date of collection.
• KYC Documents — retained for 5 to 7 years after the business relationship ends, in accordance with the Anti-Money Laundering Act requirements.

Once the designated retention period has ended, your data will be securely deleted or anonymised so that it can no longer be personally linked to you.

11 Privacy Policy Amendment

Hugo77 reserves the right to amend this Privacy Policy from time to time in line with changes in law, industry practices or our operations. Any material amendments will be communicated to users via:

• Clear and prominent in-app or on-site notifications on the hugo77 platform.
• Email to the address registered in the user's account at least 14 days before the amendment takes effect.
• Update the "Last Updated" date at the top of this document.

Continued use of the hugo77 platform after the effective date of any amendment constitutes acceptance of the revised policy. If you do not agree with the changes, you have the right to close your account before they take effect.

12 Contact Us

If you have any questions, concerns or complaints regarding this Privacy Policy or how Hugo77 handles your personal data, please contact us through the following channels:

• Live Chat — available 24 hours a day, 7 days a week via the chat icon at the bottom corner of the platform.
• Support Email — [email protected] (we aim to respond within 24–48 business hours).