Fortune111 Privacy Policy –
Malaysian Member Data Protection

Fortune111 collects various types of information to ensure the platform operates smoothly, meets legal requirements, and delivers a personalised experience to every member. The data collected can be grouped into the following categories:

All information you provide to Fortune111 must be accurate and up to date. It is your responsibility to update your account details whenever changes occur — particularly your phone number and payment method — to ensure all transactions proceed smoothly.

Fortune111 collects members' personal data through several key channels:

• Account Registration — When you complete the Fortune111 registration form with your Malaysian phone number, name, and other required details, that information is collected and stored securely.
• Financial Transactions — When you make a deposit via Touch 'n Go eWallet, GrabPay, DuitNow, Boost, ShopeePay, FPX, Maybank2u, or CIMB Clicks, the relevant transaction information is recorded for account and financial compliance purposes.
• Platform usage — Every interaction you have on the Fortune111 platform — from betting on Malaysia Super League football, IPL cricket, BWF badminton, e-sports, live casino, slots, to roulette — is automatically tracked for platform operations, security, and VIP Rewards programme purposes.
• Customer Support Communications — If you contact the Fortune111 support team via live chat or email, the content of that communication may be recorded for training and service quality improvement purposes.
• Cookies and tracking technologies — As described in Section 6, Fortune111 uses cookies and similar technologies to enhance the user experience and collect anonymised analytics data on platform usage.
• Third-party verification (KYC) — In certain cases, Fortune111 may use third-party identity verification services to confirm a member's identity in order to fulfil anti-money laundering (AML) requirements.

Fortune111 does not collect personal data from external sources without your knowledge, except in the context of identity verification and fraud prevention as required by law.

Fortune111 uses members' personal data solely for the following legitimate and transparent purposes:

• Account Management — To create and maintain your Fortune111 account, process logins, and ensure account security through two-factor authentication.
• Financial transaction processing — Processing deposits in Malaysian Ringgit (MYR) via your chosen Malaysian payment method, and processing winnings withdrawals to your registered account.
• Legal and regulatory compliance — Complying with applicable legal requirements, including anti-money laundering (AML) regulations, age and identity verification (KYC), and reporting obligations mandated by the relevant authorities.
• Fraud Prevention & Security — Detecting and preventing suspicious activity, unauthorised access, and violations of Fortune111's Terms & Conditions.
• Platform improvements — Analysing usage data (in anonymised or aggregated form) to understand how members use the Fortune111 platform and to make relevant improvements.
• Service communications — Sending account-related notices, transaction confirmations, Terms & Conditions updates, and important technical information via SMS or email to your registered phone number and email address.
• VIP Rewards Program — Calculating and managing VIP points based on your betting activity on Fortune111, and determining eligibility and benefits according to your VIP tier.

Fortune111 does not use your personal data for any purposes not stated in this policy without first obtaining your additional consent.

Fortune111 may share members' personal data with selected third parties in the following limited and controlled circumstances:

• Payment service providers — To process deposit and withdrawal transactions, the necessary information is shared with relevant Malaysian payment service providers such as Touch 'n Go, GrabPay, DuitNow, Boost, ShopeePay, and banking institutions (Maybank, CIMB). These providers are governed by their own privacy policies and security standards.
• Game & Technology Providers — Providers of live casino, slots, and virtual sports game software who supply content to the Fortune111 platform may receive the minimum technical data required to operate the games properly. Any data shared is strictly limited to technical necessities.
• Identity verification services (KYC) — To meet legal requirements, Fortune111 may engage recognised third-party providers to verify members' identity documents. These providers are bound by strict confidentiality agreements.
• Legal Authorities — Fortune111 will disclose personal data to government authorities, law enforcement bodies, or courts when required by law or a valid court order. This includes obligations under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (Malaysia).

The security of your personal data is Fortune111's top priority. The following are the security measures we have in place:

• 256-bit SSL Encryption — All data transmitted between your device and Fortune111's servers is encrypted using 256-bit TLS/SSL protocols — the same standard used by Malaysia's leading banking institutions such as Maybank and CIMB.
• Secure Password Storage — Fortune111 account passwords are never stored in plain text. We use strong hashing algorithms with salting to ensure passwords cannot be recovered — even by Fortune111 staff.
• Two-factor authentication (2FA) — Fortune111 encourages and supports the use of two-factor authentication via OTP sent to your registered Malaysian phone number as an added layer of security.
• Regular Security Audits — Fortune111's systems undergo regular penetration testing and independent security audits to identify and address any vulnerabilities before they can be exploited.
• Internal access controls — Access to members' personal data within Fortune111 is restricted to staff with a legitimate need only, in accordance with the minimum need-to-know principle.

Data retention period: Fortune111 retains members' personal data for as long as the account is active, and for the minimum period prescribed by law following account closure — typically between 5 and 7 years for financial records, in accordance with applicable Malaysian legal requirements. Data that is no longer needed will be disposed of securely.

The Fortune111 platform uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions correctly. The types of cookies used are as follows:

• Session cookies — Temporary cookies that are cleared when you close your browser. Used to maintain your logged-in status during an active Fortune111 session and ensure your betting slips are saved correctly.
• Preference Cookies — Persistent cookies that remember your preferences such as favourite sports, language settings, and display layout, so you don't have to reconfigure them every time you log in to Fortune111.
• Security Cookies — Used to detect suspicious activity, verify session identity, and protect your account against attacks such as CSRF (Cross-Site Request Forgery).
• Analytics cookies — Fortune111 uses aggregated, anonymised analytics data to understand how members interact with the platform — which pages are visited most, how much time is spent in the Sports Betting or casino sections, and so on. This data is used solely for platform improvement.

You can manage or block cookies through your browser settings. However, blocking certain cookies may affect the functionality of the Fortune111 platform — for example, you may need to log in again each time, or bet slips may not work correctly. For the best experience on Fortune111, we recommend keeping cookies enabled.

As a Fortune111 member and data subject, you have the following rights regarding your personal data, subject to applicable Malaysian law:

• Right to Access — You have the right to request a copy of the personal data Fortune111 holds about you. This request can be made through Fortune111 customer support.
• Right to Rectification — If the data we hold is inaccurate or out of date, you have the right to request a correction. You can also update most profile information directly in your Fortune111 account settings.
• Right to erasure — In certain circumstances, you may request that Fortune111 delete your personal data. However, this right is limited by Fortune111's legal obligation to retain specific records (particularly financial records) for periods prescribed under Malaysian law.
• Right to object to processing — You have the right to object to the processing of your personal data for direct marketing purposes at any time. Contact Fortune111 customer support to submit such an objection.
• Right to Data Portability — You have the right to request the personal data you have provided to Fortune111 in a machine-readable format for the purpose of transferring it to another data controller.

To exercise any of the above rights, contact the Fortune111 customer support team via live chat or email at support@fortune111.xyz. We will process your request within a reasonable timeframe and inform you of the outcome.

The Fortune111 platform is intended for adults aged 18 and above only. Fortune111 does not knowingly collect or process personal data of individuals under the age of 18.

If Fortune111 discovers or is informed that personal data of a minor has been collected without parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe a child under your care has registered a Fortune111 account, please contact our customer support immediately at support@fortune111.xyz for prompt remedial action.

In operating the Fortune111 platform, members' personal data may be processed on servers located outside Malaysia — including for backup purposes, cloud storage, or the use of global technology service providers that support platform operations.

In all such cases, Fortune111 ensures that data transfers are carried out with adequate safeguards, including data processing agreements that require third-party providers to meet security and privacy standards equal to or higher than those applicable in Malaysia. Fortune111 will not transfer members' personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate protective mechanisms.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way Fortune111 handles your personal data, we welcome you to reach us through the following channels:

• Live Chat — The fastest way to get an immediate response. Accessible directly from the Fortune111 platform — response times are typically under 5 minutes, 24 hours a day, 7 days a week.
• Privacy Email — support@fortune111.xyz — Include "Privacy Enquiry" in your email subject line to speed up processing. We will respond within 3 business days.

Fortune111 is committed to addressing all privacy concerns seriously, transparently, and within a reasonable timeframe. If you are not satisfied with our response, you have the right to file a complaint with the relevant data protection authority in Malaysia.

This Privacy Policy is subject to periodic review and updates to reflect changes in our data practices, legal requirements, or platform needs. The date of the latest update is shown at the top of this document. Continued use of the Fortune111 platform following any changes to this Privacy Policy will be considered acceptance of the updated terms.