Privacy Policy scru2 – Data Protection & Malaysian User Privacy

1 Introduction & Scope

This Privacy Policy is published by scru2 ("us", "Platform", "scru2") and applies to all users who access or use the scru2 online gaming platform, including the main website, mobile app, and all related services.

We understand that privacy is more than a legal obligation — it is the trust you place in us every time you share personal information. We take that trust seriously. This policy clearly outlines:

• What personal data we collect and why.
• How we use, store, and protect that data.
• Who your data may be shared with under very limited circumstances.
• What your rights are as a data subject and how to exercise them.

This policy should be read alongside Terms and Conditions scru2 and constitutes the entire privacy agreement between you and our platform. In the event of any inconsistency, this Privacy Policy shall take precedence for all matters relating to personal data.

2 Data We Collect

Scru2 collects several categories of personal data depending on the context of platform use. The table below provides a clear overview:

Scru2 not collect sensitive information such as biometric data, medical records, or religious information unless explicitly required by applicable law.

3 How We Collect Data

Your personal data is collected through the following methods when you interact with the scru2 platform:

• Account Registration: Information you provide directly when registering a new account, including your name, email, and phone number.
• KYC Verification: Identity documents you upload for identity verification purposes prior to your first withdrawal or when requested by the compliance team.
• Financial Transactions: Information collected automatically when you make a deposit or withdrawal through any of the supported payment methods.
• Platform Usage: Technical and behavioural data collected automatically via cookies, server logs, and similar tracking technologies.
• Communications with Support: Information you share when contacting our customer support team via live chat or email.
• Promotional Participation: Data you provide when participating in campaigns, contests, or loyalty programmes on the scru2 platform.

4 Purpose of Data Use

Scru2 uses collected personal data solely for legitimate and stated purposes. We do not process your data for any other purpose without a clear legal basis. The following are the primary purposes for which your data is used:

• Account Management: Create, maintain, and manage your account on the scru2 platform, including identity verification and login security.
• Transaction Processing: Process deposits, withdrawals, and all financial transactions accurately and securely.
• Legal Compliance: Fulfil obligations under PDPA 2010, anti-money laundering (AML) requirements, and directives from relevant regulatory authorities.
• Platform Security: Detect, investigate, and prevent fraud, illegal activity, and cybersecurity threats against the platform and its users.
• Service Improvements: Analyse usage patterns to improve platform functionality, user experience, and the games catalogue.
• Service Communications: Send you important notices relating to your account, policy changes, or security information.
• Marketing (with consent): Send you promotions, bonus offers, and gaming-related content — only if you have consented to receive them, and you may withdraw consent at any time.

5 Data Sharing with Third Parties

Scru2 does not sell your personal data. However, in very limited circumstances and strictly on a need-to-know basis, we may share your information with the following parties:

• Payment Providers: Required transaction details are shared with licensed payment providers such as FPX, DuitNow, and approved digital wallet providers to process your financial transactions.
• Game Providers: Minimal technical data required to enable smooth gameplay from third-party game software providers integrated with our platform.
• Technical Service Providers: Cloud infrastructure, cybersecurity, and technical support companies that help operate our platform — all bound by strict confidentiality agreements.
• Legal Requirements: Law enforcement agencies or regulatory authorities when we are required to do so by court order, applicable law, or to protect the legitimate rights of scru2 and its users.

All third parties that receive scru2 user data are bound by strict data processing agreements and are not permitted to use that data for any purpose other than what is specified in those agreements.

6 Data Security

Protecting your data is a core technical and operational priority at scru2. We implement multiple layers of protection to keep your data secure at all times:

• 256-bit SSL Encryption: All communications between your device and scru2 servers are encrypted using the latest TLS protocol.
• Strict Access Controls: Only authorised staff who require access to specific data to perform their duties are permitted to do so. All access is logged and monitored.
• 24/7 Monitoring: Our automated monitoring system detects unusual activity and security threats around the clock with rapid incident response.
• Regular Backups: Data is regularly backed up to a secure, separate location to ensure service continuity and data recovery in the event of an incident.
• Penetration Testing: scru2 conducts regular security testing by independent parties to identify and address any vulnerabilities before they can be exploited.

7 Cookies & Tracking Technologies

Scru2 uses cookies and similar tracking technologies to enhance your experience on our platform. The following are the types of cookies we use:

• Essential Cookies: Required for core platform operations such as login session verification and security. These cookies cannot be disabled without affecting platform functionality.
• Preference Cookies: Store your preferences such as language, theme, and display settings for a more personalised experience.
• Analytics Cookies: Helps us understand how users interact with the platform for continuous improvement. Data collected is aggregated and does not directly identify individuals.
• Security Cookies: Used to detect and prevent fraudulent activity, cyberattacks, and suspicious account usage.

You can manage your cookie preferences through your web browser settings. Please note that disabling certain cookies may affect the functionality and user experience of the scru2 platform.

8 Your Rights as a User

As a scru2 platform user and data subject under PDPA 2010, you have the following rights regarding your personal data:

To exercise any of the above rights, please contact our Privacy Officer by email [email protected]. We will process your request within 30 days from the date of receipt.

9 Data Retention & Deletion

Scru2 retains your personal data only for as long as necessary to fulfil the purposes stated in this policy or as required by applicable law. Our general retention guidelines are as follows:

• Active Account Data: Retained for the duration your account is active and for the required period following account closure in accordance with legal compliance requirements.
• Financial Transaction Records: Retained for a minimum of 7 years in compliance with Malaysia's financial and anti-money laundering legal requirements.
• KYC Data: Retained for the period specified by the relevant regulatory body, generally no less than 5 years from the date of verification.
• Activity Logs: Retained for a maximum of 2 years for security and internal audit purposes.
• Marketing Data: Retained until you withdraw consent or request deletion, whichever comes first.

Once the retention period expires, data is securely deleted using methods that ensure it cannot be recovered. For data stored in physical format, secure destruction procedures are followed.

10 Third-Party Links & Services

The scru2 platform may contain links to third-party websites or services such as game providers or payment partners. Please note that:

• Scru2 has no control over the privacy practices of those third-party websites or services.
• This Privacy Policy applies only to data processed directly by scru2.
• We encourage you to read the privacy policy of any third-party websites or services you access through our platform.
• Scru2 is not responsible for any damage or loss arising from data exposure on third-party websites that you access voluntarily.

11 Changes to This Privacy Policy

Scru2 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service improvements. When we make significant changes:

• Notice will be sent to your registered email address at least 14 days before the changes take effect.
• In-platform notices will be displayed to all logged-in users for an appropriate period.
• The "Updated" date at the top of this document will be revised to reflect the latest amendment.

Continued use of the scru2 platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you disagree with the changes made, please stop using the platform and contact us to close your account.

12 Contact Our Privacy Officer

If you have any questions, concerns, or wish to exercise your rights regarding your personal data, please contact the scru2 Privacy Officer through the following channels:

• Privacy Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat icon on the scru2 platform.
• FAQ Page: Visit FAQ page for frequently asked questions related to privacy and your account.

We are committed to responding to all privacy-related enquiries within 5 business days. For more complex data rights requests, we will notify you if additional time is needed, but no longer than 30 days.