Exototo Privacy Policy – Personal Data Protection for Malaysia Members

1Introduction and Scope of This Privacy Policy

Exototo, operating under the domain exototo.wine, is fully committed to protecting the privacy and personal data security of every member who uses our platform. This Privacy Policy is designed to ensure you clearly understand your rights and how we manage the information you share with us.

This policy applies to all users of the exototo platform, including those who access it via the website at exototo.wine or through our mobile app. It covers all personal data collected during registration, platform use, financial transactions, and interactions with our customer support team.

We encourage you to read this document in full so you have a clear understanding of how exototo handles your data responsibly. If any section is unclear, our support team is ready to answer your questions.

2Types of Personal Data We Collect

Exototo only collects data that is strictly necessary to provide you with a safe, compliant, and quality service. The data we collect falls into two main categories:

Data You Provide Directly

• Full name as it appears on a valid identity document.
• Date of birth for age verification purposes (members must be 18 years of age or older).
• Email address and mobile number for account communications.
• Current residential address for legal compliance requirements.
• Bank account or e-wallet details for processing deposits and withdrawals.
• Identity verification documents (KYC) such as a copy of your national ID or passport.
• Any information you share when contacting customer support.

Automatically Collected Data

• IP address and device location data for security and fraud detection purposes.
• Device type, operating system, and web browser version used.
• Game activity logs including time, game type, and wagering values.
• Cookie and session data to enhance the user experience on the platform.
• Complete financial transaction records for audit and regulatory compliance.

3How exototo Uses Your Personal Data

All data collected by exototo is used responsibly and only for legitimate purposes. Below is a complete list of how we use your personal information:

• Account Management: Create, verify, and manage your member account, including the login process and identity verification.
• Transaction Processing: Process deposits and fund withdrawals securely and accurately to your registered bank account or e-wallet.
• KYC & AML Compliance: Meet legal requirements related to customer identity verification and anti-money laundering.
• Platform Security: Detect and block suspicious activity, fraud attempts, and unauthorized access to your account.
• Service Communications: Send important notifications regarding your account, transactions, security updates, and policy changes.
• Experience Enhancement: Analyze usage patterns to improve platform design, speed, and features you use.
• Customer Support: Provide relevant and accurate assistance when you contact the exototo support team.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and offer appropriate assistance.

Exototo does not use your data for any third-party marketing purposes without your consent. If you have agreed to receive promotional communications from us, you may withdraw that consent at any time through your account settings.

4Personal Data Processing Basis

Exototo processes your personal data on the following lawful bases:

• Contract Performance: Processing required to fulfill the service agreement between you and exototo, including account management and transaction processing.
• Legal Obligation: Processing required to comply with applicable Malaysian laws, including KYC and AML requirements set by financial authorities.
• Legitimate Interest: Processing for fraud detection, platform security, and prevention of illegal activity that protects the interests of all members.
• Consent: In certain situations such as marketing communications, we will request your explicit consent before processing your data.

5Sharing Data with Third Parties

Exototo does not sell, rent, or disclose your personal data to third parties for their own commercial purposes. However, there are certain situations where we need to share your information with the following parties:

• Payment Service Provider: Banks, FPX, DuitNow, and e-wallet providers that process your financial transactions. They only receive the data required to complete the relevant transaction.
• Regulatory Authority: Legal authorities, regulatory bodies, and enforcement agencies when required by applicable law.
• Technical Service Provider: Companies providing technical support services such as server infrastructure, cybersecurity, and platform analytics. They are bound by strict confidentiality agreements.
• KYC Service Provider: Third parties that assist with identity verification processes as required by law.

All third parties we work with are required to comply with data security standards equal to or exceeding those we uphold. We ensure that every instance of data sharing is carried out with appropriate safeguards.

6Data Storage and Security Measures

Exototo uses the latest security technology to ensure your personal data is always protected from unauthorized access, loss, or misuse.

• 256-bit SSL Encryption: All data transmitted between your device and exototo servers is protected with the highest level of bank-grade encryption.
• Secure Storage: Personal data is stored on servers protected by multi-layered access controls, advanced firewalls, and round-the-clock security monitoring.
• Restricted Access: Only exototo staff who require data access to carry out their authorized duties are permitted to access members' personal information.
• Two-Factor Authentication: exototo's internal systems are secured with two-factor authentication to prevent unauthorized access.

Your data retention period depends on the type of data and legal requirements. Generally, active account data is retained for the duration of the active account plus 5 years after account closure, to meet Malaysia's legal compliance requirements.

7Cookies and Tracking Technologies

Exototo uses cookies and similar tracking technologies to enhance your experience on our platform. The types of cookies we use are as follows:

• Essential Cookies: Required for core platform functions such as login session management and security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collect information about how you use the platform to help us identify areas for improvement.
• Functional Cookies: Save your preferences such as language and display settings to deliver a more personalized experience.
• Analytics Cookies: Help us understand overall usage patterns to plan platform improvements more effectively.

You can manage or disable cookies through your web browser settings. Please note that disabling certain cookies may affect the functionality and user experience of the exototo platform.

8Your Rights as an exototo Member

Exototo fully recognizes your rights regarding personal data. You have the right to:

To exercise any of the above rights, please contact the exototo support team via email at [email protected]. We will process your request within 30 business days.

9Links to Third-Party Sites and Services

The exototo platform may contain links or integrations with third-party services such as payment providers and game suppliers. It is important that you understand the following:

• The exototo privacy policy applies only to the platform and services operated directly by exototo.
• When you use third-party services integrated within our platform, your data may be subject to those third parties' privacy policies.
• Exototo is not responsible for the privacy practices or content of third-party websites or services.
• We encourage you to read the privacy policy of each relevant third party before using their services.

Exototo only works with trusted third parties that have undergone our security assessment process to ensure member data remains protected at all times.

10Amendments to This Privacy Policy

Exototo reserves the right to amend this Privacy Policy from time to time to reflect changes in laws, regulations, platform practices, or for other operational reasons. When we make significant changes:

• You will be notified via your registered email or in-platform notification at least 14 days before changes take effect.
• The "Last Updated" date at the top of this page will be updated to reflect the date of the most recent amendment.
• Continued use of the platform after the effective date constitutes your acceptance of the revised policy.

We encourage you to check this page periodically to stay informed about how exototo manages your personal data.

11Contact Us About Privacy

If you have any questions, concerns, or complaints regarding this Privacy Policy or how exototo handles your personal data, please do not hesitate to contact us:

• Privacy Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available on the platform 24 hours a day, 7 days a week
• Response Time: Within 3 business days for privacy-related inquiries

For common questions about your account and the platform, please visit our FAQ page first. You may also check our Terms and Conditions for more information on platform usage.