Privacy Policy — gt108

1 Introduction

gt108 ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all members and visitors who access our platform at https://gt108.lat. This Privacy Policy ("Policy") sets out in detail the manner in which gt108 collects, processes, stores, shares, and protects personal information in connection with the provision of our online sports betting, live casino, and gaming services to users in Malaysia and other permitted jurisdictions.

This Policy is to be read in conjunction with gt108's Terms & Conditions and Responsible Gambling Policy. By registering an account or using any service offered by gt108, you acknowledge that you have read this Policy in full and consent to the data processing practices described herein. If you do not agree with any provision of this Policy, you should not use the gt108 platform.

2 Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly, including but not limited to name, identification number, contact details, location data, and online identifiers.
• "Processing" means any operation performed on Personal Data, whether automated or manual, including collection, recording, organisation, storage, alteration, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means gt108, the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of gt108 under a data processing agreement.
• "Member" / "User" means any individual who has registered an Account on the gt108 platform or who accesses our services.
• "KYC" means Know Your Customer — the identity and age verification process required for account compliance and withdrawal processing.
• "Cookie" means a small text file placed on your device by a web server for the purpose of maintaining session state, analytics, or personalisation.

3 Personal Data We Collect

gt108 collects Personal Data in the following categories, depending on how you interact with our platform:

3.1 Registration Data

When you create a gt108 account, we collect: full legal name; date of birth; email address; mobile phone number; residential address (including city and state, e.g., Kuala Lumpur, Penang, Johor Bahru, Shah Alam); and chosen username.

3.2 Identity Verification (KYC) Data

To comply with our anti-money laundering and age verification obligations, we collect copies of government-issued identity documents (Malaysian MyKad / NRIC, passport, or equivalent), selfie photographs for biometric verification, and proof of address documentation where required.

3.3 Financial & Transaction Data

We collect records of all deposits and withdrawals, the payment methods used (e.g., Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, DuitNow, FPX), transaction amounts in MYR, and associated reference numbers. We do not store full payment instrument credentials (e.g., bank account numbers) on our servers.

3.4 Gaming Activity Data

We collect detailed records of all wagers placed, games played, betting markets accessed, bonus offers claimed, winnings and losses, and session durations. This data is used for account management, responsible gambling monitoring, and regulatory compliance.

3.5 Technical & Device Data

We automatically collect IP address; device type, model, and operating system; browser type and version; session timestamps; pages visited; and referring URL. This information is used for fraud prevention, security monitoring, and platform performance optimisation.

3.6 Communications Data

Records of your interactions with our customer support team (including live chat transcripts, email correspondence, and any complaints submitted) are stored for service quality and dispute resolution purposes.

4 How We Collect Personal Data

gt108 collects Personal Data through the following means:

• Directly from you — through account registration forms, KYC submission portals, deposit and withdrawal requests, and communications with our support team;
• Automatically — through cookies, server logs, and similar tracking technologies when you access and navigate the platform;
• From third-party payment processors — transaction confirmation data and payment status updates received from providers such as DuitNow, FPX, and e-wallet operators;
• From identity verification service providers — biometric matching results and document authenticity checks conducted by our KYC technology partners;
• From fraud detection services — risk scores and device fingerprinting data from third-party anti-fraud systems.

5 Purpose of Data Processing

gt108 processes your Personal Data for the following specific purposes:

1. Account registration and management — to create, maintain, and administer your gt108 Member account;
2. Identity and age verification — to confirm that you are aged 21 or above and are the person you claim to be, in accordance with our legal and regulatory obligations;
3. Payment processing — to facilitate MYR deposits and withdrawals via your chosen payment methods;
4. Service delivery — to provide access to sports betting markets, live casino games, slots, and other gaming products;
5. Responsible gambling monitoring — to identify early indicators of problem gambling behaviour and apply appropriate safeguards including account restrictions where necessary;
6. Anti-money laundering (AML) compliance — to monitor for and report suspicious financial transactions in accordance with our international licensing obligations;
7. Fraud prevention and security — to detect and prevent fraudulent account activity, bonus abuse, and unauthorised access;
8. Customer support — to respond to your enquiries, resolve disputes, and provide technical assistance;
9. Marketing communications — to send you promotional offers, personalised betting recommendations, and platform updates, where you have provided consent or where we have a legitimate interest in doing so;
10. Platform improvement — to analyse usage patterns and improve the design, performance, and features of the gt108 platform;
11. Legal compliance — to meet our obligations under applicable laws and the terms of our operating licence.

6 Legal Basis for Processing

gt108 processes your Personal Data on the following legal grounds, consistent with internationally recognised data protection principles:

• Contractual necessity — processing required to fulfil our obligations under the Member Agreement (Terms & Conditions) you enter into upon registration, including account management, payment processing, and service delivery;
• Legal obligation — processing required to comply with applicable laws, including AML obligations, KYC requirements, and age verification under our operating licence conditions;
• Legitimate interests — processing carried out for fraud prevention, security monitoring, responsible gambling surveillance, and platform analytics, where our interests do not override your fundamental privacy rights;
• Consent — processing for marketing communications and optional analytics cookies, where your explicit consent has been obtained and may be withdrawn at any time.

7 Data Sharing & Disclosure

gt108 does not sell your Personal Data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

7.1 Service Providers

We engage third-party service providers to assist with platform operations, including payment processors (e.g., DuitNow, FPX gateway operators, e-wallet providers), KYC and identity verification vendors, fraud detection services, cloud hosting providers, and customer support software operators. These providers are bound by data processing agreements and are not permitted to use your data for any purpose beyond the specific service they are contracted to provide.

7.2 Regulatory and Law Enforcement Authorities

We may disclose Personal Data to our licensing authority, law enforcement agencies, financial intelligence units, or other government bodies where we are required to do so by law, court order, or regulatory directive — including in connection with anti-money laundering investigations or the prevention of financial crime.

7.3 Corporate Transactions

In the event of a merger, acquisition, or sale of substantially all of gt108's assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections remaining in place.

8 International Data Transfers

gt108 operates using cloud infrastructure and service providers that may be located outside of Malaysia. Your Personal Data may therefore be transferred to, stored in, or processed in countries other than Malaysia. Where such transfers occur, gt108 ensures that appropriate safeguards are in place — including contractual clauses that require the receiving party to apply data protection standards equivalent to those applied by gt108 — prior to the transfer taking place.

If you have questions about the specific countries to which your data may be transferred, or the safeguards in place, you may contact our Data Privacy team at the address set out in Section 16.

9 Data Retention

gt108 retains your Personal Data for as long as necessary to fulfil the purposes for which it was collected, as follows:

Following expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with gt108's data disposal procedures.

10 Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. gt108 uses cookies and similar technologies (including web beacons and local storage) to enable platform functionality, maintain your session, and analyse how members use the site.

10.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the platform to function — these cannot be disabled. They include session authentication tokens and security cookies that prevent cross-site request forgery.
• Analytics Cookies: Used to understand how users navigate the platform (e.g., which pages are visited most, where users drop off). This data is aggregated and anonymised. We use analytics platforms that process data in accordance with privacy standards.
• Preference Cookies: Used to remember your settings and preferences, such as display language and notification preferences.

10.3 Managing Cookies

You may disable non-essential cookies at any time through your browser settings. Please note that disabling strictly necessary cookies will affect the functionality of the gt108 platform and may prevent you from logging in or placing wagers.

11 Your Data Rights

Subject to applicable laws and the exceptions permitted therein, gt108 Members have the following rights with respect to their Personal Data:

To exercise any of these rights, please contact our Data Privacy team as described in Section 16. We will respond to all valid requests within 30 calendar days. We may need to verify your identity before processing a data rights request.

12 Children's Privacy & Under-21 Policy

The gt108 platform is strictly for adults aged 21 and above. We do not knowingly collect Personal Data from individuals under the age of 21. If you believe that a person under 21 has registered an account or provided Personal Data to gt108, please contact us immediately at the address in Section 16. Upon verification, we will close the account and delete all associated Personal Data without undue delay.

gt108 employs age verification procedures at the point of registration and again during the KYC process to prevent underage access to gambling services. These controls include documentary age verification and, where appropriate, third-party age authentication services.

13 Security Measures

gt108 implements a multi-layered security framework to protect Personal Data against unauthorised access, loss, destruction, or alteration. Our technical and organisational measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit;
• AES-256 encryption for sensitive data stored at rest, including KYC documents;
• Role-based access controls ensuring that staff access Personal Data only to the extent required for their job functions;
• Two-factor authentication (2FA) for Member accounts and internal administrative systems;
• Regular penetration testing and vulnerability assessments conducted by independent security firms;
• 24/7 network monitoring and intrusion detection systems;
• Staff training on data protection and information security practices.

Notwithstanding these measures, no system is completely impenetrable. In the event of a data breach that poses a significant risk to your rights, gt108 will notify affected Members within the timeframe required by applicable law and take all necessary remediation steps.

14 Third-Party Links & Services

The gt108 platform may contain references to third-party services (such as payment gateway interfaces rendered during the deposit or withdrawal process). This Privacy Policy applies solely to data processed by gt108 directly. Third-party services accessed through or in connection with the platform are governed by their own privacy policies, for which gt108 bears no responsibility.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your gt108 account, including your e-wallet provider (e.g., Touch 'n Go, Boost, GrabPay) and your internet banking provider (e.g., Maybank2u, CIMB Clicks, Public Bank).

15 Amendments to This Policy

gt108 reserves the right to amend this Privacy Policy at any time in response to changes in applicable law, regulatory requirements, or our business practices. When material changes are made, we will notify registered Members by email or via an in-platform notification prior to the changes taking effect, and we will update the "Last updated" date at the top of this document.

Your continued use of the gt108 platform following notification of an updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with the updated Policy, you must cease using the platform and may request account closure in accordance with our Terms & Conditions.

16 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by gt108, please contact our Data Privacy team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week — accessible directly from your Member account dashboard. Average response time is under 5 minutes.
• Email: [email protected] — please include "Privacy Request" in the subject line. We aim to respond within 2 business hours for standard enquiries.
• Member Portal: Data access, rectification, and marketing opt-out requests can be initiated directly from the Privacy Settings section of your account dashboard.

When submitting a data rights request, please provide your registered email address and account username so we can verify your identity and locate your records. We will process all valid requests within 30 calendar days of receipt.