Privacy Policy — 85xo Platform

This Privacy Policy ("Policy") is issued by 85xo ("we", "us", "our", "Platform") and applies to all personal data processed in connection with your use of the 85xo website located at https://85xo.cam, including all associated gaming services, account functions, payment processing, customer support, and marketing communications.

85xo is committed to handling your personal information with care, transparency, and respect. This Policy explains in plain terms what data we collect, the purposes for which it is processed, with whom it may be shared, how long we retain it, and the rights you hold as a data subject.

By registering an account on 85xo or otherwise accessing the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. Where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" — any information that identifies or could reasonably be used to identify a natural person, directly or indirectly, including name, identification number, contact details, location data, and online identifiers.
• "Processing" — any operation performed on personal data, including collection, recording, storage, alteration, retrieval, consultation, use, disclosure, transmission, erasure, or destruction.
• "Data Subject" — the identified or identifiable natural person to whom the personal data relates; in the context of 85xo, this primarily refers to registered players and site visitors.
• "Controller" — the entity that determines the purposes and means of processing personal data; 85xo acts as the Data Controller for personal data collected through the Platform.
• "Processor" — a third party that processes personal data on behalf of the Controller under contract, such as payment gateway providers and identity verification services.
• "KYC Data" — identity verification documentation provided by the player, including government-issued identification documents and proof of address.
• "Cookies" — small text files stored on your device by the Platform's web server to support functionality, session management, analytics, and personalisation.

85xo collects the following categories of personal data in the course of operating the Platform and providing services to registered players:

85xo collects personal data through the following channels and mechanisms:

• Direct Provision: Information you provide directly when creating an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or responding to surveys or promotions.
• Automated Technical Collection: Data collected automatically when you access the Platform, including your IP address, device identifiers, browser characteristics, pages visited, session duration, and clickstream data, collected through server logs and session management technology.
• Payment Processing Partners: Transaction data shared with 85xo by payment processors in connection with deposits and withdrawals made via FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank, and cryptocurrency channels.
• Identity Verification Providers: Where automated KYC tools are used, data received from third-party identity verification service providers who process document images on our behalf under strict data processing agreements.
• Cookies and Similar Technologies: Data collected via cookies, web beacons, and session storage as described in Section 10 of this Policy.
• Third-Party Fraud Prevention Services: Risk signals and fraud indicators received from anti-fraud and AML screening services engaged by the Platform to protect the integrity of the gaming environment.

85xo processes personal data for the following specific and legitimate purposes:

• Account Management: Creating, operating, maintaining, and securing your registered player account, including authentication and access control.
• Service Delivery: Providing access to games, sports betting markets, live casino features, and all other services available on the Platform.
• Payment Processing: Facilitating MYR-denominated deposits and withdrawals via supported Malaysian payment channels including FPX, DuitNow, and local e-wallets.
• Identity Verification (KYC): Verifying player identity and age in compliance with applicable regulatory requirements and anti-money laundering obligations.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, unauthorised account access, and other prohibited conduct.
• Responsible Gambling: Monitoring account activity to identify behavioural patterns associated with problem gambling and supporting the application of responsible gambling tools requested by the player.
• Customer Support: Responding to enquiries, resolving disputes, and maintaining records of support interactions for quality and training purposes.
• Legal & Regulatory Compliance: Meeting obligations under applicable laws, responding to legal process, and cooperating with regulatory authorities as required.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications.
• Platform Improvement: Analysing aggregated usage data to improve platform performance, game selection, and user experience.

85xo processes personal data in accordance with recognised legal bases as follows:

• Contractual Necessity: Processing required to perform our contractual obligations to you as a registered player, including account management, payment processing, and service delivery.
• Legal Obligation: Processing necessary to comply with applicable laws and regulations, including AML obligations, KYC requirements, and responses to lawful regulatory or law enforcement requests.
• Legitimate Interests: Processing carried out in pursuit of 85xo's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — in particular for the sending of direct marketing communications. You may withdraw consent at any time without detriment.

85xo does not sell, rent, or trade your personal data to any third party. We may share personal data with the following categories of recipients only where strictly necessary and under appropriate safeguards:

• Payment Service Providers: FPX gateway operators, DuitNow processors, e-wallet providers (Touch 'n Go, Boost, GrabPay), and banking partners (Maybank, CIMB, Public Bank, Hong Leong Bank) to facilitate transaction processing. These providers operate as data processors under contractual data processing agreements.
• Identity Verification Services: Third-party KYC and AML screening providers engaged to verify player identity and assess risk profiles, operating strictly under data processing agreements that prohibit independent use of your data.
• Technology & Infrastructure Partners: Cloud hosting providers, content delivery networks, and cybersecurity vendors supporting the technical operation of the Platform, all bound by confidentiality and data protection obligations.
• Game Technology Providers: Where technically required, limited session and account data may be shared with game providers to initialise gaming sessions. No financial or identity data is shared beyond what is operationally necessary.
• Regulatory & Law Enforcement Authorities: Where we are legally compelled by court order, regulatory directive, or law enforcement request to disclose personal data, we will comply with such requirements. We will, where permitted, notify affected players of such disclosures.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by 85xo under strict confidentiality obligations.

In the course of operating the Platform, your personal data may be transferred to and processed in countries outside of Malaysia. Such transfers occur where 85xo's infrastructure partners, game providers, or professional service providers are located in other jurisdictions.

Where personal data is transferred internationally, 85xo ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses requiring recipient entities to apply data protection standards equivalent to those applied by 85xo.
• Transfer only to jurisdictions recognised as providing an adequate level of data protection by applicable standards.
• Assessment of third-party security practices prior to engaging service providers who will process your personal data outside Malaysia.

By using the 85xo Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Malaysia as described in this section, subject always to the safeguards outlined above.

85xo retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required to comply with applicable legal and regulatory obligations. Key retention periods include:

• Account Data: Retained for the duration of your active account relationship with 85xo and for a period of at least five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification or from the date of account closure, whichever is later, to comply with AML and financial crime prevention obligations.
• Transaction Records: Financial transaction data retained for a minimum of seven (7) years from the date of the transaction for accounting, tax, and regulatory compliance purposes.
• Customer Support Records: Correspondence and chat transcripts retained for up to three (3) years following the last support interaction, for quality assurance and dispute resolution purposes.
• Marketing Data: Marketing preferences and consent records retained until withdrawal of consent or account closure, plus one (1) additional year to evidence consent history.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 85xo's data destruction procedures.

85xo uses cookies and similar tracking technologies to support the operation of the Platform. Cookies are small text files placed on your device by the Platform's web server. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences and settings, such as language preference, game display settings, and notification preferences, to provide a personalised experience.
• Analytics Cookies: Collect aggregated, anonymised information about how players use the Platform, including pages visited, time spent, and features used, to help us improve performance. No individual player is identified in analytics reports.
• Security Cookies: Used for fraud detection and prevention, including identification of unusual access patterns, device fingerprinting for account protection, and bot detection.

You may configure your browser to refuse some or all cookies. Please note that disabling strictly necessary cookies will impair your ability to use the Platform, including account login. Analytics and functional cookies may be disabled without material effect on core Platform access.

As a data subject, you hold the following rights in relation to personal data we hold about you. These rights may be subject to certain legal limitations and exemptions:

• Right of Access: You may request a copy of the personal data we hold about you, together with information about how it is being processed. We will respond within a reasonable period, typically within 30 days of receiving a valid request.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Minor corrections, such as contact details, may be made directly within your account settings.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may request deletion of your personal data. This right is subject to our overriding legal obligations — for example, we are required to retain KYC and financial records for the periods described in Section 9 and cannot delete such data on request.
• Right to Restriction of Processing: You may request that we temporarily restrict the processing of your personal data in circumstances where, for example, the accuracy of the data is contested or you have objected to processing pending verification of our legitimate grounds.
• Right to Data Portability: Where processing is carried out by automated means on the basis of your consent or a contract, you may request a structured, machine-readable copy of data you have provided to us.
• Right to Object: You may object to processing carried out on the basis of legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent (primarily marketing communications), you may withdraw consent at any time via your account notification settings or by contacting support.

To exercise any of the above rights, please contact our Data Privacy team via live chat or at [email protected]. We may request verification of your identity before processing data-related requests to ensure that personal data is not disclosed to or amended by unauthorised parties.

The 85xo Platform is strictly intended for use by individuals aged 21 years and above. We do not knowingly collect personal data from any person under the age of 21. If we become aware that a registered account belongs to a person under this age, the account will be immediately suspended, access will be revoked, and the matter may be referred to relevant authorities.

If you are a parent or guardian and have reason to believe that a minor has provided personal data to 85xo or has registered an account, please contact our support team immediately via live chat or by email. We will take prompt action to investigate and address such reports, including deletion of any personal data collected from minors.

85xo implements a comprehensive, layered approach to information security designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security infrastructure includes:

• Encryption in Transit: All data transmitted between your device and the 85xo Platform is encrypted using TLS 1.3. HTTPS is enforced across the entire platform without exception.
• Encryption at Rest: Personal data and KYC documents stored in our systems are protected by AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorised personnel who require it for specific operational or compliance purposes. Role-based access controls and multi-factor authentication are applied to all internal systems.
• Network Security: The Platform infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and DDoS mitigation technology.
• Penetration Testing: Regular security assessments and penetration testing are conducted by independent security professionals to identify and remediate vulnerabilities.
• Incident Response: 85xo maintains a documented data breach response procedure. In the event of a confirmed breach affecting your personal data, we will notify you and relevant authorities in accordance with applicable data protection requirements.

While we implement robust security measures, no digital system is entirely immune to risk. You are encouraged to protect your account by using a strong, unique password, enabling two-factor authentication, and reporting any suspected unauthorised account activity to our support team immediately.

85xo reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. The version date displayed at the top of this page indicates the date of the most recent revision.

Where amendments are material — for example, where we introduce a new category of data processing, a new third-party sharing arrangement, or a material change to your rights — we will provide notice to registered players via the email address on their account or through an on-platform notification prior to the changes taking effect.

Your continued use of the Platform following notification of changes constitutes acceptance of the revised Policy. We encourage you to review this page periodically. Prior versions of this Policy are available on request from our support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 85xo, please contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week from within your 85xo account dashboard. Live chat is the fastest channel for urgent privacy enquiries, with typical response times under one hour.
• Email: [email protected] — please mark your subject line with "Privacy Request" or "Data Subject Request" to ensure prompt routing to the appropriate team. Typical email response time: within 24 hours.

When submitting a data subject rights request, please provide your registered account username, the email address on your account, and a clear description of the right you wish to exercise. We will verify your identity before processing the request to ensure your data is not accessed or amended by third parties.

You also have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction if you believe that your personal data has been processed in a manner inconsistent with your rights under applicable data protection law.