Polototo Privacy Policy – Malaysian User Data Protection

1 Introduction and Scope of This Policy

Polototo ("we", "our platform") operates under the website polototo.vin and committed to protecting the privacy of all users of our online entertainment platform. This Privacy Policy describes our practices regarding the collection, use, disclosure, and protection of your personal information.

This document applies to all users accessing the Polototo platform through our website, mobile app for Android and iOS, and any other services provided under the Polototo brand. By registering an account or using any of our services, you consent to the collection and use of your information as described in this Privacy Policy.

Polototo complies with Malaysia's Personal Data Protection Act 2010 (PDPA) and all applicable data protection laws. We take our responsibility to safeguard the security and confidentiality of every user's personal information seriously.

2 Types of Personal Data We Collect

Polototo collects various types of personal information depending on how you interact with our platform. The following are the main categories of data we collect:

In addition to information you provide directly during registration, polototo also collects data automatically through cookies, tracking pixels, and similar technologies when you visit or use our platform. This data helps us understand usage patterns and improve the overall user experience.

For identity verification (KYC) purposes, we may request copies of official documents such as a national ID, passport, or bank statement. All such documents are stored securely using high-level encryption and are accessible only by authorised personnel.

3 How We Use Your Data

Polototo uses the personal information collected for the following purposes:

• Account management: Creating, verifying, and securely managing your user account.
• Transaction processing: Processing deposits, withdrawals, and all financial transactions accurately and promptly.
• Identity verification: Carrying out KYC procedures to comply with regulatory requirements and prevent fraud.
• Customer support: Responding to enquiries, resolving complaints, and providing technical assistance.
• Service communications: Sending important notifications related to your account, transactions, and platform updates.
• Marketing and promotions: Sending relevant offers, bonuses, and promotions — only to users who have given their consent.
• Platform security: Detecting and preventing fraud, hacking, and suspicious activity.
• Legal compliance: Meeting legal obligations, regulations, and regulatory body requirements.
• Service improvements: Analysing usage patterns to improve platform performance and experience.

4 Data Sharing and Disclosure

Polototo does not sell, rent, or disclose your personal data to third parties for commercial purposes without your consent. However, we may share your information in the following limited circumstances:

• Payment service providers: Such as FPX, Maybank2u, CIMB Clicks, Touch 'n Go, GrabPay, and Boost — solely for processing your financial transactions.
• Game software providers: Technical partners who provide games on our platform, under strict confidentiality agreements.
• Cloud service providers: IT infrastructure providers that store and process our data under binding data protection agreements.
• Law enforcement authorities: When required by law, court order, or a legitimate request from a government authority.
• Fraud prevention: With industry bodies or identity verification service providers to detect and prevent fraudulent activity.

Every third party that receives your data is bound by strict confidentiality and data protection agreements. They are only permitted to use that data for the specified purposes and may not use it for any other purpose.

5 Data Security and Protection

Polototo invests seriously in security infrastructure to ensure your personal data is always protected. The security measures we implement include:

• 256-bit SSL encryption: All data transmitted between your device and our servers is protected with bank-grade encryption.
• Two-factor authentication (2FA): An additional security layer to protect your account login from unauthorised access.
• 24/7 monitoring: Our security monitoring system operates around the clock to detect and respond to any cyber threats.
• Internal access controls: Only authorised personnel with a legitimate business need may access users' personal data.
• Regular security audits: Our platform undergoes regular independent security testing and audits conducted by cybersecurity experts.
• Data backups: User data is securely backed up and can be recovered within a short time in the event of a system failure.

6 Cookies and Tracking Technologies

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

The following are the types of cookies we use:

You can manage your cookie settings through your web browser at any time. Please note that disabling essential cookies may affect certain functions of the Polototo platform. Analytics and marketing cookies are optional and can be declined without affecting basic platform use.

7 Your Rights Regarding Personal Data

As a polototo platform user, you have the following rights regarding your personal data under Malaysia's PDPA:

To exercise any of the above rights, please contact our privacy team by email at [email protected]. We will process your request within 14 business days.

8 Data Retention Period

Polototo retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy, or as required by law. The following are our data retention guidelines:

• Active account data: Retained for as long as your account is active and for 5 years after account closure for legal compliance purposes.
• Financial transaction records: Retained for 7 years in accordance with Malaysia's financial legal requirements.
• KYC documents: Retained for 5 years after the business relationship ends, or longer if required by law.
• Support communication logs: Retained for 2 years from the date of last interaction.
• Analytics cookie data: Automatically deleted after 90 days.

Once the retention period expires, your data will be securely deleted or anonymised so it can no longer be linked to your identity. The deletion process is carried out in accordance with industry security standards to ensure data cannot be recovered.

9 Third-Party Links and Services

The polototo platform may contain references to third-party services such as payment providers and game providers. Please be aware that:

• Polototo is not responsible for the privacy practices of any third parties integrated with our platform.
• Each third-party service provider has its own privacy policy governing the use of your data on their platform.
• We encourage you to read the privacy policy of your payment provider before carrying out any transaction.
• All third-party integrations on the polototo platform are subject to strict data protection agreements to ensure your data is handled responsibly.

10 Child Protection

The polototo platform is intended exclusively for adults aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18.

If we discover that a child's personal data has been collected without the knowledge or consent of a parent or legal guardian, we will take immediate steps to delete that data and close the relevant account. If you believe your child has registered an account on our platform, please contact us immediately at [email protected].

11 Amendments to This Privacy Policy

Polototo reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new technologies, legal requirements, or other relevant factors. We will notify you of any significant changes through:

• In-platform polototo notification upon your next login.
• Emailed to your registered address at least 7 days before the changes take effect.
• Update the "Last Updated" date at the top of this document.

Continued use of the polototo platform following any amendments is considered acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed on how we protect your data.

12 Contact Us About Privacy

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please contact our Data Privacy Officer:

• Email: [email protected]
• Live Chat: Available 24/7 through the polototo platform
• Email Response Time: Within 14 business days

We are committed to resolving every privacy complaint fairly, transparently, and within the stipulated timeframe. If you feel your complaint has not been resolved satisfactorily, you have the right to escalate it to the Malaysia Personal Data Protection Department.