Mytown88 Privacy Policy – Personal Data Protection for Malaysian Members

1Personal Data We Collect

1.1 Data You Provide Directly

When you register and use your mytown88 account, we collect the following information that you provide voluntarily:

• Identity Information: Full name as per MyKad, Malaysian identity card number, date of birth, and gender.
• Contact Information: An active Malaysian mobile number and a valid email address.
• Account Security Information: Username, password (stored as an unreadable hash) and security questions if set.
• Verification Documents: A copy of your MyKad image is requested only during the KYC (Know Your Customer) process for your first withdrawal or when certain limits are reached.

1.2 Automatically Collected Data

When you use the mytown88 platform, our systems automatically collect the following technical data for security, fraud detection, and service improvement purposes:

• Device Data: Device type, operating system, phone model, and browser version.
• Network Data: IP address, internet service provider (ISP), and geographic location at the city/state level (not precise GPS location).
• Session Data: Login and logout times, session duration, and pages visited within the platform.
• Game Activity Data: Betting records, game results, and deposit and withdrawal transaction history.

2How We Use Your Data

Mytown88 uses your personal data solely for purposes related to operating the platform and delivering services to you as a member. We do not use your data for any purpose unrelated to the service relationship between you and mytown88.

2.1 Platform Operation Purposes

• Creating and managing your mytown88 account and keeping it secure.
• Processing deposits via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX, Maybank2u and CIMB Clicks, as well as processing your winnings withdrawals.
• Verifying your identity during the KYC process to ensure compliance with anti-money laundering (AML) laws.
• Identifying and preventing fraudulent activity, multi-account manipulation, or any activity that violates mytown88's Terms & Conditions.
• Providing customer support in Bahasa Malaysia 24 hours a day, 7 days a week.

2.2 Service Improvement Purposes

• Analyzing platform usage patterns in aggregate (not at an individual level) to understand which features are most used and which need improvement.
• Developing new features relevant to Malaysian players, such as integrating new local payment methods or launching new Sports Betting markets.
• Resolving technical issues and ensuring platform stability during peak periods such as EPL match nights or Malaysia Super League weekends.

3Data Sharing with Third Parties

Mytown88 does not sell, rent, or trade members' personal data to anyone. However, in the course of operating the platform, we may share certain information with a limited and controlled set of third-party categories as follows:

3.1 Payment Service Providers

To process your deposits and withdrawals, the required information is shared with certified and audited payment gateways. These providers receive only what is necessary to complete the transaction — they do not receive game records, betting history, or personal information beyond what the transaction requires. All payment providers working with mytown88 are bound by strict confidentiality agreements.

3.2 Malaysian Legal Authorities

Mytown88 will comply with any lawful request from Malaysian authorities including the police, courts, Securities Commission, or any regulatory body with relevant jurisdiction. In such situations, we will only disclose the information specifically requested and within the required scope — nothing beyond that.

3.3 Technology Service Providers

To operate the platform, mytown88 works with technology service providers such as cloud computing services, fraud detection systems, and platform analytics tools. All providers are bound by strict data processing agreements and may only use data for the specific services they are engaged to provide. They are not permitted to use your data for their own purposes.

4Data Security Measures

The security of your personal data is a priority at mytown88 that has never been compromised. We consistently invest in security infrastructure to ensure your data is protected at every stage — in transit, in processing, and at rest.

4.1 Technical Security

• 256-bit SSL/TLS Encryption: All communications between your device and mytown88 servers are fully encrypted. No data is transmitted as readable plain text.
• Encrypted Password Storage: Your password is never stored in plain text. The system uses a one-way bcrypt hashing algorithm to store your credentials in a form that cannot be reversed.
• Two-Factor Authentication (2FA): An additional security layer available and recommended for all mytown88 accounts. 2FA sends a unique code to your phone each time a login from a new device is detected.
• Intrusion Detection System (IDS): Round-the-clock, 24-hour monitoring for unauthorised access attempts, brute force attacks, and other suspicious activity on the platform.
• Data Segregation: Member personal data is stored in an environment isolated from the platform's technical operational data, reducing the risk of accidental exposure.

4.2 Organisational Security

Internal staff access to mytown88 members' personal data is strictly controlled on a need-to-know basis. Only staff who require access to specific data to perform their duties are permitted to do so. All access is logged and periodically audited by mytown88's internal security team.

5Cookies and Tracking Technologies

5.1 What Are Cookies?

Cookies are small text files stored on your device when you visit or use the mytown88 platform via a browser. They allow the platform to remember your preferences, maintain your login session, and understand how you use the platform in order to improve it.

5.2 Types of Cookies Used by mytown88

• Session Cookies: Required to maintain your login session while you are using the platform. These cookies are automatically deleted when you close your browser or log out. Without them, you would need to log in again every time you navigate to a new page.
• Preference Cookies: Saves your preferences such as language selection and display settings, so you don't have to reconfigure them every time you use the platform.
• Security Cookies: Helps detect unauthorized access attempts and protects your account against attacks such as CSRF (Cross-Site Request Forgery).
• Analytics Cookies: Collects aggregated information about how users interact with the platform — not at an individual level. This data is used to improve the overall user experience.

5.3 Managing Cookies

You can manage and delete cookies through your browser settings. Keep in mind, however, that disabling session and security cookies will affect core functionality on the mytown88 platform — you may be unable to stay logged in or use important security features. Analytics cookies can be turned off without impacting your ability to use the platform.

6Data Retention and Deletion

6.1 Retention Period

Mytown88 retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required under applicable Malaysian law. In general:

• Financial transaction records are retained for a minimum of 7 years in accordance with Malaysian accounting and audit legal requirements.
• Identity verification (KYC) records are retained for the duration of the active account plus 5 years after account closure for anti-money laundering compliance purposes.
• Login data and session activity are retained for 12 months for security and fraud detection purposes.
• Customer support communications are retained for 3 years for quality control and dispute resolution purposes.
• Platform analytics data is retained in aggregate form without personal identifiers for an indefinite period for product development purposes.

6.2 Account Deletion

When you request closure of your mytown88 account, personal data that is not required to be retained by law will be deleted or anonymised within 30 days of the account being officially closed. Records that must be kept by law will be retained for the periods stated above, but will be segregated and access to them strictly limited.

7Your Rights Under PDPA 2010

As a mytown88 member who is a Malaysian citizen or resident, you have the following rights under the Personal Data Protection Act 2010 regarding your personal data held by mytown88:

8Marketing Communications

8.1 Types of Communications We Send

Mytown88 may send you communications via SMS or email, covering two distinct categories:

• Service Communications (Mandatory): Account-related notifications such as deposit confirmations, withdrawal confirmations, security alerts, password changes, and other important account notices. These communications cannot be unsubscribed from as they form part of the core mytown88 service you have signed up for.
• Marketing Communications (Optional): Information about new promotions, seasonal bonuses such as Hari Raya and Chinese New Year offers, new games, and mytown88 platform updates. These communications are optional and you may opt out at any time.

8.2 How to Opt Out of Marketing

To stop receiving marketing communications from mytown88, you may use any of the following methods: click the "unsubscribe" link at the bottom of any marketing email; go to "Account Settings > Communication Preferences" within the mytown88 platform and disable marketing options; or contact our support team at support@mytown88.xyz with a request to opt out of marketing communications. Changes will take effect within 5 business days.

9Cross-Border Data Transfers

Mytown88 operates primarily in Malaysia and prioritizes infrastructure based locally or within the Southeast Asian region. However, given the cloud computing services and global technologies used to run the platform, data may at times be processed or temporarily stored outside Malaysia.

In such circumstances, mytown88 ensures that any cross-border data transfers occur only to countries or providers that offer a level of data protection equivalent to or exceeding the standards of Malaysia's PDPA 2010. All agreements with cloud service providers involving data processing outside Malaysia are supported by contractual data protection clauses that bind those providers to the privacy standards set by mytown88.

10How to Contact Us About Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by mytown88, please reach out to us through the following channels:

• Privacy Email: support@mytown88.xyz (use the subject line "Privacy Enquiry" to ensure it is handled by the right team)
• Live Chat: Available 24 hours a day on the mytown88 platform — the fastest option for general privacy enquiries
• Response Time: Privacy inquiries are responded to within 3 business days; formal privacy rights requests are resolved within 14 business days

If you are not satisfied with how mytown88 has handled your privacy request after exhausting all internal channels, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia, appointed under PDPA 2010.