Javtogel Privacy Policy – Our Commitment to Protecting Malaysian Members' Data

01Introduction and Scope of This Policy

This Privacy Policy is published by Javtogel, an online casino gaming platform operating under the domain javtogel.fun and catered specifically to users in Malaysia. This document sets out in detail how Javtogel collects, processes, uses, stores and protects your personal information as a member or visitor of our platform.

This Privacy Policy covers all your interactions with Javtogel, including account registration, gameplay activity, financial transactions via DuitNow, FPX, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay and other Malaysian payment methods, communications with customer support, participation in promotional programmes and VIP Rewards, and general use of the platform through a web browser or mobile application.

By registering for or using Javtogel's services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, you should not use our platform. This Privacy Policy should be read together with the Terms & Conditions Javtogel, which forms part of the overall agreement between you and the platform.

02Types of Personal Data We Collect

Javtogel collects your personal information through several different methods depending on the nature of your interaction with the platform. Below are the categories of data we collect and their respective purposes:

For the Know Your Customer (KYC) process required for withdrawals exceeding certain thresholds or when flagged by the monitoring system, Javtogel may request additional documents such as a copy of your identity card, a utility bill as proof of address, or a screenshot of your bank account details to verify ownership of the payment method used.

03How We Use Your Personal Data

Javtogel uses personal information collected for specific, legitimate and transparent purposes. Your data is never used for purposes unrelated to the provision of services to you. The following are the primary purposes of use:

• Account management – creating, maintaining and managing your Javtogel account, including identity verification and password management.
• Transaction Processing – processing deposits via DuitNow, FPX, Maybank2u, CIMB Clicks, Touch 'n Go eWallet, GrabPay, Boost, and ShopeePay, as well as withdrawals to your account.
• Gaming Service Provision – enabling you to play slots, Live Casino, Malaysia Super League and EPL football betting, lottery and other games available on the platform.
• VIP Rewards Programme – calculating and crediting weekly cashback, loyalty points, upgrade bonuses and other VIP benefits based on your gaming activity.
• Customer support – processing enquiries, complaints, and technical support requests submitted via live chat or email.
• Security and fraud prevention – detecting and preventing fraudulent activity, money laundering, account abuse, and unauthorised access.
• Legal compliance – meeting the reporting and compliance obligations required under applicable Malaysian law.
• Service improvement – analysing usage patterns to improve the platform's interface, performance, and overall experience.
• Service communications – sends important notifications regarding your account, changes to terms or conditions, and security updates.

If you have consented to receive marketing communications, we may use your email address or phone number to notify you of promotions, bonuses, and exclusive offers relevant to the game types you enjoy at Javtogel. This consent may be withdrawn at any time through your account settings or by contacting customer support.

04Legal Basis for Data Processing

Javtogel processes your personal data on valid legal grounds in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and its associated regulations. Each category of data processing has a specific legal basis:

• Contract Performance – processing required to provide the services you request upon registering as a Javtogel member, including transaction processing and account management.
• Legitimate interest – processing for the purposes of fraud prevention, platform security, and service improvement, where those interests do not override your privacy rights.
• Legal compliance – processing required to fulfil legal obligations under Malaysian law, including anti-money laundering requirements and related reporting.
• Consent – processing for direct marketing and promotional communications, which only occurs where you have given explicit, withdrawable consent.

05Data Sharing with Third Parties

Javtogel does not sell member personal data to any third party. This is an unwavering commitment with no exceptions. That said, to deliver our services effectively, we may share only the minimum necessary data with the following categories of service partners:

• Payment Service Providers – payment gateways processing DuitNow, FPX, and Malaysian eWallet transactions receive only the minimum data necessary to complete the relevant transaction.
• Game software providers – companies such as Pragmatic Play, PG Soft and Evolution Gaming receive the minimum technical data required to deliver games and process game results.
• Technical service providers – companies providing server infrastructure, cybersecurity systems, and analytics tools, all of which are bound by strict data confidentiality agreements.
• Legal authority – Javtogel will only disclose data to Malaysian authorities when lawfully required to do so by a court order or applicable legal directive.

06Data Storage and Retention Periods

Javtogel retains your personal data for as long as necessary to fulfil the purposes outlined in this policy and to comply with applicable legal obligations. Retention periods vary by data type:

• Active account data – retained for as long as your account remains active with Javtogel.
• Financial transaction records – retained for a minimum of 7 years from the transaction date, in accordance with Malaysian financial legal requirements.
• Customer support communication records – retained for 2 years from the date of communication for reference and dispute resolution purposes.
• Gaming Activity Log – retained for 3 years for analytics, fraud prevention, and compliance purposes.
• KYC and identity verification data – retained for 5 years after account closure in accordance with anti-money laundering requirements.
• Closed accounts – following a deletion request, data not subject to legal retention obligations will be deleted within 90 days.

Once the retention period expires, data is securely deleted or anonymised using verified data deletion procedures. Anonymised data — that which can no longer be used to identify a specific individual — may be retained for aggregate analytics purposes.

07Javtogel Data Security Measures

Javtogel implements a comprehensive range of technical and operational security measures to protect members' personal data against unauthorised access, disclosure, alteration or accidental or malicious destruction.

• Data encryption in transit – all communication between the platform and your device uses TLS 1.3 with AES-256 encryption, the highest industry standard currently available.
• Data encryption at rest – sensitive data in the database is stored in encrypted form, meaning that even if the physical server is accessed without authorisation, the data remains unreadable.
• Role-based access control – Javtogel staff may only access data that is relevant to their specific job responsibilities. Marketing managers cannot access full transaction records, and vice versa.
• Two-factor authentication (2FA) – all internal administrative access to systems containing user data is protected by mandatory two-factor authentication.
• Continuous threat monitoring – a 24-hour intrusion detection system monitors suspicious activity and alerts the security team in real time.
• Periodic security audits – penetration testing and independent security audits are conducted regularly by certified third parties to identify and remediate vulnerabilities before they can be exploited.
• Incident response plan – Javtogel maintains documented security incident response procedures. In the event of a significant data breach, affected members will be notified within 72 hours of the incident being identified.

08Cookies and Tracking Technologies

The Javtogel platform uses cookies and similar tracking technologies to enhance the user experience, maintain session security, and collect aggregated analytics data on platform usage. The following types of cookies are used:

You can manage your cookie settings through your web browser. Most browsers allow you to view, delete, or block cookies. Please note that disabling essential cookies may affect your ability to log in or use certain features of the Javtogel platform.

09Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010, you as a data subject have the following rights regarding your personal data held by Javtogel. All requests relating to these rights will be processed within 30 business days:

To exercise any of the above rights, contact the Javtogel privacy team at support@javtogel.fun with the subject line "Privacy Rights Request" and specify the particular right you wish to exercise along with the information needed to verify your identity. We will not charge for reasonable requests, though excessive or unfounded requests may be subject to a reasonable administrative fee.

10Cross-Border Data Transfers

In the course of platform operations, Javtogel may process or store personal data on servers located outside Malaysia, particularly in connection with the use of gaming software from international providers such as Pragmatic Play, PG Soft and Evolution Gaming, which maintain global server infrastructure.

Any transfer of personal data outside Malaysia is carried out only when the following conditions are met:

• The receiving country or territory provides a level of data protection equivalent to or greater than that required under Malaysian law.
• Appropriate data transfer agreements have been put in place with data recipients to ensure adequate protection.
• Transfers are limited to the minimum data necessary for the stated purpose.

If you would like to know more about the safeguards used for cross-border data transfers, you can reach us at support@javtogel.fun.

11Changes to This Privacy Policy

Javtogel reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements or technological developments. Any changes made will be published on this page with a new "Updated" date.

For material changes – meaning changes that significantly affect how we use your data or your privacy rights – Javtogel will send notifications to all active members via their registered email and in-account messages at least 14 days before those changes take effect. This gives you sufficient time to review the changes and make an informed decision.

12Contact Javtogel's Privacy Officer

If you have any questions, concerns, or complaints about how Javtogel handling your personal data, or if you wish to exercise any of the privacy rights outlined in this policy, our privacy team is ready to assist you.

• Privacy Email: support@javtogel.fun – please use the subject line "Data Privacy" to ensure your email reaches the right team.
• Live Chat: Available on the Javtogel platform 24 hours a day, 7 days a week in Bahasa Melayu.
• Response time: All privacy enquiries are acknowledged within 24 hours and resolved within 30 business days.

If you are not satisfied with how we have handled your privacy complaint after going through our internal process, you have the right to refer the matter to the Personal Data Protection Commissioner of Malaysia under the Personal Data Protection Act 2010.