Privacy Policy

This Privacy Policy ("Policy") describes how Pavalion88 ("the Company", "We", "Us", "Our") collects, processes, stores, and protects personal data provided by or collected from individuals ("Player", "User", "You") who access or use the Pavalion88 online gaming platform at pavalion88.cam and all associated services (the "Platform").

Pavalion88 takes data privacy seriously. We operate the Platform primarily for players based in Malaysia, and our data practices reflect the requirements of applicable personal data protection legislation as well as the responsible handling standards expected of a regulated gaming operator. All financial transactions on the Platform are conducted in Malaysian Ringgit (MYR).

By registering an account, making a deposit, or using any feature of the Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with the terms of this Policy, you must not register an account or continue to use the Platform.

For the purposes of this Policy, the following terms shall have the meanings set out below:

Pavalion88 collects personal data that is necessary for the provision of its services, the fulfilment of regulatory obligations, and the improvement of the player experience. The categories of data we collect are described in the table below:

We collect personal data through the following means:

• Direct Provision: Data you submit when creating an account, completing KYC verification, making deposits or withdrawals, or contacting our customer support team.
• Automated Collection: Technical and usage data collected automatically via server logs, cookies, and similar tracking technologies when you access or interact with the Platform.
• Third-Party Sources: Identity verification data from KYC and anti-fraud service providers; payment confirmation data from payment processors such as FPX, DuitNow, and e-wallet providers.
• Publicly Available Sources: In limited circumstances, data from public registers or open-source fraud prevention databases where required for compliance purposes.

Pavalion88 processes personal data for the following clearly defined purposes:

1. Account Creation and Management: To register your account, authenticate your identity, manage your profile, and administer your player relationship with the Company.
2. Service Delivery: To enable you to access games, place bets on EPL, Liga Super Malaysia, and other markets, manage your MYR balance, and use all Platform features.
3. Payment Processing: To process deposits via Maybank, CIMB, Public Bank, Hong Leong Bank, DuitNow, FPX, Touch 'n Go eWallet, Boost, and GrabPay, and to process approved withdrawal requests to your registered payment method.
4. Regulatory Compliance and KYC: To verify your identity and age (21+ requirement), satisfy anti-money laundering obligations, and fulfil reporting requirements under applicable law.
5. Fraud Detection and Prevention: To detect and prevent fraudulent activity, duplicate accounts, bonus abuse, and other prohibited conduct.
6. Responsible Gambling: To monitor gameplay patterns for indicators of problem gambling, enforce self-exclusion and deposit limit settings, and provide safeguarding measures as required.
7. Customer Support: To respond to enquiries, resolve complaints, and maintain communication records for quality assurance and dispute resolution.
8. Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — subject to your marketing preferences and opt-in consent where required.
9. Platform Improvement: To analyse aggregate usage data, identify technical issues, and improve the overall player experience on the Platform.
10. Security: To protect the integrity of the Platform, prevent unauthorised access, and maintain records for audit purposes.

Pavalion88 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations to you under the Terms & Conditions — including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations and age verification requirements.
• Legitimate Interests: Processing necessary for the Company's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your fundamental rights.
• Consent: Processing for marketing communications, where we rely on your explicit opt-in consent. You may withdraw consent at any time by updating your communication preferences in account settings or contacting our support team.

Pavalion88 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Service Providers: We share financial data with payment processors (including FPX network banks, e-wallet operators, and DuitNow) to process your transactions. These providers are contractually bound to process data solely for payment purposes.
• Identity Verification Services: We engage third-party KYC and AML compliance providers to verify identity documents and screen against watchlists. Data shared is limited to what is necessary for verification.
• Cloud Infrastructure and Hosting: Platform data is hosted on enterprise-grade infrastructure. Our infrastructure partners are bound by data processing agreements that prohibit independent use of data.
• Customer Communication Tools: We use professional-grade live chat and email support platforms. Support communications may be processed by these tools' infrastructure under data processor agreements.
• Legal and Regulatory Authorities: We will disclose personal data to law enforcement agencies, regulators, or courts when required to do so by law, court order, or where we reasonably believe disclosure is necessary to prevent harm or investigate illegal conduct.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of the Company's business, personal data may be transferred to the acquiring entity subject to equivalent privacy protections.

Pavalion88 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit a website. They allow the Platform to recognise your session, remember your preferences, and collect aggregate analytical data.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function, including session authentication, security tokens, and login state management. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings and display options to improve your experience across sessions.
• Analytical Cookies: Collect aggregated, anonymised data about how players interact with the Platform — including page visits and session durations — to help us identify areas for improvement.
• Security Cookies: Used to detect fraudulent behaviour, bot activity, and unauthorised account access attempts.

You may configure your browser to block or delete cookies; however, doing so may affect the functionality of certain Platform features, including maintaining an active login session. Your continued use of the Platform following our cookie notice constitutes acceptance of strictly necessary and functional cookies.

Pavalion88 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The general retention periods applied are as follows:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with industry-standard data destruction protocols.

Pavalion88 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the Pavalion88 Platform is encrypted in transit using industry-standard Transport Layer Security protocols.
• Encryption at Rest: Sensitive personal data including identity documents and financial records is encrypted in storage using AES-256 encryption.
• Two-Factor Authentication (2FA): Available for all player accounts to add an additional layer of identity verification at login.
• Access Controls: Personal data is accessible only to authorised Company personnel who require it for their specific role. Access is logged, audited, and governed by the principle of least privilege.
• Regular Security Audits: The Platform undergoes periodic security assessments and penetration testing by qualified third-party security professionals.
• Incident Response: In the event of a confirmed data breach that poses a risk to affected individuals, Pavalion88 will notify impacted players and relevant authorities within the timeframes required by applicable law.

Subject to applicable data protection legislation and any overriding legal obligations the Company is subject to, you hold the following rights in respect of your personal data:

To exercise any of the above rights, please contact our Data Privacy team using the contact details in Section 15 of this Policy. We will acknowledge your request within a reasonable period and respond substantively within 30 days. Where a request is complex or high in volume, this period may be extended by a further 30 days with advance notice to you.

We may be required to verify your identity before processing certain requests in order to protect against unauthorised data access.

Pavalion88 operates exclusively for adults aged 21 years and above. We enforce this requirement strictly through our registration process and KYC verification procedures. We do not knowingly collect, store, or process personal data relating to individuals under the age of 21.

If we have reason to believe that personal data has been collected from a minor — whether through misrepresentation of age at registration or otherwise — we will immediately:

1. Suspend or close the associated account;
2. Void all gameplay activity associated with the account;
3. Delete all personal data associated with the minor to the extent not required to be retained for regulatory reporting; and
4. Where appropriate, report the matter to relevant authorities.

Parents and guardians who believe their child has registered on this Platform should contact our support team immediately using the details in Section 15.

In the course of operating the Platform and engaging third-party service providers, personal data may be transferred to and processed in jurisdictions outside Malaysia. Where such transfers occur, Pavalion88 ensures that appropriate safeguards are in place to protect the transferred data, including:

• Standard contractual clauses requiring the recipient to process data to an equivalent standard of protection;
• Ensuring that any data processor engaged in a third country maintains appropriate technical and organisational security measures; and
• Limiting the scope of data transferred to the minimum necessary for the stated purpose.

By using the Platform, you acknowledge that your personal data may be transferred in accordance with this section and the safeguards described herein.

Pavalion88 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform functionality. When material changes are made, we will update the "Last Updated" date at the top of this document and, where reasonably practicable, notify registered players via email or in-Platform notice.

We encourage you to review this Policy periodically. Your continued use of the Platform following the publication of a revised Privacy Policy constitutes your acknowledgement of the changes. If you have material objections to any amendments, you may exercise your right to close your account as set out in the Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Pavalion88, please contact us using the details below. All privacy-related enquiries are handled by our dedicated support and compliance team.

When submitting a privacy request, please include your registered account details, a clear description of your enquiry or the right you wish to exercise, and any supporting information. We will acknowledge receipt of your request promptly and provide a substantive response within 30 days.

We serve players across Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and all other parts of Malaysia. Regardless of your location within Malaysia, your privacy rights are handled with the same standard of care.

© 2026 Pavalion88. All rights reserved. This Privacy Policy was last updated on 1 January 2026. For players aged 21 and above only.