To388 Privacy Policy – Member Personal Data Protection

1. Information We Collect

To388 collects various types of information from members to ensure the platform runs smoothly, securely, and delivers the best experience to every user. The information we collect falls into two main categories:

Information you provide directly:

• Full legal name as shown on your identification document.
• Date of birth for age eligibility verification (18 years and above).
• Active email address for account communications.
• Mobile phone number for two-factor authentication and communications.
• National identification number (MyKad) or passport for the KYC process.
• Bank account or e-wallet details for processing deposits and withdrawals.
• Residential address for KYC compliance purposes.

Information collected automatically:

• IP address and estimated geographic location.
• Device type, operating system, and web browser version.
• Access log data including dates, times, and pages visited.
• Cookie data and session identifiers.
• Game history and wagering activity on the platform.
• Financial transaction data including deposit amounts, withdrawals, and balances.

2. How We Collect Data

To388 collects your personal information through a variety of transparent and lawful channels:

• Account registration: Basic information is collected when you complete the registration form on the platform.
• KYC process: Identity verification documents are collected when your account reaches a threshold requiring full verification.
• Financial transactions: Payment details are collected when you make a deposit or submit a withdrawal request.
• Platform usage: Activity data is collected automatically via cookies, server logs, and tracking technologies while you use the platform.
• Support communications: Information you share when interacting with our customer support team via live chat or email.
• Profile updates: Any changes to your information made directly through your account settings.

3. Purpose of Data Use

All information we collect is used for clear and lawful purposes. Below is a summary of data usage purposes at to388:

To388 will not use your data for any purpose other than those stated above without first obtaining your consent.

4. Information Sharing

To388 operates on the principle that your personal data belongs to you. We only share your information in the following limited circumstances:

• Payment service providers: Transaction details that must be shared with providers such as FPX, DuitNow, Touch 'n Go eWallet, and Boost solely to process your payments.
• Game software providers: Game session data required by casino software or sports betting providers to ensure smooth gameplay — this information is shared on a limited basis and is protected by confidentiality agreements.
• Legal compliance: to388 may be required to disclose certain information to the relevant authorities when mandated by law, court order, or to prevent financial crime.
• Platform protection: In cases where the security of the platform or other members is at risk, relevant information may be shared with the parties responsible for addressing that threat.

In all of the above situations, to388 shares only the minimum necessary information and ensures that recipients comply with strict confidentiality obligations. to388 has never sold member personal data to any third party.

5. Data Security

Protecting your personal data from unauthorized access, loss, or misuse is to388's highest priority. The integrated security measures we employ include:

• 256-bit SSL encryption for all data in transit between your device and our servers.
• Data-at-rest encryption for all sensitive information stored in our database.
• Two-factor authentication (2FA) available for all member accounts as an added layer of protection.
• 24-hour monitoring by our cybersecurity team to detect and respond to any threats promptly.
• Role-based access control ensuring only authorised personnel can access member data relevant to their role.
• Regular security audits by independent third parties to evaluate and strengthen our data protection systems.

While we take all reasonable measures to protect your data, no security system can be guaranteed 100% secure. You also play an important role by keeping your to388 account password and login details confidential.

6. Data Retention Period

To388 retains your personal data only for as long as necessary to fulfil the original purpose of collection and to comply with relevant legal obligations.

• Active account data: Retained for the duration your account remains active and in use.
• Data after account closure: Account and transaction records are retained for a minimum of 5 years after account closure to meet compliance and financial audit requirements.
• KYC Data: Identity verification documents are retained for the period prescribed by applicable anti-money laundering laws.
• Support communication logs: Live chat session records and support emails are retained for 2 years for reference and dispute resolution purposes.
• Cookie data: Session cookies expire when you close your browser; persistent cookies are stored for up to 12 months or until you delete them.

Once the retention period expires, your data will be securely deleted or anonymised in accordance with to388's established data disposal procedures.

7. Your Rights as a Data Subject

As a to388 member, you have the following rights regarding your personal data. Contact our support team via live chat to submit any request:

To388 will process your data rights request within 30 working days from the date the request is received. For complex cases, this period may be extended and you will be notified accordingly.

8. Cookies & Tracking Technologies

To388 uses cookies and similar tracking technologies to enhance your experience on the platform. Below are the types of cookies we use:

• Essential cookies: Required for core platform functions such as login, game sessions, and security. These cookies cannot be disabled.
• Performance cookies: Collecting anonymous information about how you use the platform to help us improve the user experience.
• Functional cookies: Remembering your preferences and settings such as language and display to personalize your experience.
• Analytics cookies: Helping us understand platform usage patterns in an aggregated and anonymous manner.

You can manage your cookie preferences through your web browser settings at any time. However, disabling essential cookies may affect platform functionality. By continuing to use to388 after the cookie notice is displayed, you consent to our use of cookies.

9. Third-Party Links

The to388 platform may contain links to third-party websites such as game software providers or payment partners. Please note that:

• To388 is not responsible for the privacy practices of any third-party websites you visit through links on our platform.
• Each third-party website has its own Privacy Policy governing the collection and use of your data on their platform.
• We encourage you to read the Privacy Policy of any third-party website before providing any personal information.

Links to external websites are provided solely for convenience and do not imply that to388 endorses or is responsible for the content or privacy practices of those websites.

10. Changes to This Privacy Policy

To388 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or service improvements.

When material changes are made to this Policy, we will:

• Updating the "Last Updated" date at the top of this page.
• Posting a clear notice on the platform at least 7 days before changes take effect.
• Sending a notification to your registered email for highly material changes.

Your continued use of the to388 platform after any Privacy Policy changes take effect constitutes your acceptance of the updated Policy. It is your responsibility to review this page periodically.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how to388 handles your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the to388.fun platform — the fastest way to get a response.
• Email: [email protected] — we aim to respond within 1 to 2 business days.
• FAQ: Visit page FAQ our FAQ section for answers to common questions about privacy and your account.

For official requests regarding your personal data rights such as access, correction, or deletion, please clearly state the type of request and include your account number to expedite the verification and response process.