Shuffle Privacy Policy — Data Protection Your Privacy

Section 01

Introduction

Welcome to the shuffle Privacy Policy. At shuffle, we understand that your trust is our most valuable asset, and one of the ways we honour that trust is by being fully transparent about how your personal data is managed on our platform.

This Privacy Policy applies to all users who register, browse, or use any services offered through shuffle.vu and the shuffle mobile app. By using our platform, you agree to the collection and use of your information as described in this document.

We comply with Malaysia's Personal Data Protection Act 2010 (PDPA) and all applicable regulatory requirements. If at any time you have questions or concerns regarding privacy, our team is ready to assist you.

Section 02

Data We Collect

Shuffle collects various categories of personal data to ensure a safe, seamless, and personalised user experience. Below is a summary of the data we collect and its primary purposes:

Section 03

How We Collect Data

Shuffle collects your personal data through several different methods, depending on how you interact with our platform:

• Directly from you — during the account registration process, profile completion, KYC document submission, and interactions with our support team.
• Automatically — through cookies, server logs, and other tracking technologies as you browse and use the shuffle platform.
• From third parties — including identity verification service providers, payment providers, and fraud prevention agents we engage for security purposes.
• Via mobile app — when you download and use the shuffle app, additional data such as device information and general location may be collected with your consent.

In all situations, data collection is carried out transparently and on a valid legal basis, whether based on your consent, legitimate interest, or compliance with legal obligations.

Section 04

Purpose of Data Use

The personal data we collect is used solely for legitimate, predefined purposes. shuffle uses your data for the following:

• Creating and managing your user account and ensuring secure access to the platform.
• Conducting KYC identity verification to comply with anti-money laundering (AML) regulatory requirements.
• Processing deposits, withdrawals, and all financial transactions in your account securely and accurately.
• Providing effective and responsive customer support via live chat, email, and other channels.
• Detecting, investigating, and preventing fraudulent activity, money laundering, or security breaches.
• Personalising your gaming experience, including game recommendations and relevant promotional offers.
• Monitoring gaming habits for responsible gambling purposes and identifying users who may need assistance.
• Complying with all legal, regulatory, and reporting obligations applicable to our platform's operations.

Section 05

Data Sharing with Third Parties

Shuffle does not sell, rent, or disclose your personal data to third parties for marketing purposes without your explicit consent. However, in the course of operating the platform, we may share your data with the following categories of third parties under limited and controlled circumstances:

• Technical service providers — including cloud computing services, infrastructure providers, and software developers who help us operate the platform.
• Payment processors — financial institutions, payment gateways, and digital wallet providers that process your transactions.
• Identity verification agents — companies providing KYC and background check services for compliance purposes.
• Regulatory authorities — government agencies and regulatory bodies when required by law or court order.
• Companies in the group — shuffle-affiliated entities for integrated operations and shared services.

All third parties we engage are bound by strict data confidentiality agreements and are only permitted to process your data in accordance with shuffle's instructions.

Section 06

Data Storage & Security

The security of your personal data is shuffle's top priority. We implement multiple layers of technical and organisational security measures to protect your information from unauthorised access, loss, or misuse.

• All data is transmitted over secure connections using 256-bit SSL/TLS encryption.
• Sensitive data such as financial information is stored in encrypted databases with strict access controls.
• Our security monitoring system operates 24 hours a day to detect any threats or suspicious activity.
• Internal and external security audits are conducted periodically by qualified independent parties.
• Shuffle staff with access to personal data are bound by strict confidentiality obligations.

Data retention periods depend on the data category and legal requirements. Generally, active account data is retained for the duration of the account plus 7 years after closure to meet AML compliance and tax reporting requirements. Data that is no longer needed will be securely deleted or anonymised.

Section 07

Cookies & Tracking Technologies

Shuffle uses cookies and similar tracking technologies to enhance the user experience on our platform. Cookies are small text files stored on your device when you browse our website.

We use three main categories of cookies:

• Essential Cookies — required for core platform functions such as login authentication and session security. These cookies cannot be disabled.
• Performance Cookies — collects information about how you use the platform to help us improve our services.
• Functional Cookies — stores your preferences such as language and display settings to personalise your experience.

You can manage your cookie settings through your web browser settings. Please note that disabling certain cookies may affect the functionality and user experience of the shuffle platform.

Section 08

Your Rights as a User

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have certain rights regarding your personal data. shuffle fully respects and facilitates the exercise of these rights:

To exercise any of the above rights, please contact our privacy team by email at [email protected]. We will process your request within 30 days of receipt.

Section 09

Children's Data

The shuffle platform is intended solely for individuals aged 18 and above. We do not knowingly collect or process personal data from anyone under the age of 18.

Section 10

Privacy Policy Amendments

Shuffle reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our operations, legal requirements, or industry practices. Any material amendments will be communicated to you via your registered email or a prominent in-platform notification at least 7 days before the changes take effect.

The "Updated" date at the top of this page indicates when the latest version of this Privacy Policy was published. We encourage you to review this page periodically to stay informed about how we protect your information.

Your continued use of the shuffle platform after any amendments take effect will be considered your acceptance of the updated Privacy Policy.

Section 11

Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please do not hesitate to contact us through the following channels:

• Privacy Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 on the shuffle platform

Our privacy team will endeavour to respond to your enquiry within 3 business days and resolve any complaint within 30 days. If you are unsatisfied with our response, you have the right to lodge a complaint with the Malaysia Personal Data Protection Department.