ST789 Privacy Policy

This Privacy Policy (hereinafter referred to as "the Policy" or "this Policy") is published by ST789, the operator of the online gaming and sports betting platform accessible at https://st789.lat (hereinafter referred to as "ST789", "the Platform", "we", "us", or "our"). It governs the collection, use, storage, disclosure, and protection of personal data belonging to users (hereinafter referred to as "you", "the User", or "Account Holder") who access or use the ST789 Platform.

ST789 is committed to protecting the privacy and personal data of all users, with particular regard for players based in Malaysia. We handle personal data with care, transparency, and in accordance with applicable data protection principles. This Policy has been prepared to give you a clear and comprehensive understanding of our data practices before you create an account or interact with any feature of the Platform.

By accessing the ST789 Platform, registering an account, or submitting any personal information to us — whether through account registration, KYC verification, live chat, email, or any other channel — you acknowledge that you have read, understood, and consented to the data practices described in this Policy.

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, location data, financial information, and online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" means ST789, the entity that determines the purposes and means of Processing Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of ST789 pursuant to a written agreement.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the User's agreement to the Processing of their Personal Data for one or more specified purposes.
• "KYC" means Know Your Customer — the verification process by which ST789 confirms the identity and eligibility of its users.
• "Cookie" means a small data file placed on a User's device by a web browser when visiting the Platform.
• "Third-Party Service Provider" means any external company or individual engaged by ST789 to provide services necessary for the operation of the Platform, including payment processors and fraud prevention providers.

ST789 collects only the minimum personal data necessary to operate the Platform, comply with applicable regulatory and anti-money laundering obligations, and deliver a high-quality, personalised gaming experience to our users. The categories of Personal Data we collect are set out in the table below.

ST789 collects Personal Data through the following means:

ST789 processes your Personal Data strictly for the following purposes:

• Account administration: creating, maintaining, and managing your ST789 Account, including processing deposits and withdrawals in MYR via supported Malaysian payment methods.
• Identity verification (KYC): confirming your identity, age (minimum 21 years), and eligibility to use the Platform in compliance with anti-money laundering (AML) obligations.
• Fraud detection and prevention: monitoring Account activity for unusual patterns, suspected collusion, multi-accounting, or financial crime indicators.
• Customer support: responding to your queries, complaints, and support requests submitted via live chat or email.
• Platform personalisation: tailoring your gaming experience, delivering relevant promotions, and optimising the Platform interface based on your usage patterns.
• Responsible gambling compliance: enforcing deposit limits, processing self-exclusion requests, and monitoring for indicators of problem gambling behaviour.
• Legal and regulatory compliance: fulfilling ST789's obligations under applicable anti-money laundering regulations, record-keeping requirements, and responding to lawful requests from competent authorities.
• Platform security and improvement: diagnosing technical issues, maintaining system stability, and improving ST789's products and services through aggregated, anonymised analytics.

ST789 processes your Personal Data on the following legal bases:

• Contractual necessity: processing is necessary for the performance of the agreement between you and ST789 as set out in our Terms & Conditions — including account creation, payment processing, and game delivery.
• Legal obligation: processing is required to comply with applicable anti-money laundering, fraud prevention, and identity verification obligations.
• Legitimate interests: processing is necessary for ST789's legitimate interests in fraud prevention, platform security, and the improvement of our services — provided such interests are not overridden by your rights and interests.
• Consent: for non-essential processing such as marketing communications and non-functional cookies, ST789 relies on your express consent, which you may withdraw at any time by contacting our support team.

ST789 does not sell, rent, trade, or otherwise commercially exploit your Personal Data to third parties. We share Personal Data with third parties only in the following strictly limited circumstances:

• Payment processors: financial transaction data is shared with payment service providers (including FPX operator Payments Network Malaysia Sdn Bhd, DuitNow, and e-wallet operators) solely to facilitate deposit and withdrawal processing.
• Identity verification providers: identity document data may be shared with authorised KYC and AML verification service providers for the sole purpose of verifying your eligibility to use the Platform.
• Fraud prevention services: technical and gaming activity data may be shared with fraud detection service providers to identify and prevent account abuse, collusion, or financial crime.
• Game software providers: minimum gameplay data necessary for game delivery and dispute resolution may be shared with ST789's licensed game providers. No direct-identity data is shared with game studios.
• Legal authorities: ST789 will disclose Personal Data to law enforcement, regulators, or courts where legally required to do so by a valid court order, subpoena, or applicable law — and only to the minimum extent required.
• Corporate successors: in the event of a merger, acquisition, or sale of substantially all of ST789's assets, User data may be transferred to the successor entity subject to equivalent privacy protections.

ST789 retains Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable laws and regulations. The following general retention periods apply:

• Account and identity data: retained for the duration of the active Account relationship and for a minimum period of five (5) years following Account closure, in compliance with AML record-keeping obligations.
• Financial transaction records: retained for a minimum of seven (7) years from the date of the transaction, in accordance with standard financial record-keeping requirements.
• Customer support communications: retained for a period of three (3) years from the date of the last interaction.
• Gaming activity logs: retained for a minimum of three (3) years for dispute resolution and responsible gambling monitoring purposes.
• Marketing consent records: retained for as long as the consent remains valid or until it is withdrawn, plus a further six (6) months to evidence the prior consent.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to an identified individual. Anonymised aggregate data may be retained indefinitely for analytics purposes.

ST789 implements industry-standard technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security infrastructure includes the following measures:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and the ST789 servers;
• Encrypted storage for sensitive personal and financial data at rest;
• Access controls ensuring that Personal Data is accessible only to authorised ST789 personnel who require it to perform their duties;
• Two-factor authentication (2FA) available to all Account Holders and mandated for internal administrative access;
• Regular security audits and penetration testing conducted by independent security professionals;
• Real-time intrusion detection and automated anomaly alerts to identify and respond to threats promptly.

While ST789 takes all reasonable precautions to protect your Personal Data, no internet transmission or electronic storage system is completely secure. Users are encouraged to maintain strong, unique passwords for their ST789 Account and to report any suspected unauthorised account access to our support team without delay.

ST789 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit the Platform. They help us recognise returning users, maintain session integrity, and gather analytics data.

You may manage or withdraw consent for non-essential cookies at any time by adjusting your browser settings. Disabling cookies may affect the functionality of certain Platform features. ST789 does not use third-party advertising cookies or cross-site tracking technologies.

As a user of the ST789 Platform, you have the following rights in relation to your Personal Data. To exercise any of these rights, please contact our support team via live chat or by email at [email protected] (plain text — not a clickable link). ST789 will respond to verified requests within thirty (30) calendar days.

The ST789 Platform is strictly for individuals aged21 years and above. ST789 does not knowingly collect Personal Data from any person below the age of 21. If we become aware that Personal Data has been collected from an individual who is under 21 years of age, we will take immediate steps to delete that data and close the associated Account.

Where ST789 has reasonable grounds to suspect that a User may be below the minimum age requirement, the Account will be suspended pending identity and age verification. Documentary proof of age — such as a Malaysian National Identity Card (MyKad) or valid passport — will be required before the Account can be reinstated.

The ST789 Platform integrates with various third-party service providers necessary for its operation, including payment gateways, game software studios, identity verification services, and fraud prevention tools. These third-party providers operate under their own independent privacy policies and are contractually bound to process Personal Data shared with them only for the specific purposes authorised by ST789.

ST789 selects its service providers carefully and requires all providers to maintain data security standards comensurate with those described in this Policy. ST789 does not accept responsibility for the independent data practices of third-party game studios, payment operators (including Touch 'n Go, GrabPay, Boost, Maybank, CIMB, Public Bank, Hong Leong, DuitNow, or FPX) or any other third-party services accessed directly by the User outside of the ST789 Platform.

The ST789 Platform does not contain links to external websites. Where references to third-party payment brands or services appear in our informational content, these are factual descriptions of publicly available payment methods and do not constitute endorsements or partnerships unless expressly stated.

ST789 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or the services we offer. The date of the most recent revision is displayed at the top of this page under "Last Updated."

Where material changes are made to this Policy — changes that significantly affect how we use or protect your Personal Data — we will provide advance notice to registered Account Holders via their registered email address or through a prominent notification on the Platform at least fourteen (14) days prior to the changes taking effect.

Continued use of the ST789 Platform following the effective date of any amended Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you should cease using the Platform and contact our support team to request Account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by ST789, please contact our Data Protection team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week,365 days per year. Average first-response time is under 90 seconds. Live chat is the fastest way to reach us for any privacy-related query.
• Email (plain text — not a clickable link): [email protected]

When submitting a privacy-related request by email, please include "Privacy Request" in your subject line, along with your registered username and a clear description of your request. ST789 will acknowledge all formal privacy requests within two (2) business days and will provide a full response within thirty (30) calendar days, unless complexity or legal requirements necessitate an extension — in which case we will notify you accordingly.