Privacy Policy SBOTOP Malaysia

Welcome to SBOTOP's Privacy Policy page. At SBOTOP, we understand that entrusting your personal information to an online platform requires a great deal of confidence. That is why we take every aspect of data protection seriously — not merely to comply with the law, but because it is our moral responsibility to every member who joins the SBOTOP community in Malaysia.

This Privacy Policy clearly and transparently explains how we collect, store, use, and protect your personal information when you register for and use SBOTOP services. It also outlines your rights as a data owner and how you may exercise those rights.

SBOTOP collects your personal information through several different channels throughout your relationship with our platform. Understanding how this collection occurs helps you make more informed decisions about the information you share with us.

Direct Collection

Information is collected directly when you interact with SBOTOP, including during the account registration process, identity verification (KYC), financial transaction processing, use of platform features, and communications with our customer support team via live chat or email.

Automatic Collection

Some information is collected automatically when you use our platform. This includes technical data such as IP address, web browser type, device information, approximate location data, game activity records, and transaction logs. This automatic collection is essential for ensuring account security and preventing fraud.

Information from Third-Party Sources

In certain situations, we may receive information from trusted payment service providers, identity verification agencies, or regulatory authorities for legal compliance purposes. All information received from these external sources is handled to the same security standards as data you provide directly.

Below is a comprehensive overview of the categories of personal data we may collect from you when using SBOTOP services:

Every piece of data we collect has a clear and legitimate purpose. SBOTOP uses your personal information for the following purposes, and we will not use your data for any other purpose without informing you first:

• Account Management: To register, verify, and manage your account, including processing registration applications, verifying identity, and ensuring the security of your account at all times.
• Transaction Processing: To process deposits, withdrawals, and all other financial transactions efficiently and securely via supported payment methods including FPX, bank transfer, Touch 'n Go eWallet, GrabPay, and Boost.
• Legal & Regulatory Compliance: To fulfil our obligations under the Personal Data Protection Act 2010 (PDPA), anti-money laundering (AML) requirements, KYC procedures, and other relevant regulatory laws.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, platform abuse, collusion, and any attempts to compromise the integrity of our games or financial systems.
• Customer Support: To respond to your enquiries, resolve complaints, provide technical assistance, and ensure a satisfactory user experience.
• Service Improvement: To analyse usage patterns, identify areas for improvement, and develop better new features for our members.
• Marketing Communications: To send information about promotions, bonuses, and special offers — but only if you have given consent to receive such communications.

Each data usage purpose is supported by a valid legal basis — whether your consent, contractual necessity, legal obligation, or SBOTOP's legitimate interests that do not override your privacy rights.

SBOTOP does not sell, rent, or trade your personal data. However, in the course of operating the platform, there are limited situations where we need to share certain information with trusted third parties. All such sharing is subject to strict data protection agreements.

• Payment Service Providers: Required transaction information is shared with licensed payment providers such as banks, digital wallet operators and payment gateways to facilitate the processing of your deposits and withdrawals.
• Game Service Providers: Relevant game data is shared with our game software providers to ensure proper game functionality, wagering settlement, and wins verification.
• Regulatory Authorities: SBOTOP will disclose required information to legal or regulatory authorities when mandated by law or a valid court order.
• Technical Service Providers: Cloud infrastructure providers, cybersecurity services and data analytics providers acting as data processors under our instruction and subject to strict confidentiality agreements.

SBOTOP does not share your personal data with third-party advertisers or marketing analytics companies without your explicit consent. If you have previously agreed to receive marketing communications from our partners, you may withdraw that consent at any time through your account settings.

Protecting your personal data from unauthorised access, loss or damage is SBOTOP's highest priority. We continuously invest in the latest security technologies and procedures to ensure comprehensive protection:

• Data Encryption in Transit: All communication between your device and SBOTOP's servers is protected by TLS 1.3 protocol with AES-256 encryption, the standard used by global banking and financial institutions.
• Data Encryption at Rest: Sensitive personal data is stored in encrypted format within our databases, ensuring it remains unreadable even in the event of unauthorised access.
• Multi-Layer Access Control: Access to member personal data is strictly limited to staff with a legitimate operational need. All access is logged and regularly audited.
• 24/7 Security Monitoring: Our automated monitoring system operates continuously to detect suspicious activity, intrusion attempts, and any security threats in real time.
• Regular Security Testing: SBOTOP conducts regular penetration testing and security audits by independent cybersecurity experts to identify and patch any vulnerabilities.
• Incident Response Plan: We have established incident response procedures to address any data breaches swiftly and to notify affected members in accordance with legal requirements.

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and SBOTOP's privacy policy, you have the following rights regarding your personal data. We are committed to facilitating the exercise of these rights without unnecessary obstacles:

To exercise any of the above rights, please contact the SBOTOP customer support team. We will process your request within 30 business days. Please note that some data deletion requests may not be fully processed if the data is required for legal compliance or ongoing dispute resolution.

SBOTOP uses cookies and similar tracking technologies to enhance your user experience, maintain session security, and analyse how our platform is used. The following 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 as the platform will not function properly without them.
• Functional Cookies: Stores your preferences such as language selection, display settings and saved login information (if you choose to do so).
• Analytics Cookies: Helps us understand how members use the platform, the most frequently visited pages and navigation patterns. This data is used in aggregated and anonymised form.
• Security Cookies: Used to detect suspicious activity, prevent fraud, and ensure your login sessions remain secure at all times.

You can manage cookie settings through your web browser at any time. However, disabling certain cookies may affect the functionality and user experience of the SBOTOP platform. For more information on managing cookies, please refer to your web browser's help guide.

SBOTOP does not retain your personal data longer than is necessary for the purposes for which it was collected, or as required by law. The following are our data retention period guidelines:

• Active Account Data: Retained for the duration your account is active and in use. This data is required for account management, legal compliance, and the resolution of any disputes that may arise.
• Financial Transaction Data: Transaction records are retained for a minimum of 7 years after the transaction occurs, in compliance with Malaysia's financial and tax legal requirements.
• KYC Documents: Identity verification documents are retained for 5 years after the business relationship is terminated, in accordance with applicable anti-money laundering (AML) requirements.
• Communication Logs: Customer support communication records are retained for 2 years for quality control and dispute resolution purposes.
• Inactive Account Data: Accounts inactive for 3 years will be archived. After a 2-year archival period, data no longer required for legal compliance will be securely deleted.

When your data is no longer needed, SBOTOP will securely delete it using methods that ensure it cannot be recovered. For physical data, we use certified secure destruction methods.

SBOTOP reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or service improvements. We are committed to notifying you of any significant changes.

• Material amendments will be communicated via email notification to your registered email address at least 14 days before the amendment takes effect.
• Amendment notices will also be prominently displayed on the SBOTOP platform homepage and at the top of this Privacy Policy page.
• The "Updated" date at the top of this page will always reflect the date the latest amendment takes effect.
• For minor amendments such as spelling corrections or clarifications that do not alter the intent of the policy, changes may take effect immediately without prior notice.
• Continued use of the SBOTOP platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this page regularly to stay informed of our latest privacy practices. A version history of the Privacy Policy is available upon request.

If you have any questions, concerns, or complaints regarding how SBOTOP handles your personal data, our privacy team is ready to assist. We take every privacy-related enquiry seriously and strive to provide a satisfactory response in a timely manner.

• Privacy Email: [email protected] (label your email subject with "Privacy Enquiry" for faster handling)
• Live Support: Via the live chat feature within the SBOTOP platform, available 24/7
• Response Time: We aim to respond to all privacy-related enquiries within 5 business days
• Official Complaints: If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia.