Gen5 Privacy Policy – Personal Data Protection for Malaysian Players

This Privacy Policy ("Policy") is published by gen5 ("Platform", "we", "us") and governs how we manage the personal data of all users and members of the gen5 platform in Malaysia. We recognise that your trust is the foundation of our relationship, and protecting your personal data is not merely a legal obligation — it is a core principle that shapes how we operate every day.

This Policy applies to all information collected when you use the gen5 platform, register an account, make a deposit via Touch 'n Go eWallet, GrabPay, DuitNow, or other Malaysian payment methods, play games, contact our support team, or interact with any aspect of our services. By using the gen5 platform, you agree to the terms of this Privacy Policy.

Gen5 collects your personal data only when it is genuinely necessary to provide the services you use. We believe in the principle of data minimisation — we do not collect what we do not need.

• Registration Information: Your full name, Malaysian phone number, email address, and date of birth as provided when opening your gen5 account. This information is required to verify your identity and confirm that you meet the minimum age requirement of 18 years.
• Identity Verification Documents: A copy of your MyKad or passport may be requested during the KYC (Know Your Customer) process to comply with Malaysia's anti-money laundering (AML) regulations. These documents are stored in fully encrypted format.
• Financial Information: Deposit and withdrawal transaction records, including the payment method used — whether Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, or FPX. We do not store your full card number or sensitive bank account details — only encrypted tokens are retained for recurring transaction processing.
• Platform Activity Data: Records of games played, session duration, bet amounts, and winnings on the gen5 platform. This data is used for account management, fraud detection, and regulatory compliance.
• Technical Data: IP address, device type, web browser, operating system, and access log data. This information helps us enhance platform security and verify player identity.
• Communications: Records of your interactions with the gen5 support team via live chat, email at [email protected], or any other communication channel we provide.

Personal data collected by gen5 is used solely for the purposes stated below. We do not use your data for any other purpose without first obtaining your consent.

• Account Management: To create, verify, and manage your gen5 account, including the login process, security settings, and two-factor authentication (2FA).
• Transaction Processing: To process deposits via your chosen Malaysian payment method and manage the withdrawal of your winnings to your registered account.
• Legal Compliance: To fulfil our obligations under Malaysia's PDPA, AML regulations, KYC requirements, and any other applicable laws or regulations.
• Platform Security: To detect and prevent fraud, unauthorised access, system abuse, and any suspicious activity that may compromise the security of your account or the gen5 platform as a whole.
• Service Improvement: To understand how players use the gen5 platform, identify areas for improvement, and develop new features that better meet the needs of Malaysian players.
• Customer Support: To provide effective support when you contact the gen5 support team, including resolving technical issues, account inquiries, and complaints.
• Service Communications: To send you important account-related notices, terms updates, security information, and promotional communications that you have consented to receive.
• Responsible Gaming: To monitor playing patterns for the purpose of identifying players who may benefit from responsible gambling support, in line with gen5's commitment to player well-being.

Gen5 does not sell, rent, or share your personal data with third parties for marketing purposes. This is an unwavering commitment. In certain limited situations, we may need to share your information with the following parties:

• Payment Service Providers: The transaction information required is shared with payment processors such as e-wallet providers (Touch 'n Go, GrabPay, Boost, ShopeePay) and online banks (Maybank2u, CIMB Clicks via FPX) solely for the purpose of processing your transactions. All such providers are bound by strict confidentiality agreements.
• Regulatory Authorities: We may be required to disclose information to Malaysian government agencies, regulatory bodies, or law enforcement when mandated to do so by law, court order, or lawful official directive. gen5 discloses only the minimum information necessary in such circumstances.
• Technology Providers: Technology companies that assist us in operating gen5's technical infrastructure may have limited access to certain data solely for technical purposes. All such third parties are bound by comprehensive data protection agreements and are not permitted to use your data for any other purpose.
• Business Transfer: In the event that gen5 is involved in any merger, acquisition, or asset transfer, user data may be transferred as part of those assets. In such circumstances, you will be notified in advance and an equally strict or stricter privacy policy will continue to apply.

Gen5 implements a comprehensive range of technical and administrative security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction.

• End-to-End Encryption: All data transmitted between your device and gen5's servers is protected by 256-bit SSL/TLS encryption — the same security standard used by leading Malaysian banking institutions such as Maybank and CIMB. Data stored in our databases is also encrypted using industry-standard encryption algorithms.
• Secure Server Infrastructure: Your data is stored in data centres equipped with multiple layers of physical and digital protection, including enterprise-grade firewalls, intrusion detection systems, and continuous 24/7 monitoring.
• Internal Access Control: Access to player personal data within gen5 is strictly limited to staff who genuinely require it to perform their duties. All access is logged and audited on a regular basis.
• Financial Information Tokenisation: Sensitive payment information such as e-wallet account details is never stored directly. Instead, gen5's system uses encrypted tokens for processing recurring transactions, meaning your actual financial data is never stored in a readable format.
• Retention Period: Your personal data is retained for as long as your account remains active, and for the period required by Malaysian law following account closure (typically 7 years for financial records in accordance with LHDN requirements). Data that is no longer needed will be securely deleted or disposed of.
• Incident Response: gen5 has a structured security incident response procedure in place. Should a data breach occur that affects your information, we will notify you and the relevant authorities within the timeframe required by law.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you hold several important rights regarding your personal data held by gen5. We fully respect and facilitate the exercise of all these rights.

• Right of Access: You have the right to request and receive a copy of the personal data we hold about you. Requests can be submitted via [email protected] and will be processed within 21 business days.
• Right to Correction: If you find that the personal data we hold on record at gen5 is inaccurate, incomplete, or out of date, you have the right to request an immediate correction and we will update it as promptly as possible.
• Right to Erasure: Under certain circumstances, you have the right to request the deletion of your personal data. Please note that this right may be limited by legal obligations to retain certain records for periods prescribed under Malaysian regulations.
• Right to Object to Processing: You have the right to object to the processing of your personal data for specific purposes, including direct marketing. Such requests will be handled at no charge and without any conditions.
• Right to Withdraw Consent: Where the processing of your data is based on consent, you have the right to withdraw that consent at any time. Withdrawing consent does not affect the validity of any processing that took place prior to withdrawal.

To exercise any of the above rights, please contact the gen5 privacy team at [email protected] stating the right you wish to exercise and any relevant information. We will respond within 3 business days to acknowledge receipt of your request, and within 21 business days to resolve it.

Gen5 uses cookies and similar technologies to enhance your experience on the platform, ensure proper technical functionality, and understand how players use our services.

• Essential Cookies: Cookies required for the core functionality of the gen5 platform, including login session authentication, security, and remembering your account settings. These cookies cannot be disabled without affecting platform functionality.
• Analytics Cookies: We use internal analytics data to understand usage patterns on the gen5 platform — including the most frequently visited pages, average session duration, and user navigation paths. This data is used in aggregate form and does not identify individual users.
• Preference Cookies: Cookies that store your preferences — such as display language, display settings, and other options — to make your experience on the gen5 platform more convenient.
• Cookie Controls: You can manage or disable cookies through your web browser settings. Please note that disabling essential cookies may affect the functionality of the gen5 platform. gen5 does not use third-party cookies for advertising purposes.

The gen5 platform is strictly for individuals aged 18 and above. We do not knowingly collect or process personal data from anyone under the age of 18. Should we discover that we have inadvertently collected personal data from a minor, we will take immediate action to delete that data and close the associated account. If you believe a minor has registered an account on gen5, please contact us at [email protected] right away so we can take the appropriate action. gen5 employs an age verification system during the registration process and reserves the right to request proof of age at any time.

Gen5 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new technologies, legal requirements, or other relevant reasons. When we make material changes to this Policy, we will notify you via an in-platform notice on gen5 and/or by email to the address registered to your account. The "Updated" date at the top of this policy will be revised each time a change is made. Your continued use of the gen5 platform after changes are published constitutes your acceptance of the updated terms. It is your responsibility to review this Privacy Policy periodically. If you do not agree with any changes, you have the right to close your account and contact us to request the deletion of any personal data that is not required to be retained for legal purposes.

For any enquiries, concerns, or requests regarding this Privacy Policy or how gen5 manages your personal data, you may reach us through the following channels:

• Email: [email protected] — for formal privacy inquiries, complaints, or data subject rights requests. We will respond within 3 business days.
• Live Chat: Available 24/7 within the gen5 platform for urgent privacy inquiries or general questions about how we protect your data.
• Official Complaints: If you are dissatisfied with how gen5 has handled your privacy concern, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP), the regulatory body responsible for enforcing the PDPA in this country.