PTTogel Privacy Policy

1 Introduction

This Privacy Policy (hereinafter "Policy") is published by PTTogel, the operator of the online gambling platform accessible at https://pttogel.lat (hereinafter the "Platform", "Site", or "Service"). PTTogel is committed to safeguarding the privacy and personal data of all individuals who interact with our Platform, whether as registered players, visitors, or prospective members.

This Policy sets out in clear and formal terms the categories of personal data PTTogel collects, the purposes for which that data is processed, the legal bases relied upon for such processing, the parties with whom data may be shared, the security measures we have in place, and the rights you hold in respect of your personal data.

By registering an account on the PTTogel Platform, you acknowledge that you have read, understood, and consent to the data processing practices described in this Policy. This Policy should be read in conjunction with our Terms & Conditions, which form an integral part of the contractual relationship between PTTogel and all registered users.

2 Definitions

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

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, and online identifiers.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" — PTTogel, in its capacity as the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Subject" — you, the registered user or visitor whose personal data is collected and processed by PTTogel.
• "Third Party" — any natural or legal person other than the data subject and PTTogel, including payment processors, KYC verification services, and technology partners.
• "Cookies" — small text files placed on your device by the Platform to facilitate session management, analytics, and personalisation.
• "KYC" — Know Your Customer; the identity verification process conducted by PTTogel to comply with anti-money laundering and responsible gambling obligations.

3 Categories of Personal Data We Collect

PTTogel collects personal data across several categories, depending on the nature of your interaction with the Platform. The table below provides an overview of the data categories collected and the context in which they arise:

4 How We Collect Personal Data

PTTogel collects personal data through the following primary channels:

4.1 Direct Collection

Data you provide directly when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting our customer support team, or participating in a promotional offer. This includes all information entered into forms, chat windows, and email correspondence.

4.2 Automated Collection

Technical data collected automatically when you access the Platform, including your IP address, browser session data, device fingerprint, and activity logs. This data is captured via first-party cookies, server-side logging, and session management technology.

4.3 Third-Party Sources

In limited circumstances, PTTogel may receive personal data from third-party sources, including:

• Payment processors and e-wallet providers (for transaction verification and fraud screening);
• Identity verification and KYC service providers engaged to validate government-issued documents;
• Anti-fraud and risk management platforms providing device reputation and behavioural analytics data;
• Self-exclusion registries, where a player has voluntarily registered for cross-platform exclusion services.

5 Legal Basis for Processing

PTTogel processes personal data only where there is a lawful basis for doing so. The legal bases relied upon for processing activities on the Platform are as follows:

• Contractual Necessity: Processing is necessary to perform the contract between PTTogel and the registered player — including account management, payment processing, and service delivery;
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, KYC requirements, and licensing conditions;
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform integrity, and improving service quality, where such interests are not overridden by the data subject's fundamental rights;
• Consent: Where PTTogel relies on consent (for example, for optional marketing communications), such consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6 How We Use Your Personal Data

PTTogel processes personal data for the following specific purposes:

• Account Management: Creating, maintaining, and securing your registered PTTogel account;
• Identity Verification (KYC): Verifying your identity and age to comply with responsible gambling standards and regulatory requirements — mandatory for all players aged 21 and above before withdrawal;
• Payment Processing: Facilitating deposits via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency channels; processing withdrawal requests in MYR;
• Fraud and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, and other prohibited conduct;
• Responsible Gambling: Monitoring gaming activity to identify patterns of potential problem gambling; administering self-exclusion, deposit limits, and cooling-off periods at player request;
• Customer Support: Responding to queries, resolving disputes, and providing assistance via live chat and email;
• Legal Compliance: Retaining records as required by anti-money laundering regulations, gaming licence conditions, and applicable Malaysian and international law;
• Service Improvement: Analysing aggregated platform usage data to improve game selection, payment infrastructure, and user experience;
• Marketing Communications: Sending promotional information, bonus offers, and platform updates where you have opted in to such communications. You may opt out at any time.

7 Data Sharing & Disclosure

PTTogel does not sell, lease, or trade your personal data to third parties for commercial purposes. We may share personal data with the following categories of recipient, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: Banks, e-wallet operators (Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, DuitNow/FPX), and cryptocurrency processors to execute financial transactions;
• KYC and Identity Verification Partners: Third-party providers engaged to verify identity documents and conduct AML screening;
• Technology Infrastructure Providers: Cloud hosting, database, and content delivery providers operating under strict data processing agreements with PTTogel;
• Fraud Prevention Services: Risk analytics and device reputation providers used to protect platform integrity;
• Regulatory Authorities and Law Enforcement: Where PTTogel is legally obligated to disclose data in response to a court order, regulatory request, or lawful law enforcement demand;
• Gaming Licensing Authority: Information required for licence compliance reporting and audit purposes;
• Professional Advisers: Lawyers, auditors, and insurers, subject to professional confidentiality obligations, where required for legal or business purposes.

8 Cookies & Tracking Technologies

8.1 What We Use Cookies For

PTTogel uses first-party cookies and similar tracking technologies to operate the Platform and improve your experience. We do not use third-party advertising cookies or behavioural tracking networks. The categories of cookies we deploy are as follows:

• Strictly Necessary Cookies: Essential for session management, authentication, and security. These cannot be disabled without impairing Platform functionality;
• Functional Cookies: Store your preferences (such as language, display settings, and responsible gambling alerts) to personalise your experience;
• Analytics Cookies: Collect aggregated, anonymised data about how users navigate the Platform, used solely for internal service improvement purposes;
• Security Cookies: Used for fraud detection, bot identification, and IP-based access control.

8.2 Managing Cookies

You may configure your browser to reject or delete cookies at any time. Please note that disabling strictly necessary cookies will affect your ability to log in, maintain a session, or access certain Platform features. PTTogel does not currently respond to "Do Not Track" browser signals as no uniform standard has been adopted for such signals.

9 Data Retention

PTTogel retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following retention periods apply as a general guide:

• Account and Identity Data: Retained for the lifetime of the account plus a minimum of 5 years following account closure, in accordance with anti-money laundering record-keeping requirements;
• Financial Transaction Records: Retained for a minimum of 7 years from the date of each transaction, as required by applicable financial regulations;
• KYC Documents: Retained for 5 years following the completion of the relevant business relationship, unless a longer period is required by law;
• Customer Support Communications: Retained for 3 years from the date of the last interaction, unless the matter relates to an ongoing dispute or legal proceeding;
• Gaming Activity Logs: Retained for 5 years for responsible gambling monitoring, fraud prevention, and dispute resolution purposes;
• Technical and Analytics Data: Retained for up to 24 months in aggregated or anonymised form.

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised in accordance with PTTogel's internal data deletion procedures.

10 Data Security

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

• TLS Encryption: All data transmitted between your browser and the PTTogel Platform is encrypted using Transport Layer Security (TLS 1.2 or higher) to prevent interception in transit;
• Encryption at Rest: Sensitive data fields — including KYC documents, financial data, and identity information — are encrypted at rest using industry-standard encryption protocols;
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All internal access is subject to role-based access controls and comprehensive audit logging;
• Two-Factor Authentication (2FA): Available to all registered players for account login protection, and mandatory for administrative system access by PTTogel personnel;
• Regular Security Audits: PTTogel engages independent third-party security specialists to conduct periodic penetration testing and vulnerability assessments of the Platform;
• Incident Response: PTTogel maintains a documented data breach response procedure. In the event of a breach likely to result in high risk to affected individuals, notification will be provided without undue delay.

While PTTogel takes all reasonable steps to protect your personal data, no internet transmission is completely secure. Players are advised to keep their account credentials confidential and to contact our support team immediately at [email protected] if they suspect any unauthorised access to their account.

11 Your Rights as a Data Subject

As a data subject, you hold the following rights with respect to your personal data processed by PTTogel. These rights may be subject to certain exemptions under applicable law, particularly where processing is required for legal compliance or fraud prevention purposes.

To exercise any of the above rights, please contact PTTogel's Data Protection team via email at [email protected] with the subject line "Data Subject Request". PTTogel will respond to all valid requests within 30 calendar days. Identity verification may be required before actioning a request.

12 International Data Transfers

PTTogel's Platform is operated from infrastructure located in multiple jurisdictions. As a result, your personal data may be transferred to, stored in, or processed in countries outside Malaysia. Where such transfers occur, PTTogel ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by relevant data protection authorities, incorporated into agreements with data processors located outside Malaysia;
• Transfers only to jurisdictions that provide an adequate level of data protection as assessed by PTTogel's legal team;
• Binding corporate rules or equivalent mechanisms where personal data is transferred between affiliated entities.

All payment processing partners handling MYR transactions — including those facilitating Touch 'n Go eWallet, DuitNow, FPX, and bank transfers — are contractually required to process and store transaction data in accordance with applicable Malaysian financial regulations.

13 Children's Privacy

The PTTogel Platform is strictly intended for individuals aged 21 years and above. PTTogel does not knowingly collect, process, or store personal data from individuals under the age of 21. If PTTogel becomes aware that personal data has been submitted by or on behalf of an underage individual, the relevant account will be immediately suspended, all associated data will be securely deleted, and any funds in the account will be handled in accordance with our Terms & Conditions.

Parents or guardians who believe that a minor may have registered an account on PTTogel are requested to contact our support team immediately at [email protected] so that appropriate action can be taken without delay.

14 Amendments to This Policy

PTTogel reserves the right to update or amend this Privacy Policy from time to time to reflect changes in data processing practices, legal requirements, or Platform functionality. Where material changes are made that affect your rights or how your data is used, PTTogel will provide notice via the email address registered to your account no less than 14 calendar days prior to the changes taking effect.

The current version of this Policy, together with its effective date, is always accessible on this page. Your continued use of the Platform following the publication of an updated Policy constitutes your acknowledgement of the amended terms. If you do not accept the changes, you must cease using the Platform and request voluntary account closure in accordance with the Terms & Conditions.

15 Contact Us & Complaints

PTTogel welcomes questions, feedback, and formal complaints regarding the handling of personal data. All privacy-related enquiries should be directed to our dedicated Data Protection team:

• Email: [email protected] — Subject line: "Privacy Enquiry" or "Data Subject Request"
• Live Chat: Available 24/7 via the on-site live chat widget — our agents will direct privacy-related queries to the appropriate team
• Response Commitment: All privacy enquiries acknowledged within 48 hours; substantive responses provided within 30 calendar days

PTTogel serves players across Malaysia — including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and beyond. All privacy communications are handled in English by our dedicated data protection team.

If you are not satisfied with PTTogel's response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority in the jurisdiction where you are resident, or to the supervisory authority designated by PTTogel's gaming licence jurisdiction.