Privacy Policy 110r – Our Commitment to Protecting the Personal Data of Malaysian Members

This Privacy Policy applies to all users who register, browse, or use any part of the 110r — including the 110r.my website, online games, live casino services, payment systems, and customer support channels we provide.

110r is the data controller responsible for the processing of your personal data as described in this document. We fully comply with the Personal Data Protection Act 2010 (PDPA) Malaysia, which is the primary legal framework governing the collection and use of personal data in Malaysia.

We understand that Malaysians — whether from Kuala Lumpur, Penang, Johor Bahru, Kota Kinabalu, Kuching, or any other state — have every right to know how their information is managed. That is why we have written this Privacy Policy in plain, straightforward language, rather than legal jargon that most people would find confusing.

110r collects personal data from you in several different ways. Below is a detailed breakdown of the data categories we collect:

A. Data You Provide Directly:

• Full name as stated on your Malaysian identity card or official document
• Mobile phone number (active in Malaysia)
• The email address you used for registration
• Date of birth (for mandatory 18+ age verification)
• Current residential address in Malaysia
• Bank account or e-wallet details (such as Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow) registered for deposits and withdrawals
• Copies of identity documents (such as MyKad) submitted during the KYC (Know Your Customer) process

B. Data Collected Automatically During Platform Use:

• The IP address of the device you use to access the platform 110r
• Device type, operating system, and web browser version
• In-platform activity data — games played, session duration, bets placed
• Transaction information — total deposits, withdrawals, and complete payment history
• Server log data, including access timestamps and actions performed within the account
• Cookie and other relevant tracking technology information (as described in Section 7)

C. Data from Third Parties (where applicable):

• Identity verification information from certified KYC service providers in Malaysia
• Payment verification data from service providers such as FPX, Maybank2u, CIMB Clicks, and relevant e-wallet providers

110r uses the personal data collected for the following purposes, all of which are directly related to delivering the platform's services to you:

110r will not use your personal data for any purpose beyond those stated in the table above without first obtaining your explicit consent. Any new use not anticipated in this Privacy Policy will be communicated to you via in-platform notification or email prior to implementation.

110r processes your personal data on valid legal grounds under Malaysia's Personal Data Protection Act 2010 (PDPA). These grounds include:

• Consent: You provided explicit consent when registering your account 110r and agree to this Privacy Policy. Consent to marketing communications is separate and may be withdrawn at any time.
• Contract Performance: Data processing required to deliver the services you request — such as processing deposits via DuitNow or FPX, crediting winnings to your account, or managing your live casino gaming sessions.
• Legal Obligation: In certain cases, 110r is required to process your data in order to comply with applicable legal obligations in Malaysia — including KYC requirements, anti-money laundering (AML) regulations, and mandatory financial reporting.
• Legitimate Interests: 110r may process certain data based on our legitimate interests — such as detecting fraud, preventing platform abuse, and ensuring system security — provided these interests do not override your fundamental privacy rights.

110r does not sell, rent, or trade your personal data to third parties for marketing purposes. However, in the course of operating the platform, we may share your personal data with the following limited categories of third parties:

• Payment Service Providers: Providers such as Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX (Maybank2u, CIMB Clicks) receive the transaction information necessary to process your deposits and withdrawals. This data is shared only to the extent required for payment processing.
• KYC Service Provider: Accredited identity verification providers used by 110r may receive a copy of your identification documents during the verification process. All such providers are bound by strict confidentiality agreements.
• Game Providers: Third-party game software providers that operate certain games within the platform 110r may receive the game session data required for their technical operations.
• Statutory Authorities: 110r may be required to disclose your personal data to Malaysian government authorities or regulatory bodies when mandated by law, court order, or a legitimate investigation requirement.

110r implements a comprehensive range of technical and organisational security measures to protect your personal data from unauthorised access, loss, destruction, or improper disclosure:

• 256-bit SSL Encryption: All data transmitted between your web browser and the 110r is encrypted using industry-standard 256-bit SSL protocol — the same standard used by leading banking institutions in Malaysia.
• Secure Servers: Member personal data is stored on servers protected by multi-layered firewalls, intrusion detection systems, and strict physical access controls.
• 24/7 Monitoring: Security system 110r is monitored around the clock by our IT security team to detect and respond to any threats or anomalies without delay.
• Internal Access Controls: Access to member personal data within the organisation 110r is restricted to employees who genuinely require it to carry out their duties. All access is logged and audited on a regular basis.
• Regular Security Testing: 110r conducts regular penetration testing and security audits to ensure our data protection systems remain at the highest standard at all times.
• Staff Training: All staff 110r who handle personal data receive regular data protection training and are bound by strict confidentiality agreements.

While we take all reasonable precautions, no online security system can be guaranteed to be 100% secure. You also play an important role in protecting your account — use a strong password, never share your login credentials, and notify us immediately if you suspect any suspicious activity on your account 110r yours.

Platform 110r uses cookies and similar tracking technologies to enhance the user experience, maintain session security, and analyse platform usage patterns. The types of cookies we use are as follows:

• Essential Cookies: Required for core platform operations 110r — including login, session security, and core gameplay functions. These cookies cannot be disabled without affecting the platform's functionality.
• Preference Cookies: Saves your personal settings such as language preferences and preferred display layout, making your experience on 110r more comfortable.
• Analytics Cookies: Collecting anonymous information about how users interact with the platform 110r — this data helps us improve the platform's design and performance. The information collected cannot directly identify any individual.
• Security Cookies: Used to detect suspicious activity, prevent fraud, and protect member accounts 110r from unauthorised access.

You can manage or disable non-essential cookies through your web browser settings. However, disabling essential cookies may affect your ability to use certain features of the platform. 110r seamlessly. For more information on how to manage cookies on your device, refer to the help guide of your web browser.

110r retaining your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy, or as required by applicable Malaysian law:

• Active Account Data: For as long as your account remains active on the platform 110r and for a reasonable period after the account becomes inactive.
• Financial Transaction Data: A minimum of 7 years from the transaction date, in compliance with Malaysia's financial and tax legal requirements.
• KYC Records (Identity Verification): At least 5 years after the business relationship ends, in line with Malaysia's anti-money laundering (AML) requirements.
• Server Log Data: Typically retained for 12 months for security purposes and technical troubleshooting.
• Customer Support Data: For 3 years after a case is resolved, for reference in the event of any subsequent complaints.

Once the retention period has expired and there is no legal or legitimate requirement for continued storage, 110r will securely delete or anonymise your personal data using methods that comply with industry standards.

As a data subject under Malaysia's PDPA, you have specific rights regarding your personal data held by 110r. We fully respect these rights and provide straightforward mechanisms for you to exercise them:

Platform 110r is strictly for adult users aged 18 and above. We do not knowingly collect, store, or process personal data from individuals under the age of 18 under any circumstances.

If you believe that a minor has registered an account on 110r or that we have inadvertently collected data from individuals under the age of 18, please contact us immediately at [email protected]. We will take prompt action to verify and delete any such data and close the account in question without delay.

110r reserves the right to amend or update this Privacy Policy from time to time to reflect changes in our data processing practices, updates to relevant Malaysian legislation, or improvements in how we manage user information.

For any material amendments — meaning changes that significantly affect how we use or protect your data — 110r will notify all members in advance via their registered email or in-platform notification at least 14 days before any changes take effect.

Continued use of the platform 110r after the effective date of any amendment to this Privacy Policy will be deemed as your acceptance of the updated version. The most recent update date of this Privacy Policy is always clearly displayed at the top of this page for your easy reference.

If you have any questions, concerns, or complaints regarding how 110r manages your personal data, or if you wish to exercise any of the privacy rights described in this Privacy Policy, please contact us through the following channels:

• Privacy Email: [email protected] (Subject: Privacy Policy Enquiry)
• Live Chat: Available on the platform 110r 24 hours a day, 7 days a week
• Frequently Asked Questions Our FAQ page contains answers to the most frequently asked privacy questions

Our support team 110r who are fluent in Bahasa Malaysia are ready to assist you with any privacy-related enquiries within a reasonable timeframe. We are committed to addressing every concern with seriousness, thoroughness, and respect.