Privacy Policy —
How baru01 Protects Your Data

baru01 ("the Platform", "we", "us", "our") operates the online casino and sports betting services available at baru01.click. As part of our operations, we collect and process personal data belonging to individuals ("you", "the User", "Member") who visit, register on, or otherwise interact with the Platform.

This Privacy Policy has been prepared in accordance with applicable data protection legislation and sets out in clear terms the nature of the personal data we collect, the purposes for which that data is processed, the parties with whom it may be shared, how long it is retained, the security measures we apply to protect it, and the rights available to you as a data subject.

This Privacy Policy is to be read alongside our Terms and Conditions, which govern the overall contractual relationship between you and baru01. In the event of any conflict between the two documents concerning data matters, this Privacy Policy shall take precedence.

For the purposes of this Privacy Policy, the following terms shall bear the meanings ascribed to them below:

• "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, or online identifier.
• "Processing" means any operation performed on Personal Data, whether or not by automated means, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.
• "Data Controller" means baru01, the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of baru01 pursuant to documented instructions.
• "Data Subject" means the living individual to whom Personal Data relates — in this context, you, the Member or visitor.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the processing of their Personal Data.
• "Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, or financial account details that require enhanced protection.
• "Cookies" means small text files placed on a device by a website to store data relating to the user's interaction with that site.

baru01 collects Personal Data from Members and visitors across several categories. The specific data collected depends on the nature of your interaction with the Platform:

A. Registration & Account Data

• Full legal name as it appears on government-issued identification
• Date of birth (for the purpose of verifying that you are 21 years of age or above)
• Email address and mobile phone number
• Residential address, including city (e.g., Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam) and postcode
• Preferred username and encrypted account password
• Nationality and Malaysian identity card (MyKad) number or passport number

B. Financial & Transaction Data

• Payment method details including e-wallet account references for Touch 'n Go eWallet, Boost, and GrabPay
• Bank account details for FPX and DuitNow transactions with Maybank, CIMB, Public Bank, RHB, and Hong Leong Bank
• Cryptocurrency wallet addresses (BTC, ETH, USDT) where applicable
• Deposit history, withdrawal history, and transaction records
• Account balance information

C. Identity Verification (KYC) Data

• Scanned copies or photographs of government-issued identity documents
• Proof of address documents dated within three months
• Selfie or live photograph for facial identity verification where required
• Source of funds documentation in high-value account situations

D. Usage & Behavioural Data

• Wagering history including game types, bet amounts, outcomes, and frequency
• Session duration, login timestamps, and active hours
• Device type, operating system, browser type, and screen resolution
• IP address and approximate geographic location derived from IP
• Pages visited, features accessed, and in-platform navigation paths

E. Communications Data

• Support chat transcripts and email correspondence with the baru01 team
• Feedback, complaints, and dispute records
• Survey responses and promotional opt-in or opt-out preferences

baru01 collects Personal Data through the following primary channels:

• Directly from you — when you complete the registration form, submit KYC documents, make a deposit or withdrawal, contact our support team, or participate in a promotion.
• Automatically — through cookies, session tracking technologies, and server logs as you navigate and interact with the Platform.
• From payment service providers — transaction confirmation data received from Malaysian payment processors including FPX, DuitNow, Touch 'n Go eWallet, and affiliated banks when you initiate a payment.
• From identity verification partners — data returned by third-party KYC service providers during the verification process.
• From fraud detection and AML services — risk-assessment data generated by anti-money-laundering screening tools used to protect the integrity of the Platform.

baru01 processes Personal Data only where a valid legal basis exists. The primary legal bases upon which we rely are as follows:

baru01 uses the Personal Data it holds for the following specific purposes:

• Account Administration: Creating, managing, verifying, and maintaining your baru01 Account throughout its lifecycle.
• Transaction Processing: Facilitating deposits via Malaysian payment methods and processing withdrawal requests to your nominated payment account.
• Identity Verification: Conducting mandatory age and identity checks to ensure compliance with the 21+ age requirement and applicable anti-money laundering regulations.
• Responsible Gambling: Monitoring account activity patterns to identify potential indicators of problem gambling, and operating self-exclusion, deposit limit, and cool-off tools.
• Fraud Prevention: Identifying and preventing fraudulent transactions, bonus abuse, multi-accounting, and other prohibited conduct as defined in our Terms and Conditions.
• Customer Support: Handling enquiries, resolving disputes, and communicating with Members regarding their accounts.
• Promotions & Personalisation: Sending relevant promotional offers, VIP programme updates, and personalised content where you have provided consent to receive such communications.
• Platform Improvement: Analysing aggregated usage data to improve the Platform's performance, user interface, and game offerings.
• Legal Compliance: Meeting our obligations under applicable laws, regulations, and any orders received from competent authorities.

baru01 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. However, in the course of operating the Platform and fulfilling our legal obligations, we may share your Personal Data with the following categories of third parties:

• Payment Service Providers: Malaysian payment processors including FPX, DuitNow, Touch 'n Go eWallet operator, Boost, GrabPay, and partner banks (Maybank, CIMB, Public Bank, RHB, Hong Leong) receive transaction data necessary to process your deposits and withdrawals.
• Identity Verification Partners: Third-party KYC service providers who assist with document verification and age confirmation receive the data you submit during the verification process.
• Game Content Providers: Where your gameplay data is processed by third-party game studios or live dealer platform operators, limited technical data is shared as required for game delivery and result validation.
• Anti-Fraud and AML Partners: Risk management service providers who assist in detecting suspicious transactions and complying with anti-money laundering obligations.
• Cloud Infrastructure Providers: Technology partners who host and process data on our behalf under strict contractual data protection obligations.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or regulatory direction, baru01 will disclose Member data to the relevant competent authority.
• Professional Advisers: Legal, accounting, and audit professionals who provide services to baru01 under binding confidentiality obligations.

baru01 retains Personal Data only for as long as is necessary for the purposes for which it was collected, or as required to comply with applicable legal, regulatory, tax, or accounting obligations.

The general retention principles applied by baru01 are as follows:

• Active Account Data: Retained for the full duration of the active Account relationship and for a minimum of five (5) years following account closure or the last active transaction, whichever is later.
• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure or the conclusion of any related regulatory matter, in compliance with anti-money laundering obligations.
• Financial Transaction Records: Retained for a minimum of seven (7) years to satisfy applicable tax and financial reporting requirements.
• Support and Communications Records: Retained for three (3) years from the date of the most recent communication, or longer where a dispute or investigation is ongoing.
• Marketing Consent Records: Retained for the duration of the marketing relationship and for a reasonable period thereafter to evidence consent in the event of a complaint.

At the end of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised in accordance with our data disposal procedures.

baru01 implements a multi-layered technical and organisational security framework designed to protect Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. Our key security measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the baru01 Platform is encrypted using industry-standard TLS protocols, preventing interception in transit.
• Data Encryption at Rest: Sensitive Personal Data stored in our databases is encrypted at the storage layer using AES-256 or equivalent encryption standards.
• Access Controls: Access to Member Personal Data is restricted on a strict need-to-know basis. Staff are granted only the minimum data access required for their specific role.
• Regular Security Audits: The Platform undergoes periodic security assessments and penetration testing conducted by qualified security professionals.
• Secure Password Policies: Account passwords are stored using one-way hashing algorithms. baru01 staff do not have access to your plain-text password.
• Intrusion Detection and Monitoring: Automated systems monitor the Platform for anomalous access patterns, suspicious login attempts, and potential data breach indicators on a continuous basis.

baru01 uses cookies and similar tracking technologies to operate and improve the Platform, to remember your preferences, to analyse traffic patterns, and to support our fraud detection systems.

Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies that keep you logged in, and security cookies used to detect fraudulent activity. These cannot be disabled.
• Functional Cookies: Store your preferences such as language settings, preferred odds format, and last-visited game category to improve your experience on return visits.
• Analytical Cookies: Collect anonymised data about how Members use the Platform — pages visited, time spent, navigation paths — to help us identify areas for improvement.
• Performance Cookies: Monitor Platform load times, server response rates, and error rates to support technical performance management.

You may adjust your browser settings to block or delete cookies. However, please note that disabling strictly necessary cookies will impair the functionality of the Platform and you may not be able to log in or use certain features. baru01 does not use third-party advertising cookies or cross-site tracking pixels.

As a Data Subject, you hold a number of rights in relation to the Personal Data that baru01 holds about you. These rights may be exercised by contacting our support team as described in Section 15. baru01 will respond to all valid rights requests within a reasonable timeframe and without undue delay.

Your rights include, but may not be limited to, the following:

• Right of Access: You have the right to request a copy of the Personal Data that baru01 holds about you, along with information about how it is processed.
• Right to Rectification: If any Personal Data we hold is inaccurate or incomplete, you have the right to request that it be corrected.
• Right to Erasure: You may request deletion of your Personal Data in certain circumstances, for example where the data is no longer necessary for the purpose for which it was collected and there is no overriding legal obligation to retain it.
• Right to Restriction: You may request that we restrict the processing of your Personal Data in specific situations, such as while a rectification request is being resolved.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request that your data be provided to you in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests, including profiling, where you believe your individual circumstances override our legitimate interests.
• Right to Withdraw Consent: Where processing is based on your consent (for example, receiving promotional communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

baru01 operates mandatory age verification as part of its KYC process. All Members are required to provide satisfactory proof of age before withdrawal functionality is activated. Accounts that cannot verify the Member is aged 21 or above will be suspended pending resolution.

Parents and guardians who are concerned about minors accessing online gambling platforms are encouraged to use parental control software and internet filtering tools to restrict access to gambling websites.

The baru01 Platform may contain references or navigational links to our own internal pages. Where the Platform integrates third-party services — such as live game studios, payment processors, or identity verification platforms — those third parties operate under their own privacy policies and data handling practices.

baru01 has no control over, and accepts no responsibility for, the privacy practices of third-party services that operate independently of the Platform. We encourage you to review the privacy policies of any third-party service providers you interact with, particularly in the context of payment processing through Malaysian banking and e-wallet platforms.

All third-party Data Processors engaged by baru01 are subject to Data Processing Agreements that require them to process Personal Data only on baru01's documented instructions and to implement appropriate security safeguards.

baru01 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the services offered on the Platform. The date of the most recent revision is displayed prominently at the top of this document.

Where changes to this Privacy Policy are material — meaning they significantly affect the way we collect or use your Personal Data, or the rights available to you — we will endeavour to notify registered Members via the email address associated with their Account prior to the changes taking effect.

Your continued use of the baru01 Platform following the effective date of any amendment constitutes your acknowledgement of the revised Privacy Policy. If you do not agree with the changes, you must cease using the Platform and contact our support team to close your Account.

If you wish to exercise any of your data protection rights, submit a privacy-related enquiry, raise a concern about how your Personal Data is being handled, or report a suspected data protection issue, please contact the baru01 team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week directly through the baru01 Platform. Our agents are available in English, Bahasa Melayu, and Mandarin to serve Members across Malaysia.
• Email: [email protected] — For privacy-specific requests, please include "Privacy Request" in the subject line to ensure prompt routing to the appropriate team.

We aim to acknowledge all privacy-related requests within three (3) business days and to resolve them within a reasonable timeframe, not exceeding thirty (30) calendar days for standard requests. Complex requests may require additional time, in which case we will communicate the expected resolution timeframe to you.