linitoto Privacy Policy for Malaysian Players

Introduction

linitoto is committed to handling personal information responsibly. This Privacy Policy applies to all individuals who access, register with, or otherwise interact with linitoto services, including Malaysian residents in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam and elsewhere. The policy describes what data is collected, why it is needed, how it is protected and what choices are available to account holders.

By registering an account or using linitoto services, the user acknowledges that this Privacy Policy has been read and understood. This policy should be read alongside the linitoto Terms & Conditions. Where a conflict exists, the specific terms that address particular processing activity should be considered in their combined context. Mandatory legal rights under applicable data-protection law are not affected.

Definitions

Personal Data

Any information relating to an identified or identifiable natural person, including name, contact details, identification number, payment references, device identifiers and account activity.

Processing

Any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.

Data Controller

The entity responsible for determining the purposes and means of processing personal data in connection with linitoto services.

Third-Party Processor

An organisation engaged to process personal data on behalf of linitoto under a contract and in accordance with this policy.

Consent

A freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose.

Sensitive Data

A subset of personal data requiring heightened protection, which may include identification documents, financial account information and responsible-gambling self-assessment records.

Personal Data We Collect

linitoto collects personal data in connection with registration, account activity payment transactions, security checks and service communications. The categories and examples below are indicative rather than exhaustive.

Purposes of Processing

linitoto processes personal data for the following purposes:

• Account creation and management: registering eligible users, maintaining account settings and delivering service features;
• Identity and age verification: confirming that a player is at least 21 years old, confirming identity and preventing multiple accounts;
• Payment processing: facilitating deposits and withdrawals through available Malaysian payment options;
• Anti-moneylaundering and fraud prevention: screening transactions, detecting suspicious patterns and complying with financial-intelligence obligations;
• Responsible gambling: recording player-imposed limits, monitoring activity patterns and administering self-exclusion or cooling-off measures;
• Customer support: responding to account, payment, technical and general service queries;
• Service improvement: understanding how users navigate sports betting, casino and account features to identify performance and usability improvements;
• Security and fraud prevention: detecting, blocking and investigating unauthorised access, account takeovers and related threats;
• Legal compliance: meeting applicable legal, regulatory, tax and reporting obligations.

Legal Bases for Processing

Where a formal legal basis for processing is required, linitoto may rely on one or more of the following, depending on the specific activity and applicable law:

• Performance of a contract: processing necessary to register an account, handle deposits and withdrawals, settle wagers and deliver the services the user requested;
• Legal obligation: processing required to comply with identity-verification, anti-money-laundering, tax-reporting or other applicable regulatory requirements;
• Legitimate interests: processing for fraud prevention, security monitoring, service improvement and responsible-gambling administration, balanced against individual privacy interests;
• Consent: where marketing communications, optional analytics or similar activities require a freely given and withdrawable agreement.

Consent to optional processing, such as promotional communications, may be withdrawn by adjusting account communication preferences. Withdrawal of consent does not affect the lawfulness of earlier processing.

Data Sharing and Disclosure

linitoto does not sell personal data to third parties for marketing or advertising purposes. Personal data may be shared only in the circumstances described below.

• Payment service providers: banks, e-wallet operators including Touch 'n Go eWallet, Boost and GrabPay, FPX and DuitNow processors, and digital-asset networks required to process account transactions;
• Identity verification and KYC providers: services engaged to confirm identity, verify documents and screen against applicable compliance databases;
• Fraud prevention and security services: providers who help detect, investigate and prevent account compromise, payment fraud and related threats;
• Technology and infrastructure providers: hosting, data-processing and software suppliers who handle data under appropriate contractual protections;
• Regulatory and law-enforcement authorities: where disclosure is required by a valid legal order, applicable statute or regulatory direction;
• Professional advisers: lawyers, auditors and compliance consultants acting under confidentiality obligations where disclosure is reasonably necessary.

International Data Transfers

linitoto may operate or use service providers in jurisdictions outside Malaysia. Where personal data is transferred to a country that does not provide an equivalent level of data protection, linitoto will rely on appropriate safeguards to protect the information, which may include standard contractual clauses, processor agreements or other applicable legal mechanisms.

Payment data transmitted through Malaysian banking networks, FPX or DuitNow may be processed within frameworks governed by the relevant financial-system rules and Bank Negara Malaysia guidelines applicable to those services.

Data Retention

Personal data is retained for as long as is reasonably necessary to fulfil the purposes described in this policy, including the duration of an active account relationship and any applicable post-closure obligations. Specific retention periods may be influenced by:

• Statutory record-keeping requirements for financial, tax or anti-money-laundering compliance;
• The resolution of open disputes, chargebacks or investigations;
• Responsible gambling records that must be maintained to honour active self-exclusion arrangements;
• Legal proceedings or regulatory inquiries in which records remain relevant.

When personal data is no longer required for any of the above purposes, linitoto will take reasonable steps to securely delete, anonymise or dispose of it. Aggregated or fully anonymised data that cannot identify an individual may be retained for analytical purposes without a fixed deletion timeline.

Security Measures

linitoto implements technical and organisational measures intended to protect personal data against accidental loss, unauthorised access, disclosure, alteration or destruction. These may include:

• Encrypted transmission protocols for data in transit;
• Access-control policies restricting data access to authorised personnel with a legitimate need;
• Security logging and monitoring to detect and respond to anomalous activity;
• Periodic review of security practices in relation to known risks and service changes.

No security measure eliminates risk entirely. Users should also maintain strong, unique passwords, keep verification codes private and avoid signing in from shared or unverified devices. Any suspected unauthorised account activity should be reported through the support contact information displayed within linitoto.

Cookies and Tracking Technologies

linitoto may use cookies and similar technologies to support session management, security, fraud detection, and service performance monitoring. Cookies may be session-based (deleted when the browser is closed) or persistent (retained for a set period).

Essential cookies required for login, account security and fraud prevention may be placed without separate consent because they are technically necessary for services the user has requested. Optional analytical or performance cookies will be handled in accordance with the applicable consent rules at the time of access.

Most browsers provide settings to manage or delete cookies. Disabling essential cookies may prevent certain linitoto functions from working as intended.

User Rights

Subject to applicable law and the specific circumstances of each request, users may have the following rights in relation to personal data held by linitoto:

• Access: request confirmation of whether personal data is held and obtain a copy;
• Correction: request correction of inaccurate or incomplete personal data;
• Deletion: request erasure where data is no longer required, subject to legal-retention obligations;
• Restriction: request that processing be limited while accuracy is disputed or an objection is considered;
• Objection: object to processing based on legitimate interests where individual circumstances justify it;
• Portability: receive a structured, common-format copy of data provided directly, where technically feasible and legally applicable;
• Withdrawal of consent: withdraw optional consent to processing at any time, without affecting prior lawful processing.

Requests will be assessed on their individual merits. Identity verification may be required before a response is provided. Certain requests may be limited where legal, regulatory or contractual obligations require particular data to be maintained.

Children and Minors

linitoto services are intended strictly for adults aged 21 and above. linitoto does not knowingly collect personal data from persons below this age. If information suggests that an account has been registered by or on behalf of a minor, linitoto may take steps to restrict the account pending verification and, where confirmed, to close it and handle the associated data accordingly.

Parents and guardians who believe a minor has registered or accessed linitoto should contact support immediately using the email address provided in this policy. Responsible gambling controls, including self-exclusion and account closure, are available to all adult account holders who wish to prevent further access.

Policy Changes, Contact and Complaints

This Privacy Policy may be updated periodically to reflect changes in applicable law, regulatory guidance, service developments or data-handling practices. The effective date shown at the top will be revised on each update. Material changes that significantly affect user rights or data-processing activities will be communicated through the website or account interface as required.

For data-privacy queries, correction requests, deletion requests or complaints relating to how linitoto handles personal information, users should contact linitoto through the support email. The website email [email protected] is provided as plain text for reference.

If a response to a privacy complaint is considered unsatisfactory, users may have the right to refer their concern to the applicable data-protection supervisory authority in the relevant jurisdiction. linitoto will cooperate with such inquiries to the extent required by law.