Privacy Policy — svip2

This Privacy Policy ("Policy") issued by svip2 ("the Company", "we", "us", or "our") and applies to all personal data collected in connection with your use of the svip2 online gaming platform accessible at https://svip2.click ("the Platform") and all associated services.

svip2 takes its obligations regarding the privacy and security of personal data seriously. This Policy is designed to give you clear, transparent information about how we handle your data so that you can make informed decisions about your use of the Platform.

By registering an Account on the svip2 Platform, or by otherwise accessing or using any part of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

For the purposes of this Policy, the following terms shall carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — the data subject — who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, or online identifier.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, use, disclosure, or deletion.
• "Data Controller" refers to svip2, which determines the purposes and means of processing your Personal Data.
• "Data Processor" refers to any third party that processes Personal Data on behalf of svip2 under a data processing agreement.
• "Account" means a registered user profile on the svip2 Platform.
• "User", "you", or "your" refers to any individual who accesses, registers on, or uses the svip2 Platform.
• "KYC" means Know Your Customer — the identity verification process applied to all svip2 Account holders.
• "Cookies" means small text files placed on your device by the Platform to facilitate certain functions and improve user experience.

svip2 collects the following categories of personal data in connection with your use of the Platform:

svip2 collects personal data through the following means:

• Direct Collection: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawal requests, submitting support enquiries, or participating in promotions.
• Automated Technical Collection: Data collected automatically as you interact with the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, and browsing behaviour on the Platform.
• Payment Processors: Transaction data received from payment service providers including GrabPay, Touch 'n Go eWallet, Boost, DuitNow, FPX-connected banks (such as Maybank, CIMB, Public Bank, Hong Leong Bank), and card networks in connection with deposit and withdrawal processing.
• Identity Verification Services: Data returned by KYC and identity verification service providers engaged by svip2 to validate the authenticity of identity documents.
• Third-Party Sources: Fraud prevention databases, credit reference agencies, and publicly available sources where permitted by applicable law, for the purpose of anti-moneylaundering (AML) and fraud prevention checks.

svip2 processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your svip2 Account, including authentication and access control.
• Service Delivery: Processing deposits and withdrawals, making Games available, crediting bonuses, and fulfilling all other contractual obligations to you as a registered Player.
• KYC and AML Compliance: Verifying your identity, confirming your age (21+ requirement), and conducting ongoing anti-money-laundering and counter-terroristfinancing checks as required by applicable law.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, unauthorised access, account compromise, and other forms of platform misuse.
• Responsible Gambling: Monitoring usage patterns to identify potential problem gambling behaviour and applying responsible gambling tools where appropriate, including deposit limits and self-exclusion where requested.
• Customer Support: Responding to enquiries, resolving disputes, and providing technical assistance.
• Marketing Communications: Sending promotional offers and platform updates where you have consented to receive such communications. You may withdraw this consent at any time.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the features, performance, and user experience of the Platform.
• Legal and Regulatory Compliance: Meeting our obligations under applicable data protection, gaming regulation, financial crime prevention, and tax laws.

svip2 processes your personal data one or more of the following legal bases, depending on the nature of the processing activity:

• Contractual Necessity: Processing is required to perform our contractual obligations to you as a registered svip2 User — including maintaining your Account, processing transactions, and delivering gaming services.
• Legal Obligation: Processing is necessary to comply with applicable laws and regulations, including KYC requirements, AML obligations, and gaming licence conditions.
• Legitimate Interests: Processing is necessary for our legitimate interests — such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your fundamental privacy rights.
• Consent: Where we rely on your consent (for example, for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

svip2 does not sell, rent, or trade your personal data. We may disclose your personal data to the following categories of third parties, strictly where necessary and under appropriate data protection safeguards:

• Payment Service Providers: GrabPay, Touch 'n Go eWallet, Boost, DuitNow, FPX-participating banks, Visa, Mastercard, and cryptocurrency processors — solely to execute your deposit and withdrawal transactions.
• Identity Verification and KYC Providers: Third-party services engaged to verify the authenticity of identity documents and conduct age verification checks.
• Fraud Prevention and AML Services: Specialist providers engaged to assist in detecting and preventing money laundering, fraud, and other financial crimes.
• Technology and Infrastructure Providers: Hosting, cloud infrastructure, and cybersecurity service providers who process data on our behalf under strict contractual data processing agreements.
• Customer Support Platforms: Third-party live chat and ticketing software used to manage support interactions on the Platform.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or regulatory direction — including gaming regulators and financial intelligence authorities.

All third parties to whom svip2 discloses personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

As an online platform serving Malaysian users, certain aspects of our technical infrastructure and third-party service providers may involve the transfer of personal data to jurisdictions outside of Malaysia. Where such transfers occur, svip2 ensures that adequate safeguards are in place to protect your personal data, including:

• Transfer to countries recognised as providing an adequate level of data protection under applicable law.
• Use of contractual clauses that impose equivalent data protection obligations on the recipient.
• Application of appropriate technical and organisational security measures to protect data in transit and at rest.

svip2 will not transfer your personal data internationally in circumstances where the transfer would result in a lower standard of protection than you would receive under Malaysian data protection law.

svip2 retains your personal data for as long as is necessary for the purposes for which it was collected, or as required by applicable legal, regulatory, or accounting obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of your Account registration and for a minimum period of five (5) years following Account closure, in accordance with AML and gaming regulatory requirements.
• Transaction Records: Financial transaction records are retained for a minimum of seven (7) years following the date of the transaction, as required for accounting and regulatory reporting purposes.
• KYC and Identity Documents: Retained for a minimum of five (5) years following Account closure or the date of the most recent transaction, whichever is later.
• Support Communications: Live chat transcripts and email correspondence are retained for up to two (2) years from the date of the interaction unless required for longer in connection with an ongoing dispute or legal proceeding.
• Technical and Usage Data: Retained for up to twenty-four (24) months unless required for longer for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data lifecycle procedures. Anonymised aggregate data may be retained indefinitely for analytical purposes where it no longer constitutes personal data.

svip2 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies may be placed on your device when you visit the Platform:

• Strictly Necessary Cookies: Essential to the operation of the Platform. These cookies enable core functions such as user authentication, session management, and security features. They cannot be disabled without impairing Platform functionality.
• Functional Cookies: Enable enhanced functionality and personalisation — such as remembering your language preferences, display settings, and last accessed games. Disabling these may affect your user experience.
• Analytics Cookies: Used to collect aggregated, anonymised information about how Users interact with the Platform, helping us identify areas for improvement. No personally identifiable data is retained through these cookies.
• Security Cookies: Used to support fraud detection, bot identification, and account security functions. These are a necessary component of our Platform security architecture.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the availability of some Platform features. For strictly necessary cookies, no opt-out is available as they are required for the Platform to function.

Subject to applicable law, you have the following rights in respect of your personal data held by svip2:

• Right of Access: You may request a copy of the personal data svip2 holds about you, along with information about how it is being used.
• Right of Rectification: You may request correction of any inaccurate or incomplete personal data held in your Account at any time.
• 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, provided there is no overiding legal obligation requiring its retention.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: Where processing is based on your consent or on contract, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your personal data where it is based on our legitimate interests, including for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact our support team using the details provided in Section16 of this Policy. We will respond to all verified data rights requests within thirty (30) days of receipt. In complex cases, we may extend this period by a further sixty (60) days, notifying you of the extension and the reason for the delay.

svip2 strictly prohibits access to its Platform by individuals under the age of 21. We do not knowingly collect, retain, or process personal data relating to any individual under 21 years of age.

Age verification is a mandatory component of our Account registration process. All new registrations are subject to KYC-based age verification before Account activation. Accounts found to belong to individuals under 21 will be immediately suspended, all associated data securely managed in accordance with applicable law, and any deposited funds returned to the original payment source where permissible.

svip2 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and our Platform.
• Encryption of sensitive data fields (including financial data and identity document copies) at rest within our secure database infrastructure.
• Strict internal access controls — only authorised personnel with a documented need to access specific categories of personal data are permitted to do so.
• Regular security audits, vulnerability assessments, and penetration testing of our Platform infrastructure.
• Two-factor authentication availability for User Accounts.
• Real-time fraud detection and intrusion monitoring systems operating continuously across our Platform infrastructure.
• Secure, audited destruction of physical and digital data upon expiry of applicable retention periods.

While svip2 takes all reasonable steps to protect your personal data, no transmission over the internet is entirely secure. You are responsible for maintaining the confidentiality of your Account credentials and for ensuring that your device and internet connection are reasonably secure when accessing the Platform.

The svip2 Platform integrates with a number of third-party services in order to deliver our full suite of features. These include payment gateways, game software providers, KYC verification services, and customer support tools. Each of these integrations involves limited, purpose-specific data sharing governed by contractual data processing agreements.

In particular, when you make a deposit or withdrawal using a Malaysian e-wallet service (such as GrabPay, Touch 'n Go eWallet, or Boost), a bank transfer via FPX, or a DuitNow transfer, your payment data is processed by the relevant payment service provider in accordance with their own privacy policies and applicable Malaysian financial regulations.

svip2 does not control the privacy practices of these third-party providers. We encourage you to review the privacy policies of any third-party payment or service provider you use in connection with your svip2 Account.

svip2 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. We will provide advance notice of any material changes through one or more of the following means:

• A prominent notification displayed on the Platform upon your next login following the update.
• An email notification to your registered address summarising the key changes.
• An update to the "Last Updated" date shown at the top of this page.

Your continued use of the Platform following the effective date of any amendment will constitute acceptance of the updated Privacy Policy. If you do not agree with the amended terms, you are entitled to close your Account by contacting our support team. Any personal data collected prior to the date of Policy amendment will continue to be handled in accordance with the Policy version applicable at the time of collection, to the extent required by law.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data svip2 holds about you, please contact our Data Privacy team through any of the following channels:

When contacting us regarding a data rights request, please include your registered email address and Account username to enable us to locate your data accurately. We may request additional identity verification before actioning any sensitive data request.

This Privacy Policy was last reviewed and updated on 1 January 2026. All prior versions of this Policy are superseded in their entirety by this version.