Privacy Policy

1. Introduction

pasar123 ("We", "Us", "Our", "the Platform", "the Company") operates the online casino and sports betting platform accessible at https://pasar123.cam. We take the privacy and security of our Players' personal information seriously and are committed to handling it in accordance with applicable data protection laws and international best practices.

This Privacy Policy ("Policy") explains the types of personal data we collect from individuals who access or use the pasar123 Platform ("Player", "You", "Your"), the purposes for which we process it, the legal bases upon which processing is conducted, the parties with whom we may share it, and the rights you hold in respect of your personal data.

By registering an account on the Platform or by continuing to access the Platform after this Policy has been published or updated, you acknowledge that you have read and understood its contents. If you do not agree with any aspect of this Policy, you should cease using the Platform and contact us to request account closure.

2. Definitions

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, location data, and online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, pasar123.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a formal data processing agreement.
• "Sensitive Data" means Personal Data that by its nature requires enhanced protection, including financial information, identity documents, and data relating to health or gambling behaviour.
• "KYC Documents" means identity and address verification documents submitted by the Player as part of the Know Your Customer process.
• "Cookies" means small text files placed on a Player's device by the Platform for functional, analytical, and preference purposes.
• "Account" means the personal account registered by a Player on the pasar123 Platform.

3. Data We Collect

pasar123 collects only the Personal Data that is reasonably necessary for the purposes described in this Policy. The categories of data we collect are as follows:

3.1 Registration & Account Data

• Full legal name
• Date of birth (for age verification purposes)
• Gender
• Email address
• Malaysian mobile phone number
• Residential address (including city — e.g. Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam)
• Username and encrypted password
• Preferred language and currency (MYR)

3.2 Identity Verification (KYC) Data

• Copy of Malaysian MyKad, passport, or equivalent government-issued photo ID
• Proof of address documents (utility bills, bank statements issued within the past 3 months)
• Selfie or video verification where required for enhanced due diligence
• Source of funds declaration for high-value accounts

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction history, including amounts in MYR
• Payment method details (Touch 'n Go eWallet account reference, DuitNow ID, bank account name and last four digits, cryptocurrency wallet addresses)
• Account balance history and transaction timestamps
• Bonus and promotional credit history

3.4 Gaming & Betting Activity Data

• Game session logs including titles played, bet sizes, outcomes, and session duration
• Sports betting history including markets, selections, odds, and settlement results
• Responsible gambling tool usage (deposit limit settings, self-exclusion requests, cooling-off periods)

3.5 Technical & Device Data

• IP address and approximate geolocation at the time of login and transaction
• Device type, operating system, and browser type
• Session duration, pages visited, and click-path data
• Cookie identifiers and similar tracking technologies

3.6 Communications Data

• Content of live chat, WhatsApp, and email communications with our support team
• Feedback, complaints, and dispute correspondence
• Marketing preferences and opt-in/opt-out records

4. How We Collect Personal Data

pasar123 collects Personal Data through the following channels:

• Directly from you — when you register an account, complete KYC, make a deposit or withdrawal, contact support, or use any Platform feature that requires you to enter information.
• Automatically — through Cookies, server logs, and analytics tools as you browse and interact with the Platform.
• From third-party payment processors — when you use Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, or cryptocurrency networks to fund or withdraw from your account. These processors may share transaction confirmation data with us.
• From identity verification partners — where we use licensed third-party KYC service providers to validate the documents you submit.
• From fraud prevention databases — where we screen new registrations and high-value transactions against industry fraud and anti-money laundering databases.

5. Data Processing & Use

We use the Personal Data we collect for the following purposes:

6. Legal Basis for Processing

pasar123 processes Personal Data on the following legal bases:

• Contract performance — processing necessary to register your account, process transactions, and provide the services you have requested.
• Legal obligation — processing required to comply with anti-money laundering regulations, licensing conditions, age verification requirements, and applicable data protection law.
• Legitimate interests — processing for fraud prevention, platform security, service improvement, and responsible gambling monitoring, where these interests are not overridden by your data protection rights.
• Consent — processing for direct marketing communications, where you have provided explicit opt-in consent. You may withdraw this consent at any time by updating your communication preferences in your Account settings.

7. Data Sharing & Disclosure

pasar123 does not sell, rent, or trade your Personal Data to any third party for commercial purposes. We may share your Personal Data with the following categories of recipient only to the extent necessary for the stated purpose:

7.1 Payment Processors

We share transaction data with licensed payment service providers including e-wallet operators (Touch 'n Go eWallet, Boost, GrabPay), DuitNow, FPX-connected banks (Maybank, CIMB, Public Bank, Hong Leong), and cryptocurrency network operators. These parties receive only the minimum data necessary to execute and confirm your payment transaction.

7.2 KYC & Identity Verification Partners

KYC documents and biometric data submitted during verification are processed by licensed identity verification service providers acting as Data Processors under binding data processing agreements. These providers are prohibited from using your data for any purpose other than the verification service.

7.3 Fraud Prevention & AML Services

We may share relevant Personal Data with industry fraud prevention consortiums and anti-money laundering screening services to protect the Platform and its Players from financial crime.

7.4 Regulatory & Law Enforcement Authorities

We may disclose Personal Data to regulatory bodies, licensing authorities, tax authorities, or law enforcement agencies where we are legally obliged to do so or where disclosure is necessary to prevent or investigate serious crime.

7.5 Group Companies & Successors

In the event of a merger, acquisition, or sale of the Platform, your Personal Data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

8. Data Retention

We retain Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account registration data: Retained for the duration of the active account plus 5 years following account closure, in accordance with AML record-keeping requirements.
• KYC documents: Retained for a minimum of 5 years from the date of verification or account closure, whichever is later.
• Transaction and financial records: Retained for 7 years to comply with financial record-keeping obligations.
• Gaming session logs: Retained for 2 years from the date of each session, or longer where required for dispute resolution or regulatory purposes.
• Customer communications: Retained for 3 years from the date of the last communication, or longer where related to an ongoing dispute.
• Marketing consent records: Retained for the duration of the consent period plus 3 years following withdrawal of consent.

On expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that makes re-identification impossible.

9. Data Security

pasar123 implements robust technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption applied to all data transmitted between your device and the Platform
• End-to-end encryption for all payment transactions, including MYR bank transfers and cryptocurrency transactions
• Two-factor authentication (2FA) available to all Players and mandatory for all staff accounts
• Access controls limiting internal access to Personal Data strictly to authorised personnel with a documented business need
• Regular penetration testing and vulnerability assessments conducted by independent security professionals
• Encrypted storage of all KYC documents and financial records
• Real-time intrusion detection and 24/7 security monitoring

While we take all reasonable precautions to safeguard your Personal Data, no data transmission over the internet can be guaranteed to be completely secure. Players are encouraged to use strong, unique passwords and to enable 2FA on their Accounts.

10. Cookies & Tracking Technologies

pasar123 uses Cookies and similar tracking technologies to provide a functional, personalised, and secure experience on the Platform. The categories of Cookies we use are as follows:

10.1 Strictly Necessary Cookies

These Cookies are essential for the Platform to function. They enable core features such as secure login session management, fraud prevention checks, and maintaining your account state during a session. They cannot be disabled without impairing the Platform's core functionality.

10.2 Functional Cookies

These Cookies remember your preferences, such as your preferred language, display settings, and whether you have acknowledged our Terms & Conditions. They improve your experience by reducing the need to re-enter information on repeat visits.

10.3 Analytical Cookies

We use anonymised analytical Cookies to understand how Players interact with the Platform — which pages are visited most, where drop-offs occur, and which features generate the most engagement. This data is used solely to improve Platform performance and user experience. Analytical Cookies do not identify you personally.

10.4 Managing Cookies

You may adjust your Cookie preferences at any time through your browser settings. Please note that disabling Cookies may affect the functionality of the Platform. Strictly necessary Cookies cannot be disabled through browser settings as they are essential to the Platform's security and integrity.

11. Your Rights

Subject to applicable data protection law, you hold the following rights in respect of your Personal Data held by pasar123:

• Right of Access: You may request a copy of the Personal Data we hold about you, including the purposes for which it is processed and the recipients with whom it has been shared.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data we hold about you. Basic account details can be updated directly within your Account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and no other legal basis applies. Please note that this right is subject to our legal obligations to retain certain data under AML and financial record-keeping regulations.
• Right to Restrict Processing: You may request that we restrict processing of your data in certain circumstances, such as while the accuracy of the data is being contested.
• Right to Data Portability: You may request a copy of your Personal Data in a structured, commonly used, machine-readable format to facilitate transfer to another data controller.
• Right to Object: You may object to processing based on legitimate interests at any time. You also have an unconditional right to object to processing of your data for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact our support team via live chat or by email at [email protected]. We will respond to all valid requests within 30 calendar days. In cases of particular complexity, this period may be extended by a further 60 days with notification.

12. International Data Transfers

In operating a global online platform, it may be necessary for pasar123 to transfer your Personal Data to countries outside Malaysia for processing by our service providers, including KYC verification partners, payment processors, and cloud infrastructure providers. In all such cases, we ensure that:

• Transfers are made only to countries or organisations that provide an adequate level of data protection, as recognised by applicable law.
• Where adequacy decisions do not apply, transfers are safeguarded by appropriate contractual protections, including standard contractual clauses or binding corporate rules.
• All recipient Data Processors are bound by contractual obligations to process your data solely in accordance with our instructions and this Policy.

13. Protection of Minors

pasar123 is strictly an adult platform. Our services are available exclusively to individuals who are 21 years of age or older. We do not knowingly collect Personal Data from individuals under the age of 21.

Age verification is conducted during the account registration process and enforced again prior to the first withdrawal. Where we discover that Personal Data has been collected from a minor, we will immediately suspend the relevant account, delete the data, and return any deposited funds to the payment method used. If you believe a minor has registered an account on the Platform, please notify us immediately at [email protected].

14. Policy Amendments

pasar123 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. Material changes — those that affect your rights or our core processing activities — will be communicated to registered Players via email notification at least 14 days before the changes take effect.

The effective date at the top of this page will be updated whenever the Policy is revised. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to an amendment, you should cease using the Platform and contact us to request account closure and deletion of your data where permissible.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way pasar123 handles your Personal Data, please contact our Data Protection team through the following channels:

• Live Chat: Available 24/7 on the Platform — average initial response time 3–5 minutes
• WhatsApp: Available 24/7 in English, Bahasa Melayu, and Chinese
• Email: [email protected] — for data protection enquiries, please include "Privacy Request" in your subject line

All data subject rights requests and privacy-related complaints will be acknowledged within 5 business days and resolved within the timeframes required by applicable law.