Privacy Policy
— Triton77

1. Introduction

This Privacy Policy ("Policy") is published by Triton77 ("the Company", "we", "us", "our") and applies to all personal data processed in connection with your use of the Triton77 platform, accessible at triton77.cam and all associated domains, mobile interfaces, and Services (collectively, "the Platform").

Triton77 operates as an internationally licensed online casino and sports betting platform, primarily serving players in Malaysia including those based in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and beyond. In the course of providing our Services — including account registration, identity verification, payment processing, gameplay, customer support, and promotional communications — we necessarily collect and process certain personal data about you.

This Policy describes:

• the categories of personal data we collect;
• the purposes for which we process that data;
• the legal bases underpinning our data processing activities;
• the parties with whom we may share your data;
• how long we retain personal data;
• the rights you hold in respect of your personal data; and
• how to exercise those rights or submit a complaint.

By registering an account on the Platform or otherwise interacting with our Services, you acknowledge that you have read and understood this Policy. If you do not accept the terms of this Policy, you should not use the Platform.

2. Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" — any information that identifies or could reasonably identify a living individual, either alone or in combination with other data.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Subject" — the individual to whom the personal data relates; in the context of this Platform, this means the Player.
• "Controller" — the entity that determines the purposes and means of processing personal data; Triton77 acts as the Data Controller for the personal data it collects from Players.
• "Processor" — a third party that processes personal data on behalf of the Controller pursuant to a data processing agreement.
• "KYC Data" — identity verification documentation including government-issued ID, proof of address, and payment method verification materials collected under the Know Your Customer process.
• "Cookies" — small data files stored on your device by a web browser at the request of a website, used to maintain session state, preferences, and analytical data.
• "Third Party" — any entity other than Triton77 and the Player.

3. Data We Collect

Triton77 collects personal data in several categories, described below.

3.1 Registration Data

When you create an account, we collect:

3.2 KYC Verification Data

To process withdrawals and comply with licensing obligations, we collect:

3.3 Financial Data

We collect transactional data relating to deposits and withdrawals. This includes payment method type (Maybank2u, CIMB Clicks, DuitNow, Touch 'n Go eWallet, FPX, Boost, GrabPay, USDT wallet address, BTC wallet address, etc.), transaction reference numbers, amounts, and timestamps. We do not store full bank account numbers or card numbers — these are processed and tokenised by our third-party payment service providers.

3.4 Gameplay & Betting Data

3.5 Technical & Usage Data

3.6 Communications Data

Records of support conversations via live chat or email, including correspondence content, timestamps, and resolution outcomes, are retained for quality assurance and dispute resolution purposes.

4. How We Collect Data

We collect personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotional activities;
• Automatically — via cookies, web beacons, and server logs when you access or use the Platform;
• From third parties — including KYC verification service providers, payment processors, fraud prevention systems, and analytics providers, to the extent permitted by applicable law and necessary for Platform operations;
• From publicly available sources — where permitted for identity verification or compliance screening purposes (e.g., sanctions list checks).

5. Purposes of Processing

The table below sets out the primary purposes for which Triton77 processes personal data and the corresponding lawful basis for each purpose.

6. Legal Basis for Processing

6.1 Contract Performance

The majority of data processing at Triton77 is necessary for the performance of our contract with you as a Player — i.e., to operate your account, process deposits and withdrawals, and provide access to casino games and sports betting markets. Without this processing, we cannot deliver the Services to you.

6.2 Legal Obligation

Our international gaming licence imposes mandatory obligations on us regarding KYC verification, AML monitoring, responsible gambling compliance, and record-keeping. Processing personal data for these purposes is required by law and is not optional for either party.

6.3 Legitimate Interests

We process certain data under our legitimate interests in maintaining the security, integrity, and operational effectiveness of the Platform — including fraud detection, abuse prevention, and internal analytics. Where we rely on legitimate interests, we have assessed that those interests are not outweighed by your rights and freedoms.

6.4 Consent

Where we rely on consent as a legal basis — for example, for sending promotional emails or depositing non-essential cookies — we will obtain your explicit, freely given consent before processing. You may withdraw consent at any time without affecting the lawfulness of prior processing. Consent withdrawal does not affect your account access.

7. Data Sharing & Disclosure

Triton77 does not sell your personal data. We share personal data with third parties only in the following circumstances:

7.1 Service Providers (Processors)

We engage the following categories of third-party service providers who process data on our behalf under contractual data processing agreements:

• KYC / Identity Verification Providers: process identity documents and perform liveness checks to fulfil our licensing obligations;
• Payment Service Providers: process deposit and withdrawal transactions via DuitNow, FPX, Touch 'n Go eWallet, Maybank, CIMB, GrabPay, Boost, and cryptocurrency channels;
• Game Studio Partners: licensed international game studios receive pseudonymised gameplay session data necessary to deliver game outcomes and maintain RNG integrity;
• Customer Support Platforms: host and manage live chat and email support ticket systems;
• Analytics & Monitoring Tools: process aggregated usage and performance data to support platform maintenance and improvement.

7.2 Regulatory & Legal Disclosure

We may disclose personal data to licensing authorities, law enforcement agencies, financial intelligence units, or courts where required to do so by applicable law, by our licensing conditions, or in response to a valid legal process (court order, subpoena, or equivalent). We will, where legally permissible, notify affected players of such disclosures.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the Company's business, personal data may be transferred to the successor entity as part of that transaction, subject to equivalent data protection obligations being imposed on the acquirer.

8. International Data Transfers

Given that Triton77 operates under international licensing and uses globally distributed service providers, your personal data may be transferred to and processed in countries outside Malaysia. These include countries in which our technology infrastructure, KYC providers, and payment processors are hosted.

Where such transfers occur, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) or equivalent data transfer mechanisms as required by applicable data protection frameworks;
• Contractual obligations requiring third-party recipients to apply data protection standards equivalent to those described in this Policy;
• Transfer impact assessments where required.

By using the Platform, you acknowledge that your personal data may be transferred internationally as described in this section.

9. Data Retention

Triton77 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable legal, regulatory, or licensing obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data lifecycle procedures.

10. Cookies & Tracking Technologies

10.1 What We Use

Triton77 uses cookies and similar tracking technologies (including web beacons and session tokens) to operate the Platform, maintain your logged-in session state, remember your preferences, and gather aggregate analytics about Platform usage.

10.2 Categories of Cookies

• Strictly Necessary Cookies: essential for the Platform to function; cannot be disabled without breaking core functionality (e.g., session authentication tokens, security cookies);
• Functional Cookies: remember your preferences such as language, currency, and display settings;
• Analytics Cookies: collect pseudonymised usage data to help us understand how players interact with the Platform and identify areas for improvement. Used with your consent.

10.3 Managing Cookies

You may configure your browser to refuse or delete cookies. Blocking strictly necessary cookies will impair or prevent your use of the Platform. You can withdraw consent for non-essential cookies at any time via your browser settings. Note that cookie preferences are stored per device and per browser.

11. Your Rights

As a player whose personal data is processed by Triton77, you hold the following rights. To exercise any of these rights, contact us using the details in Section 15.

11.1 Right of Access

You may request confirmation of whether we hold personal data about you, and if so, a copy of that data along with information about how it is processed. We will respond within 30 days of receiving a verified request.

11.2 Right to Rectification

If personal data we hold about you is inaccurate or incomplete, you may request that we correct or complete it. We will process rectification requests without undue delay.

11.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other lawful basis applies), or where the data has been unlawfully processed. Erasure requests are subject to our legal retention obligations — we cannot delete data that we are required to retain under licensing or AML law.

11.4 Right to Restriction of Processing

You may request that we restrict processing of your personal data in certain circumstances, including while the accuracy of data is being contested, or where you have objected to processing under legitimate interests pending verification of our grounds.

11.5 Right to Data Portability

Where processing is based on your consent or on contract performance, and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.

11.6 Right to Object

You may object to processing of your personal data where we rely on legitimate interests as the legal basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary for legal claims.

11.7 Right to Withdraw Consent

Where we rely on your consent for processing (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and does not affect your account access or gameplay rights.

12. Security Measures

Triton77 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption: all data in transit is encrypted using TLS 1.3; data at rest is encrypted using AES-256;
• Access Controls: role-based access control (RBAC) limits access to personal data to authorised personnel with a demonstrable need to access it;
• Two-Factor Authentication: available and encouraged for all player accounts; mandatory for internal administrative access;
• Security Monitoring: intrusion detection systems (IDS), anomaly detection, and regular penetration testing are employed to identify and remediate vulnerabilities;
• Vendor Due Diligence: all third-party processors are assessed for security compliance before engagement and subject to contractual security obligations;
• Incident Response: a documented data breach response procedure is in place, including a 72-hour notification timeline for breaches posing material risk to data subjects.

No data transmission over the internet can be guaranteed as 100% secure. While we take all reasonable measures, players also have a responsibility to protect their own credentials and devices.

13. Children's Privacy

The Platform is strictly intended for individuals aged 21 years and above. Triton77 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

Age verification is conducted as part of the KYC process. Any individual who misrepresents their age to gain access to the Platform is in breach of our Terms and Conditions and applicable law. We encourage parents and guardians to monitor their children's online activities and to use appropriate parental controls. For more information, visit our Responsible Gambling page.

14. Changes to This Privacy Policy

Triton77 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our Platform's Services. The effective date at the top of this document will be updated upon each revision.

Where changes are material — for example, a change in the types of data we collect or the purposes for which we use it — we will notify you by email (to your registered address) and/or by a prominent notice on the Platform before the change takes effect. We will also, where required by law or the nature of the change, seek your renewed consent.

We recommend reviewing this Policy periodically. Continued use of the Platform following the effective date of any update constitutes your acknowledgement of the revised Policy.

15. Contact Us

For any privacy-related enquiries, to exercise your data rights, or to submit a complaint regarding our data practices, please contact the Triton77 Data Protection team:

• Email: [email protected]
• Live Chat: Available 24/7 on the Platform. Please state "Privacy Request" at the start of your message for priority routing.

We will acknowledge your request within 3 business days and provide a substantive response within 30 calendar days. If your request is complex or voluminous, we will notify you of any extension beyond the initial 30-day period.

If you are dissatisfied with our handling of your personal data or our response to your rights request, you have the right to lodge a complaint with the relevant supervisory authority in the jurisdiction applicable to your residency.