Privacy Policy HCM44 – Personal Data Protection for Malaysian Members

Hcm44 collects your personal data through several means — either directly when you register and use the platform, or automatically through tracking technologies used in our platform's operations. Below are the categories of data we collect and the reasons for doing so:

Every piece of data we collect serves a clear and legitimate purpose. hcm44 uses your personal data solely for the following:

• Account management: Creating and maintaining your hcm44 account, processing registration, managing logins, and keeping your account secure from unauthorised access.
• Financial transaction processing: Processing deposits made via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, or FPX (Maybank2u, CIMB Clicks), and managing withdrawals of winnings to your preferred payment method.
• Identity verification (KYC): Conducting the age verification and identity checks required by the platform's KYC procedures to confirm you meet the minimum eligibility requirements and to prevent fraud.
• Anti-money laundering (AML) compliance: Monitoring transactions to detect and prevent activities suspected of involving money laundering or the financing of illegal activities, in line with regulatory compliance requirements.
• Platform improvements: Analysing aggregated (not individual) usage data to understand how members use the hcm44 platform, identify technical issues, and make ongoing improvements to the user experience.
• Service communications: Sends important notifications about your account, changes to our terms and conditions or privacy policy, security information, and responses to your customer support inquiries.
• Experience personalisation: With your consent, we may use usage data to suggest promotions or games relevant to your interests. You may withdraw this consent at any time.
• Responsible gaming: Monitors gameplay patterns to identify signs of potential gambling problems and offers appropriate responsible gaming tools when needed.

Hcm44 does not sell, rent, or trade your personal data to third parties for marketing purposes. However, in the course of running our platform, there are situations where we need to share your data with carefully selected third parties. This is done only when strictly necessary and always with appropriate safeguards in place.

• Payment service providers: When you make a deposit or withdrawal, the required transaction details are shared with the relevant e-wallet provider (Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow) or bank via FPX. This sharing is solely for the purpose of processing your financial transaction.
• Game providers: Companies such as Pragmatic Play, Microgaming, NetEnt, and Evolution Gaming, which supply games to the hcm44 platform, may receive the minimum session data required to operate their games. All game providers are bound by strict confidentiality agreements.
• Identity verification services: For the KYC process, your identity information may be verified against a licensed third-party verification service. This is to ensure the safety of all hcm44 members.
• Statutory authorities: hcm44 may be required to disclose your personal data to statutory authorities, law enforcement agencies, or regulators when compelled by law or a valid court order. In such cases, we will disclose only the minimum information necessary.
• Business acquisition: In the event of a merger, acquisition, or sale of hcm44 assets, members' personal data may be transferred to the new entity. Members will be notified in advance of any such changes and informed of their rights in that context.

Hcm44 continuously invests in cybersecurity infrastructure to ensure our members' personal and financial data remains protected at all times. Below are the key security measures we have in place:

• 256-bit SSL Encryption: All data communications between your browser and hcm44's servers are encrypted using TLS protocol with 256-bit SSL keys. This ensures that any information you transmit — whether during login, deposits, or other activities — cannot be read by any unauthorised party.
• Servers in secure data centres: hcm44 member data is stored in high-grade data centres protected by comprehensive physical and digital security controls, including intrusion detection systems, biometric access controls, and 24/7 monitoring.
• Password hashing: Your password is stored using a strong cryptographic hashing algorithm (bcrypt). This means your actual password is never stored or viewable by any hcm44 staff — not even in the event of an unexpected data breach.
• Internal access controls: Access to members' personal data within hcm44 is restricted to staff who have a direct operational need (the "least privilege" principle). All access to sensitive data is logged and monitored.
• Regular security audits: The hcm44 platform undergoes regular security audits and penetration testing by independent cybersecurity firms to identify and patch vulnerabilities before they can be exploited.
• Incident response procedures: hcm44 has a detailed security incident response procedure in place. In the event of a data breach that affects the security of members' personal data, hcm44 is committed to notifying affected members within a reasonable timeframe in accordance with applicable legal requirements.

Hcm44 uses cookies and similar tracking technologies to enhance user experience, maintain account security, and understand how the platform is used. Here is an overview of the types of cookies we use:

• Strictly necessary cookies: These cookies are essential to the core functionality of the hcm44 platform — including maintaining your login session, remembering your language preference, and securing your transactions. They cannot be disabled without affecting how the platform operates.
• Performance cookies: We use performance cookies to collect information about how members use the hcm44 platform — which pages are visited most frequently, how long sessions last, and where users encounter technical difficulties. All of this information is collected in aggregate and anonymously.
• Functionality cookies: These cookies allow the hcm44 platform to remember your preferences — such as your favourite games, display settings, and last deposit method — so you don't have to reconfigure them every time you log in.
• Analytics cookies: hcm44 uses licensed third-party analytics tools to understand overall platform usage trends. Analytics data does not contain any information that could identify you as an individual.

You can manage cookie settings in your web browser. However, disabling certain cookies may affect the functionality of the hcm44 platform. For more information on how to manage cookies, please refer to your web browser's help documentation.

As an hcm44 member, you have several rights regarding your personal data. hcm44 is committed to respecting and facilitating the exercise of these rights:

• Right of access: You have the right to request a copy of all personal data hcm44 holds about you. This request can be made via customer support live chat or by emailing support@hcm44.best and will be processed within 30 business days.
• Right to rectification: If you find that any personal data we hold about you is inaccurate or out of date, you have the right to request a correction. Details such as your phone number and email address can be updated directly from your account settings.
• Right to erasure: Under certain circumstances, you have the right to request deletion of your personal data (the "right to be forgotten"). However, this right is not absolute — we may be required to retain certain data to comply with legal obligations (for example, financial transaction records for AML purposes).
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes. You may withdraw your marketing consent at any time from your account settings or by contacting our support team.
• Data portability right: You have the right to receive the personal data you have provided to hcm44 in a structured, commonly used, machine-readable format — where technically feasible.
• Right to restrict processing: Under certain circumstances (for example, while you dispute the accuracy of your data), you may request that hcm44 restrict the processing of your data pending resolution.

Hcm44 retains your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required by applicable law.

• Active account: For as long as your hcm44 account remains active, we retain all personal data and usage data necessary to deliver our services safely and effectively.
• Financial transaction records: Deposit and withdrawal transaction records are retained for a minimum of 7 years from the date of the transaction. This is a standard compliance requirement for financial records and anti-money laundering activities.
• Closed accounts: After an hcm44 account is closed at a member's request, usage data and personal data not subject to legal retention requirements will be deleted within 90 days. Financial transaction records will be retained for 7 years as stated above.
• Accounts suspended or closed due to fraud: In such cases, hcm44 reserves the right to retain all relevant data for as long as necessary for the purposes of investigation, legal action, or asset recovery.
• Customer support communication logs: Conversation records with the hcm44 customer support team are retained for 2 years from the date of the last interaction, for quality control and dispute resolution purposes.

Hcm44 may update this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or platform improvements. Here is how we handle such updates:

• Notice of material changes: For any material changes to how we process your personal data, hcm44 will notify members via in-platform notifications at least 7 days before the changes take effect.
• Date updated: The "Last Updated" date at the top of this page always reflects the date of the most current version of this Privacy Policy. We encourage you to review this page periodically.
• Continued use as acceptance: Continued use of the hcm44 platform after a Privacy Policy update takes effect will be considered your acceptance of the revised terms. If you do not agree with the changes, you have the right to close your account.
• Previous version archive: Previous versions of the Privacy Policy are available upon request from hcm44's customer support team, should you need them for reference purposes.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how hcm44 handles your personal data, please contact us through the following channels:

• Live chat: The fastest way to get a response — the hcm44 support team is available 24/7 via live chat on hcm44.best.
• Email: For more detailed privacy enquiries, please email us at support@hcm44.best. Include "Privacy Enquiry" in the subject line to ensure your message is directed to the right team.

We are committed to responding to all privacy-related inquiries within 5 business days. For more serious or complex complaints, we will provide an update on resolution progress within 30 business days.