Privacy Policy

Introduction

Retrotogel ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all users who access or interact with the Retrotogel platform at retrotogel.cam. This Privacy Policy ("Policy") sets out in detail what personal data we collect, the purposes for which it is processed, how long it is retained, who it may be shared with, and what rights you hold as a data subject.

This Policy applies to all registered players, account applicants, and visitors to the Retrotogel platform — including players based in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and all other locations from which the Platform is accessed. It applies across all channels through which you engage with Retrotogel, including the web platform, mobile browser interface, customer support, and any promotional communications.

By registering an account on Retrotogel or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree to this Policy, you must discontinue your use of the Platform immediately.

Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings defined below:

• "Personal Data" means any information relating to an identified or identifiable natural person — including but not limited to name, email address, phone number, date of birth, national identification number (NRIC/Passport), financial account details, and IP address.
• "Processing" means any operation performed on Personal Data, whether by automated means or otherwise — including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means Retrotogel, the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" means any third-party entity that processes Personal Data on behalf of Retrotogel under a written data processing agreement.
• "Data Subject" means you — the individual whose Personal Data is being processed.
• "Consent" means any freely given, specific, informed, and unambiguous indication by a Data Subject that they agree to the processing of their Personal Data for a stated purpose.
• "Cookies" means small data files placed on your device by the Platform to enable session management, analytics, and certain functional features.
• "KYC" means the Know Your Customer identity verification process required under applicable anti-money laundering and responsible gambling obligations.

Data We Collect

Retrotogel collects personal data through several channels, including account registration, payment processing, KYC verification, customer support interactions, and automated technical collection during your use of the Platform. The categories of data we collect are detailed below.

3.1 Data You Provide Directly

• Full legal name and date of birth
• Email address and contact phone number
• Malaysian NRIC number, Passport number, or equivalent government-issued identification
• Residential address (including postcode and state)
• Payment account details — including Touch 'n Go eWallet account identifiers, Boost account details, DuitNow/FPX registered bank account numbers, Maybank/CIMB/Public Bank/RHB/Hong Leong account references, and cryptocurrency wallet addresses where applicable
• Account credentials (username; passwords are stored exclusively in encrypted, hashed form — we never retain plaintext passwords)
• Communications you send to our support team, including chat logs and email correspondence

3.2 Data Collected Automatically

• IP address and approximate geolocation
• Device type, operating system, and browser type and version
• Session duration, pages visited, and navigation patterns within the Platform
• Game play history, betting activity, wagering volumes, and transaction logs
• Login timestamps and access logs
• Cookie identifiers and similar tracking technologies (see Section 7)

3.3 Data Received from Third Parties

• Identity verification results from accredited KYC service providers
• Payment status confirmations and transaction references from payment processors including FPX, DuitNow, and e-wallet operators
• Fraud risk scores from third-party fraud detection services where applicable

How We Process Your Data

The following table summarises the primary purposes for which Retrotogel processes your personal data, the categories of data involved, and the applicable legal basis for each processing activity.

Legal Basis for Processing

Retrotogel processes personal data only where a valid legal basis exists. The four primary legal bases we rely upon are as follows:

• Contractual Necessity: Processing is necessary to perform our contractual obligations to you as a registered player — including account management, game access, deposit processing, and withdrawal fulfilment. Without this processing, Retrotogel cannot provide its services to you.
• Legal Obligation: Certain processing activities are required by applicable law, including anti-money laundering (AML) regulations, know-your-customer (KYC) requirements, and responsible gambling obligations. Retrotogel cannot waive these obligations regardless of player preference.
• Legitimate Interests: Some processing is carried out on the basis of Retrotogel's legitimate interests — including fraud prevention, platform security, and aggregate analytics — provided those interests are not overridden by your rights and freedoms.
• Consent: Where processing is based on your consent — including promotional email communications — you retain the right to withdraw that consent at any time by contacting our support team or adjusting your account communication preferences. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Disclosure

Retrotogel does not sell, rent, or commercially exploit your personal data. We share personal data only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose.

• Payment Processors: We share transaction-relevant data with accredited payment processors and banking partners — including FPX operators, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, and major Malaysian banks (Maybank, CIMB, Public Bank, Hong Leong Bank, RHB) — solely for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: We engage accredited third-party KYC service providers to verify player identities. Verification data is shared with these providers under strict data processing agreements and used solely for verification purposes.
• Fraud Prevention Services: Where fraud risk is identified, transaction and device data may be shared with accredited fraud detection providers to assess and mitigate risk.
• Game Technology Providers: Game-play data (but not financial or identity data) may be shared with licensed game software providers for the purposes of game delivery, dispute resolution, and technical support.
• Legal and Regulatory Authorities: Retrotogel will disclose personal data to competent legal or regulatory authorities where required to do so by applicable law, court order, or regulatory direction — including disclosures required under anti-money laundering obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of Retrotogel's assets, your personal data may be transferred to the acquiring entity. Affected players will be notified of any such transfer and the resulting change in data controller.

Cookies & Tracking Technologies

The Retrotogel Platform uses cookies and similar tracking technologies to enable essential Platform functionality, maintain your session, and provide analytics information that helps us improve our services. The categories of cookies we deploy are as follows:

• Strictly Necessary Cookies: These cookies are required for the Platform to function and cannot be disabled. They include session management cookies, authentication tokens, and security cookies that protect against cross-site request forgery. No consent is required for these cookies as they are essential to service delivery.
• Functional Cookies: These cookies remember your preferences — such as language settings and last-used payment method — to provide a more personalised experience. Disabling these cookies may affect certain Platform features.
• Analytics Cookies: We use analytics cookies to collect aggregate, anonymised data about how players use the Platform — including page visit frequency, session duration, and navigation paths. This data helps us identify areas for improvement. Analytics data is not linked to individual player identities.
• Marketing Cookies: Where you have consented, marketing cookies may be used to track promotional campaign effectiveness. You may withdraw consent for marketing cookies at any time through your browser settings.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may impair the functionality of the Platform. Retrotogel does not respond to "Do Not Track" browser signals at this time, as no uniform standard for such signals has been adopted.

Data Retention

Retrotogel retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. Retention periods vary by data category and are summarised below:

• Account and identity data: Retained for the duration of your account's active status and for a minimum of five (5) years following permanent account closure, in accordance with applicable anti-money laundering record-keeping obligations.
• Transaction and financial records: Retained for a minimum of seven (7) years from the date of the relevant transaction, in compliance with applicable financial record-keeping requirements.
• KYC verification documents: Retained for a minimum of five (5) years from the date of account closure or the date of the last transaction, whichever is later.
• Customer support correspondence: Retained for three (3) years from the date of the last communication, or for the duration of any unresolved dispute.
• Marketing preferences and consent records: Retained for the duration of your account's active status and for one (1) year following account closure.
• Analytics data: Aggregate, anonymised analytics data may be retained indefinitely as it no longer constitutes personal data.

Upon the expiry of the applicable retention period, personal data is securely deleted or permanently anonymised in accordance with our data destruction procedures.

Data Security

Retrotogel implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the Retrotogel Platform is encrypted using industry-standard 256-bit SSL encryption.
• Password Protection: Account passwords are stored exclusively in hashed, salted form using modern cryptographic hashing algorithms. Retrotogel never stores, views, or transmits plaintext passwords.
• Access Controls: Access to personal data within Retrotogel's internal systems is restricted on a need-to-know basis, with role-based access controls and activity logging for all staff with data access.
• Regular Security Audits: The Platform undergoes periodic security assessments, including vulnerability scanning and penetration testing, to identify and remediate potential security risks.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication on their accounts for additional protection against unauthorised access.

Notwithstanding these measures, no method of electronic transmission or storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security. Players should ensure their own devices and credentials are adequately protected.

Your Rights as a Data Subject

Subject to applicable law, you hold the following rights with respect to your personal data held by Retrotogel. To exercise any of these rights, contact our support team using the details in Section 14.

• Right of Access: You have the right to request confirmation of whether Retrotogel holds personal data about you, and to obtain a copy of that data along with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. For basic account details, you may update these directly from your account profile.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where processing is unlawful. Note that this right is subject to overriding legal and regulatory retention obligations — Retrotogel may be required to retain certain data notwithstanding an erasure request.
• Right to Restriction of Processing: You may request that we restrict the processing of your data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests. Where you object, Retrotogel will cease the relevant processing unless compelling legitimate grounds exist that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Retrotogel will respond to verified data subject rights requests within 30 calendar days. In complex cases, this period may be extended by a further 30 days, and you will be notified accordingly.

Minors & Age Policy

The Retrotogel Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect or process personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account.

Retrotogel employs age verification controls during registration and through its KYC process to prevent underage access. Parents and guardians who believe their child has registered on the Platform should contact our support team immediately. We will investigate and take appropriate action without delay.

International Data Transfers

Retrotogel operates as an international platform, and your personal data may be transferred to and processed in jurisdictions outside Malaysia. Where such transfers occur, Retrotogel ensures that appropriate safeguards are in place to protect your data at a standard equivalent to the protections described in this Policy.

Safeguards for international data transfers may include contractual data protection clauses between Retrotogel and the receiving entity, transfer to jurisdictions recognised as providing adequate data protection, or other legally recognised transfer mechanisms. Data transfers to third-party payment processors — including those facilitating Malaysian payment methods — are governed by the data protection commitments of those processors under applicable financial regulation.

Amendments to This Policy

Retrotogel reserves the right to update or amend this Privacy Policy at any time. Where material changes are made, we will endeavour to notify registered players through an on-Platform notification or email communication with reasonable prior notice.

The date of the most recent revision is displayed at the top of this page. Continued use of the Retrotogel Platform following the effective date of any revised Policy constitutes your acceptance of those changes. Players are encouraged to review this Policy periodically.

Contact Us

For any queries, requests, or concerns relating to this Privacy Policy or the processing of your personal data by Retrotogel, please contact our Data Protection team through the following channels. All data subject rights requests and privacy-related enquiries will be handled with priority.

• Live Chat: Available 24/7 directly on the Retrotogel Platform — fastest channel for urgent enquiries, with an average response time under 2 minutes.
• Email: [email protected] — please include "Privacy Request" in the subject line, along with your registered username and the nature of your request. We aim to acknowledge all privacy requests within 3 business days and resolve them within 30 days.

When submitting a data subject rights request, please include sufficient information to allow us to verify your identity. We may request additional verification — such as a copy of your registered ID — before processing requests that could affect account access or data disclosure.