🔐 big321 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how big321 ("big321," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes personal data in connection with the operation of the big321 online gaming platform accessible at big321.club ("Platform").

This Policy applies to all individuals who register for or use a big321 account, visit the big321 website, or interact with big321's customer support services, regardless of the device or location from which they access the Platform. By registering a big321 account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

big321 is committed to handling personal data in a responsible, transparent, and lawful manner consistent with applicable data protection legislation, including the Personal Data Protection Act 2010 (Malaysia) ("PDPA") and any other applicable laws governing the processing of personal data in the jurisdictions in which big321 operates.

2. Data Controller

For the purposes of applicable data protection law, the data controller responsible for your personal data is big321, the operator of big321.club. Queries relating to this Policy or to the exercise of your data rights should be directed to big321's support team via 24/7 in-platform live chat or by email at [email protected].

3. Personal Data We Collect

big321 collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification number (e.g., MyKad number or passport number) collected during the registration and KYC verification process.
• Contact Data: Email address, Malaysian mobile phone number, and residential address.
• Financial Data: Bank account details, e-wallet identifiers (e.g., Touch n Go eWallet or Boost account references), cryptocurrency wallet addresses, transaction histories, and deposit and withdrawal records.
• Verification Data: Copies of identity documents, proof of address documents, selfie photographs, and source-of-funds documentation submitted for KYC purposes.
• Technical Data: IP address, browser type and version, device type and identifier, operating system, time zone, referring URLs, and session activity logs.
• Gaming Data: Game history, wagering records, bonus utilisation, session duration, and responsible gaming tool usage (e.g., deposit limits set or self-exclusion requests made).
• Communications Data: Records of customer support interactions, live chat transcripts, and any correspondence between you and big321.

big321 does not collect special category personal data (such as health data, racial or ethnic origin data, or political opinions) unless specifically required by applicable law or voluntary responsible gaming processes.

4. How We Collect Personal Data

big321 collects personal data through the following means:

• Direct collection: Information you provide when registering your big321 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and gaming data collected automatically when you access and use the big321 platform, including via cookies and server-side logging.
• Third-party sources: Identity verification data supplemented or verified by licensed KYC service providers; fraud screening data from third-party fraud prevention services; and, where applicable, data from payment processors relating to transaction authentication.

5. Purposes and Legal Basis for Processing

big321 processes your personal data for the following purposes and on the following legal bases:

• Account registration and operation (contractual necessity): To create and maintain your big321 account, authenticate your identity, and provide access to Platform services.
• Payment processing (contractual necessity): To process deposits, withdrawals, and refunds in MYR via your chosen payment method, including Touch n Go eWallet, Boost, and local Malaysian bank transfers.
• KYC and regulatory compliance (legal obligation): To verify player identity and age (21+), comply with anti-money laundering ("AML") obligations, and meet reporting requirements imposed by big321's licensing authority.
• Fraud prevention and platform security (legitimate interests): To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct on the Platform.
• Customer support (contractual necessity / legitimate interests): To respond to support requests, resolve disputes, and maintain records of player interactions.
• Responsible gaming (legal obligation / legitimate interests): To monitor player behaviour for signs of problem gambling, implement responsible gaming tools, and comply with applicable regulatory obligations.
• Platform improvement and analytics (legitimate interests): To analyse aggregated, anonymised usage data to improve Platform performance, game selection, and user experience.
• Marketing communications (consent): To send you information about big321 promotions and offers where you have provided explicit consent. You may withdraw consent at any time via your account settings.

6. Disclosure of Personal Data

big321 does not sell your personal data to any third party. Personal data may be disclosed to the following categories of recipients, all of whom are bound by appropriate confidentiality and data protection obligations:

• Payment service providers: Including Touch n Go, Boost, and licensed Malaysian banking institutions, solely for the purpose of processing your transactions.
• KYC and identity verification providers: Licensed third-party services engaged to assist with identity verification, age verification, and AML screening.
• Game software providers: Third-party game providers (e.g., Pragmatic Play, PG Soft) receive necessary session and transaction data to operate games on the big321 platform. Such providers are contractually prohibited from using this data for any other purpose.
• Fraud prevention and cybersecurity services: Third-party providers engaged to protect the integrity and security of the Platform.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory directive, big321 may disclose personal data to relevant authorities, including the Royal Malaysia Police (PDRM) or financial intelligence units.
• Professional advisors: Lawyers, auditors, and insurers engaged by big321 in connection with the operation of its business, subject to professional confidentiality obligations.

7. International Data Transfers

big321 may transfer your personal data to countries outside Malaysia in connection with the services provided by third-party game software providers, cloud infrastructure providers, and KYC service providers operating internationally. Where such transfers occur, big321 ensures that appropriate safeguards are in place, including contractual data protection clauses consistent with the requirements of the PDPA and any applicable international data transfer frameworks. By using the big321 platform, you consent to such transfers as may be necessary for the operation of the services described in this Policy.

8. Data Retention

big321 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and licensing obligations. In practice:

• Account data and KYC documentation are retained for a minimum of five (5) years following account closure, in accordance with AML regulatory requirements.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for a minimum of three (3) years.
• Gaming and session logs are retained for a period sufficient to meet licensing audit requirements, typically a minimum of one (1) year.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with big321's data disposal procedures.

9. Security Measures

big321 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the big321 platform.
• Encryption at rest for sensitive personal data stored on big321 servers.
• Role-based access controls limiting internal access to personal data to authorised personnel only.
• Regular penetration testing and vulnerability assessments of Platform infrastructure.
• Two-factor authentication options for player accounts to reduce the risk of unauthorised access.

Notwithstanding the above, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your big321 account has been compromised, please contact our support team immediately via in-platform live chat.

10. Cookies and Tracking Technologies

big321 uses cookies and similar tracking technologies on the Platform for the following strictly limited purposes:

• Essential cookies: Required for the Platform to function, including maintaining your login session and remembering your language preferences.
• Performance cookies: Collect anonymised, aggregated data about how players use the Platform to help big321 improve platform speed and reliability.
• Analytics cookies: Used to understand aggregate user behaviour patterns — no personally identifiable information is extracted from analytics data.

big321 does not deploy third-party behavioural advertising cookies or tracking pixels. You may manage cookie preferences through your browser settings; however, disabling essential cookies may affect Platform functionality. By continuing to use the big321 platform, you consent to the use of cookies as described above.

11. Your Rights

Subject to applicable law and big321's legal obligations, registered big321 players have the following rights with respect to their personal data:

• Right of access: You may request a copy of the personal data big321 holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to big321's legal retention obligations.
• Right to restriction: You may request that big321 restrict the processing of your personal data in certain circumstances.
• Right to object: You may object to the processing of your personal data where processing is based on big321's legitimate interests.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of the above rights, please contact big321 via in-platform live chat or at [email protected]. big321 will respond to all data rights requests within thirty (30) days of receipt, subject to identity verification requirements.

12. Children and Minors

The big321 platform is strictly restricted to persons aged 21 years and above. big321 does not knowingly collect personal data from individuals under the age of 21. If big321 becomes aware that personal data has been collected from a person under 21, such data will be deleted promptly and the associated account will be closed. If you believe that a minor has registered a big321 account, please contact us immediately via live chat so that we may investigate and take appropriate action.

13. Links to Third-Party Services

The big321 platform may reference or integrate services provided by third-party game providers and payment processors. big321 is not responsible for the privacy practices of any third-party service and makes no representations regarding the data practices of such parties. We encourage you to review the privacy policies of any third-party service provider whose services you access in connection with the big321 platform.

14. Changes to This Policy

big321 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. Where material changes are made, big321 will notify registered players via the email address on record or via a prominent notice on the Platform prior to the change taking effect. The date at the top of this Policy reflects when it was last updated. Continued use of the big321 platform following the publication of a revised Policy constitutes your acceptance of the updated terms.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or big321's data practices, please contact us via:

• In-platform live chat: Available 24/7 within the big321 platform.
• Email: [email protected] (plain text — not a clickable link).

big321 is committed to resolving all privacy-related enquiries promptly and transparently. This Privacy Policy was last updated on 1 June 2026 and supersedes all previous versions.