Sayap33 Privacy Policy – Malaysia Member Personal Data Protection

Sayap33 ("we", "our platform") is committed to protecting the privacy of every member who uses our services. This Privacy Policy is designed to give you full clarity on how your personal information is collected, processed, stored, and protected when you use the sayap33 platform.

This document also outlines your rights as a data subject under Malaysia's Personal Data Protection Act 2010 (PDPA), and how you may exercise those rights. We encourage you to read this document carefully and to contact us should you have any questions.

This policy applies to all Sayap33 channels, including the official website, mobile app for Android and iOS, and all interactions conducted through our customer support channels. It covers all user categories — whether new members, active members, or former members whose accounts have been closed.

We only collect data that is strictly necessary to provide a safe and quality service. The following are the categories of data we collect and their purposes:

We do not collect any sensitive data such as health information, religious beliefs, or political views unless required by law. All data collection is conducted directly from you or through your use of our platform only.

The personal data we collect is used responsibly and only for the following legitimate purposes:

• Account Management: Creating, verifying, and securely maintaining your member account.
• Transaction Processing: Processing deposits, withdrawals, and other financial activities related to your account.
• Identity Verification (KYC): Ensuring compliance with anti-money laundering laws and age verification.
• Platform Security: Detecting and preventing fraudulent activity, hacking, and system abuse.
• Customer Support: Responding to enquiries, resolving disputes, and providing technical support.
• Service Communications: Sending important account notifications, promotions, and service updates.
• Legal Compliance: Meeting reporting obligations to relevant authorities when required.

Sayap33 values your trust. We only share your personal data in limited and controlled circumstances, namely:

• Payment Providers: Required financial information is shared solely with approved payment processors to complete your transactions.
• Technology Service Providers: Our technical partners who help operate the platform infrastructure are bound by strict confidentiality agreements.
• Authorities: We will disclose information to law enforcement agencies or regulatory bodies when required to do so under applicable Malaysian law.
• Audit & Compliance: Independently appointed auditors engaged to ensure platform operational compliance are bound by binding confidentiality agreements.

All third parties who receive your data are required to handle that information in accordance with data protection standards equal to or higher than our own. We do not permit third parties to use your data for their own purposes outside the scope of services provided to us.

Protecting your personal data is an absolute priority for sayap33. We implement comprehensive technical and organisational security measures to ensure your data is always safeguarded against unauthorised access, loss, or damage.

Key security measures we implement include:

• 256-bit SSL/TLS Encryption for all data transmitted between your device and our servers.
• Two-factor authentication (2FA) available to all member accounts for an additional layer of security.
• 24/7 Monitoring by our security team to detect any suspicious activity.
• Regular data backups at a secure, separate location to ensure service continuity.
• Penetration testing conducted periodically by independent security experts.
• Security training for all staff who handle members' personal data.

While we take every reasonable precaution, no security system is entirely foolproof. In the event of any data breach that may affect you, we are committed to notifying you within the timeframe prescribed by law.

Sayap33 retains your personal data only for as long as necessary to fulfil the original purpose of collection or to comply with applicable legal obligations. In general, our retention principles are as follows:

• Active Account Data: Retained for the duration of your active membership on the Sayap33 platform.
• Post-Account Closure Data: Basic information is retained for five (5) years for anti-money laundering compliance purposes.
• Transaction Records: Retained for seven (7) years in accordance with Malaysia's accounting and tax legal requirements.
• Technical Logs: Log data and security records are retained for three (3) months before being automatically deleted.

Once the retention period expires, your data will be securely deleted or converted into an anonymised format that can no longer be linked to your identity.

Under Malaysia's PDPA and Sayap33's privacy policy, you have the following rights regarding your personal data:

To exercise any of the above rights, please contact our customer support team. We will process your request within 21 business days from the date of receipt of a complete request.

The sayap33 platform uses cookies and similar technologies to enhance the user experience, secure login sessions, and understand how users interact with our platform. The types of cookies we use are:

• Essential Cookies: Required for core platform functions such as login authentication and session security. These cookies cannot be disabled.
• Performance Cookies: Collecting anonymous information on how users interact with the platform to help us improve our services.
• Preference Cookies: Saving your preferences such as language and display settings for a more convenient experience on return visits.

You can manage your cookie settings through your web browser. Please note that disabling essential cookies may affect platform functionality and your overall user experience.

Sayap33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, relevant legislation, or service improvements. Each new version will be published on this page with a clear update date.

For significant changes that may affect how we process your data, we will endeavour to notify you in advance via email or in-platform notification at least seven (7) days before the changes take effect. Your continued use of our platform after the effective date constitutes acceptance of the updated policy.

We encourage you to review this page periodically to stay informed about how we protect your privacy.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, our team is ready to assist.

You may contact our Data Protection Officer (DPO) through Sayap33's customer support channels, available 24 hours a day, 7 days a week. We are committed to responding within three (3) business days for all privacy-related enquiries.

You also have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia if you believe your privacy rights have been violated and we have failed to resolve the matter to your satisfaction.