nanas44 Privacy Policy

1. Introduction

nanas44 ("the Company", "we", "us", "our") operates the online gaming platform accessible at nanas44.co (the "Platform"). This Privacy Policy describes how nanas44 collects, uses, stores, shares, and protects personal data relating to individuals who access or use the Platform ("Players", "Users", "you"). It also describes the rights available to you in relation to your personal data and how to exercise them.

By registering an account with nanas44 or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not accept the practices described herein, you should not use the Platform. This Privacy Policy forms part of, and should be read alongside, the nanas44 Terms & Conditions.

nanas44 is committed to handling your personal data with the same care and discretion that we apply to securing your account and funds. Transparency is central to that commitment — which is why this policy is written in plain, accessible language rather than obscured behind opaque legal boilerplate.

2. Data Controller

For the purposes of applicable data protection legislation, nanas44 acts as the data controller in respect of personal data collected through the Platform. The data controller is responsible for determining the purposes and means of processing your personal data. Queries relating to data controller status or the exercise of data subject rights should be directed to the nanas44 support team at the contact details provided in Section 14 of this policy.

Where nanas44 engages third-party service providers who process personal data on our behalf (for example, payment processors and KYC verification providers), those parties act as data processors under contractual data processing agreements that require them to process data only on nanas44's documented instructions and to maintain appropriate security standards.

3. Personal Data We Collect

3.1 Registration and Account Data

When you register a nanas44 account, we collect: full legal name, date of birth, residential address, email address, phone number, and login credentials (username and hashed password). This information is required to create and manage your account and to verify your identity in accordance with our KYC obligations.

3.2 Identity Verification (KYC) Data

To comply with international gaming licensing requirements and applicable anti-money-laundering obligations, nanas44 may collect copies of government-issued identity documents (such as MyKad or passport), proof of address documents, and source-of-funds documentation. These documents are processed solely for the purposes of identity verification and regulatory compliance.

3.3 Financial Data

We collect records of deposits, withdrawals, and transaction history associated with your account. Payment instrument details (such as bank account numbers or e-wallet identifiers) are collected to process financial transactions. nanas44 does not store full payment card numbers on its systems.

3.4 Gaming Activity Data

We collect records of your wagering activity on the Platform, including bet history, game sessions, stakes, outcomes, and promotional interactions. This data is used for account management, responsible gaming monitoring, dispute resolution, and regulatory reporting.

3.5 Technical and Device Data

We automatically collect technical data including your IP address, browser type and version, operating system, device identifiers, session timestamps, and pages visited on the Platform. This data is used for security monitoring, fraud prevention, and Platform optimisation.

3.6 Communications Data

Records of your communications with the nanas44 support team — including live chat transcripts and email correspondence — are retained for quality assurance, training, and dispute resolution purposes.

4. How We Collect Your Data

nanas44 collects personal data through the following channels:

• Direct collection: Information you provide when registering, completing KYC, making deposits, contacting support, or updating your account profile.
• Automated collection: Technical data collected automatically when you access and navigate the Platform via cookies, server logs, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data may be supplemented by information obtained from licensed KYC and credit reference agencies where required for compliance purposes. Payment processors may share transaction-related data with nanas44 to facilitate financial operations.

5. Purposes of Processing and Legal Basis

nanas44 processes your personal data for the following purposes, each grounded in a specific legal basis under applicable data protection legislation:

• Account creation and management — necessary for the performance of the contract between you and nanas44.
• Processing financial transactions — necessary for the performance of the contract and for compliance with financial regulatory obligations.
• Identity verification (KYC) — necessary for compliance with legal obligations under applicable gaming licensing and anti-money-laundering regulations.
• Fraud prevention and security — necessary for legitimate interests pursued by nanas44 in protecting the Platform, its players, and its financial systems from fraudulent activity.
• Responsible gaming monitoring — necessary for compliance with gaming licensing obligations and for the legitimate interest of safeguarding player welfare.
• Customer support — necessary for the performance of the contract and for legitimate interests in maintaining service quality.
• Marketing communications — based on your consent, where separately obtained. You may withdraw consent at any time by updating your communication preferences in account settings.
• Regulatory reporting — necessary for compliance with legal obligations imposed by gaming licensing authorities and financial regulators.

6. Sharing Your Personal Data

nanas44 does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: To facilitate deposits and withdrawals via Touch 'n Go eWallet, Boost, Maybank FPX, CIMB FPX, Public Bank FPX, and other accepted methods.
• KYC and identity verification providers: To fulfil our identity verification and anti-money-laundering obligations.
• Game content providers: Limited technical data may be shared with licensed game providers whose content is integrated into the Platform, solely to support game delivery and integrity.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory directive. nanas44 will disclose only the minimum data required to satisfy such obligations.
• Professional advisers: Including legal counsel, auditors, and insurers where necessary in the ordinary course of business, subject to professional confidentiality obligations.

In all cases where data is shared with third-party processors, nanas44 maintains contractual data processing agreements that bind those processors to process data only as instructed by nanas44 and to maintain security standards commensurate with the sensitivity of the data.

7. International Data Transfers

The nanas44 Platform serves Malaysian players and processes data primarily within the jurisdiction of its gaming licence. Where personal data is transferred to third parties located outside Malaysia — for example, to international KYC providers or game content delivery infrastructure — such transfers are conducted subject to appropriate safeguards, including standard contractual clauses or equivalent data protection mechanisms recognised under applicable law. You may request further information about the specific safeguards in place for any such transfer by contacting nanas44 support.

8. Cookies and Tracking Technologies

nanas44 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function, including session authentication and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options to improve your experience.
• Analytics cookies: Collect aggregated data about Platform usage to help us understand how players navigate the site and where improvements can be made. This data is anonymised where possible.
• Security cookies: Used for fraud detection and prevention, including identifying unusual access patterns or account activity.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. nanas44 does not use third-party advertising or behavioural tracking cookies.

9. Data Retention

nanas44 retains personal data for the following periods, or longer where required by applicable law or regulatory obligation:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, in accordance with anti-money-laundering record-keeping requirements.
• Transaction records: Retained for a minimum of seven (7) years to satisfy financial regulatory and tax record-keeping obligations.
• Gaming activity data: Retained for a minimum of five (5) years following the last relevant transaction, as required by gaming licensing regulations.
• Support communications: Retained for three (3) years following the closure of the relevant support interaction.
• Technical and log data: Retained for twelve (12) months and then deleted, unless specific data must be retained in connection with an ongoing fraud investigation or legal proceeding.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with nanas44's data disposal procedures.

10. Your Data Subject Rights

Subject to applicable data protection legislation, you hold the following rights in respect of your personal data processed by nanas44:

• Right of access: You may request a copy of the personal data nanas44 holds about you, along with information about how it is processed.
• Right to rectification: You may request correction of inaccurate or incomplete personal data held by nanas44.
• 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 nanas44's legal retention obligations.
• Right to restrict processing: You may request that nanas44 restrict the processing of your personal data in certain circumstances, for example whilst the accuracy of data is contested.
• Right to data portability: You may request a copy of personal data you have provided to nanas44 in a structured, commonly used, machine-readable format where processing is carried out by automated means.
• Right to object: You may object to processing of your personal data carried out on the basis of legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please contact nanas44 support via the details in Section 14. We will respond to verified requests within thirty (30) days. Identity verification may be required before requests are processed to protect the security of your account.

11. Security Measures

nanas44 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

• 256-bit SSL/TLS encryption for all data in transit between your device and nanas44 servers.
• Encryption of sensitive data fields — including identity documents and payment references — at rest within nanas44 systems.
• Role-based access controls limiting internal access to personal data to authorised personnel with a documented need to access it.
• Regular security assessments and penetration testing of Platform infrastructure.
• Two-factor authentication available to all Players for account access, and mandatory for internal administrative access.
• Documented incident response procedures for managing and reporting personal data breaches in compliance with applicable notification obligations.

Notwithstanding the above, no security system is impenetrable. nanas44 cannot guarantee absolute security of data transmitted over the internet. You are responsible for maintaining the security of your nanas44 account credentials and for notifying us promptly of any suspected unauthorised access.

12. Children and Minors

The nanas44 Platform is strictly intended for adults aged 21 years and above. nanas44 does not knowingly collect personal data from individuals under the age of 21. If we become aware that an account has been registered by or on behalf of a person under the minimum age requirement, that account will be immediately suspended and all associated data reviewed in accordance with our legal obligations. If you have reason to believe that a minor has registered with nanas44, please notify our support team immediately.

13. Changes to This Privacy Policy

nanas44 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or operational requirements. Material changes will be communicated to registered Players via email notification or prominent on-Platform notice at least fourteen (14) days prior to taking effect. The "Last Updated" date at the top of this policy will be revised accordingly. Continued use of the Platform after the effective date of any amended Privacy Policy constitutes acceptance of the revised terms. We encourage you to review this policy periodically.

14. Contact and Data Subject Requests

For all enquiries relating to this Privacy Policy, data subject rights requests, or concerns about the handling of your personal data by nanas44, please contact our support team via:

• Live chat: Available 24 hours a day, 7 days a week through the nanas44 Platform.
• Email: [email protected] — please include your registered account username and clearly describe the nature of your request.

nanas44 will acknowledge data subject rights requests within five (5) business days and provide a substantive response within thirty (30) calendar days. Where a request is complex or involves a large volume of data, this period may be extended by a further two months, in which case you will be notified of the extension and the reasons for it.

If you are not satisfied with nanas44's response to a privacy concern or data rights request, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.