Privacy Policy scru2 – Your Personal Data Protection

Introduction

Scru2 (referred to as "we", "our platform", or "scru2.app") values the privacy of every member and user of our platform. We understand that your personal data is a trust placed in us, and we are committed to handling it with full responsibility, transparency, and integrity.

This Privacy Policy applies to all users who access or use the scru2 platform via our website, mobile app, or any other digital channel we operate. It comprehensively explains our privacy practices, including the types of data we collect, why we need it, how we use it, and the protective measures we implement to keep your information secure at all times.

This policy should be read together with Terms and Conditions and Responsible Gaming Policy which together form the entire agreement between you and scru2.

2Types of Personal Data We Collect

We only collect data that is strictly necessary to provide you with a quality, secure, and legally compliant service. The following are the categories of data we may collect:

3How We Collect Your Data

Your personal data is collected through several different channels throughout your interactions with the scru2 platform. We ensure every data collection method is transparent and legally compliant.

• Account Registration: Information you provide directly during registration, such as your name, email, and contact details.
• KYC Process: Identity documents and proof of address uploaded for identity verification purposes
• Financial Transactions: Information collected during the deposit and withdrawal process via various payment methods.
• Platform Usage: Data generated automatically when you browse and use features within the scru2 platform
• Communications with Us: Information you share when contacting our customer support team.
• Mobile App: Device technical data collected through the scru2 app for Android and iOS with your consent
• Cookies & Similar Technologies: Browsing data collected automatically to improve user experience

We never purchase or obtain your personal data from third-party sources without your prior knowledge and consent.

4Purposes for Using Your Personal Data

Scru2 uses your personal data solely for legitimate, relevant, and non-excessive purposes. The following are the primary purposes for which your data is used:

• Account Management: Creating, verifying, and securely maintaining your member account.
• Service Provision: Enabling you to seamlessly access all games, promotions, and features on the scru2 platform.
• Financial Processing: Processing deposits, withdrawals, and other transactions accurately and securely.
• Legal Compliance: Fulfilling KYC, AML (Anti-Money Laundering), and regulatory reporting obligations.
• Fraud Prevention: Detecting, investigating, and preventing fraudulent activity, money laundering, and platform abuse.
• Customer Support: Handling your enquiries, complaints, and assistance requests effectively.
• Marketing Communications: Sending relevant promotional information, bonuses, and exclusive offers — you may unsubscribe at any time.
• Platform Improvements: Analysing usage patterns to improve overall service quality, security, and user experience.
• Responsible Gaming: Monitoring gameplay patterns to identify and assist members who may need responsible gaming support.

5Data Sharing & Disclosure

Scru2 takes the confidentiality of your data very seriously. We do not sell, rent, or trade your personal data to third parties for their own marketing purposes. However, there are limited situations where we may need to share your data:

• Trusted Service Providers: Technical partners such as payment processors, cloud service providers, and identity verification companies bound by strict confidentiality agreements
• Game Software Providers: Information required for game operations, supplied by third-party software developers within the scru2 ecosystem.
• Legal Requirements: When required by a court, law enforcement agency, or competent regulatory body under Malaysian law
• scru2 Rights Protection: In cases of fraud, platform abuse, or legal action necessary to protect the rights and interests of scru2 and its members
• Business Transfer: In the event of a merger, acquisition, or asset transfer, data may be transferred to the successor entity subject to equivalent privacy protections

Every third party with whom we share data is subject to a strict data processing agreement and is required to protect your information to a standard no less than this Privacy Policy.

6Security & Data Protection

The security of your personal data is our absolute top priority. scru2 invests in industry-grade security infrastructure to ensure your information is protected at all times, whether in transit or at rest.

• 256-bit SSL Encryption: All data transmitted between your browser and scru2 servers is protected by industry-grade 256-bit SSL/TLS encryption
• Stored Data Encryption: Sensitive data stored in our databases is encrypted using the latest encryption algorithms
• Strict Access Control: Only authorised staff with a legitimate business need may access member personal data
• 24/7 Monitoring: Our security systems are monitored continuously around the clock to detect any suspicious activity
• Regular Auditing: We conduct regular security audits and penetration testing to identify and address any vulnerabilities.
• Two-Factor Authentication (2FA): 2FA is available and strongly encouraged for all members to add an extra layer of protection to your account

While we implement all reasonable security measures, no system in the world can be guaranteed 100% secure. In the event of any data breach involving your information, we will notify you within the timeframe required by law and take immediate remedial action.

7Cookies & Tracking Technologies

Scru2 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

You may manage or disable optional cookies through your browser settings at any time. However, please note that disabling essential cookies may affect the functionality of the scru2 platform.

8Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act (PDPA) 2010, you have certain rights regarding the personal data we hold about you. scru2 fully respects and supports the exercise of these rights.

9Data Retention Period

Scru2 retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy or as required by applicable laws and regulations. Our principle is simple: keep what is needed, discard what is no longer necessary.

• Active Account Data: Retained for the duration your account is active and for a defined period following account closure
• Financial Records & Transactions: Retained for a minimum of 7 years in accordance with accounting and anti-money laundering legal requirements
• KYC Documents: Retained for a minimum of 5 years after the business relationship ends, in line with AML requirements
• Communication Logs: Customer support records are retained for 3 years for reference and dispute resolution purposes
• Technical & Log Data: Security logs and technical data are retained for 12 months and subsequently deleted or anonymised.

Once the retention period expires and there is no legal requirement to retain the data, scru2 will securely delete or anonymise your data using industry-recognised methods.

10Changes to This Privacy Policy

Scru2 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our privacy practices, current legal requirements, or new platform features introduced. We are committed to informing you of any material changes.

• Any significant changes will be communicated via a clear notice on the platform and/or by email to your registered address
• The effective date of the latest version will be clearly stated at the top of this document
• Previous versions of the Privacy Policy will be kept as historical records and can be requested through our support team
• Continued use of the scru2 platform after the effective date of any changes constitutes acceptance of the latest version of this Privacy Policy.

We encourage you to review this page regularly to ensure you are always informed about how we protect your privacy. Your trust is the foundation of our relationship with you.

11Contact Us – Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please do not hesitate to contact us. Our Data Protection Officer (DPO) is specifically appointed to handle all privacy-related matters.