Introduction
This Privacy Policy ("Policy") describes how Siritogel ("we", "us", "our", "the Platform") — the operator of the online gambling platform accessible at siritogel.cam — collects, uses, processes, stores, and protects the personal data of individuals ("you", "the Player", "the User") who access or register on our platform.
Siritogel recognises its responsibility to handle personal data with care, transparency, and respect for individual privacy rights. We are committed to processing personal data in compliance with applicable data protection legislation and in a manner consistent with our obligations as an internationally licensed online gaming operator serving players across Malaysia, including those based in Kuala Lumpur, Penang, Shah Alam, Petaling Jaya, and Johor Bahru.
Scope: This Policy applies to all personal data collected through the Siritogel website, mobile-optimised platform, customer support interactions, email correspondence, and payment processing — from the moment you visit siritogel.cam, whether or not you register an account.
By registering an account on Siritogel or by continuing to use our platform after this Policy has been made available to you, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue your use of the Platform and may request account closure in accordance with our Terms & Conditions.
This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy.
Definitions
For the purposes of this Policy, the following terms have the meanings assigned to them below:
Data We Collect
Siritogel collects the following categories of personal data, depending on the nature of your interaction with the Platform:
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, MyKad / Passport / Driver's Licence number | Account registration; KYC verification |
| Contact Data | Email address, mobile phone number, residential address | Account registration; correspondence |
| Financial Data | Payment method details (eWallet identifiers, bank account references, cryptocurrency wallet addresses), transaction history, deposit and withdrawal amounts in MYR | Deposits; withdrawals; KYC |
| Technical Data | IP address, device type, browser type and version, operating system, session identifiers, login timestamps | Platform access; account activity |
| Usage Data | Games played, wager amounts, win/loss records, session duration, sports betting markets accessed, bonus usage history | Ongoing platform use |
| KYC Documents | Scanned or photographed copies of government-issued ID, proof of address documents, selfie verification images | Identity verification; withdrawal processing |
| Communications Data | Content of Live Chat conversations, email correspondence, support ticket records | Customer support interactions |
| Preference Data | Responsible gambling settings, deposit limits, self-exclusion status, marketing consent preferences | Account settings; responsible gambling tools |
How We Collect Your Data
Siritogel collects personal data through the following mechanisms:
- Direct Submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or updating your account settings.
- Automated Technical Collection: Data collected automatically when you access the Platform, including IP addresses, device identifiers, browser cookies, session logs, and usage analytics generated as you navigate the site.
- Payment Processors: Transaction confirmation data shared by payment providers including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency processing partners — to the extent necessary to confirm and record deposits and withdrawals.
- KYC and Identity Verification Providers: Data returned by our third-party identity verification partners as part of the KYC process, including document authenticity assessments and identity match scores.
- Fraud Prevention and AML Providers: Risk scoring data and watchlist screening results provided by third-party compliance service providers, to the extent required for our regulatory obligations.
- Publicly Available Sources: In limited circumstances, publicly available information from government databases or sanctions lists may be used to supplement identity verification or compliance screening.
Legal Basis for Processing
Siritogel processes personal data on one or more of the following legal bases, depending on the specific processing activity:
- Contractual Necessity: Processing required to fulfil the terms of the Player Account agreement — including account creation, deposit and withdrawal processing, game participation, and bonus management.
- Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money laundering (AML) checks, counter-terrorism financing (CTF) screening, KYC identity verification, and licensing requirements.
- Legitimate Interests: Processing carried out for Siritogel's legitimate operational interests, including fraud detection, platform security, responsible gambling monitoring, and platform performance analytics — where those interests are not overridden by your fundamental rights and freedoms.
- Consent: Where we process personal data for purposes such as optional marketing communications, you will be asked for and must provide explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Note on Withdrawal of Consent: Where processing is based on your consent, you may withdraw that consent at any time by contacting us using the details in Section 16. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal, nor does it affect processing carried out on other legal bases.
How We Use Your Data
We use personal data collected from Players for the following purposes:
- Account Management: Creating and maintaining your Player Account, verifying your identity, processing login authentication, and managing account settings.
- Payment Processing: Facilitating deposits and withdrawals via Malaysian payment methods (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong) and cryptocurrency channels.
- KYC and Compliance: Verifying your identity, assessing compliance with age restrictions (21+), screening against sanctions and politically exposed persons (PEP) lists, and meeting anti-money laundering obligations.
- Platform Security and Fraud Prevention: Detecting and preventing unauthorised access, bonus abuse, money laundering, multi-accounting, and other prohibited activities.
- Responsible Gambling: Monitoring account activity to identify indicators of problem gambling behaviour and delivering responsible gambling tools including deposit limits, session reminders, and self-exclusion management.
- Customer Support: Responding to account queries, resolving disputes, and maintaining records of support interactions for quality and training purposes.
- Service Improvement: Analysing aggregated usage data and platform performance metrics to improve game offerings, payment flows, and the overall player experience.
- Legal and Regulatory Compliance: Maintaining records as required by applicable law and responding to lawful requests from courts, regulators, or law enforcement authorities.
- Marketing Communications (Consent-Based): Sending promotional offers, bonus notifications, and platform updates where you have provided explicit consent. You may opt out at any time.
Data Sharing & Disclosure
Siritogel does not sell your personal data to any third party. We do not share personal data with advertisers, data brokers, or commercial partners for their own independent marketing or commercial purposes.
We may share personal data with the following categories of third parties, strictly limited to what is necessary for the described purpose:
- Payment Service Providers: Malaysian eWallet operators, FPX banking partners, DuitNow infrastructure providers, and cryptocurrency processing networks — solely for the purpose of executing deposit and withdrawal transactions.
- KYC and Identity Verification Partners: Third-party identity verification and document authentication services used to fulfil our regulatory compliance obligations.
- Fraud Prevention and AML Service Providers: Risk scoring, sanctions screening, and transaction monitoring providers engaged to support our anti-fraud and regulatory compliance programmes.
- Cloud Infrastructure and Hosting Providers: Secure cloud service providers on whom we rely to host the Platform and store data, bound by contractual data processing obligations.
- Game Content Providers: Licensed game software providers who may receive limited technical data (such as session identifiers) necessary to deliver game content. Game providers do not receive full identity data.
- Legal and Regulatory Authorities: Courts, regulatory bodies, law enforcement agencies, or licensing authorities, where disclosure is required by law, court order, or our licensing obligations.
- Professional Advisers: Legal counsel, auditors, and compliance advisers bound by professional confidentiality obligations.
Data Processor Agreements: All third parties who process personal data on our behalf are required to enter into a formal data processing agreement that obligates them to handle your data only in accordance with our instructions and this Policy.
International Data Transfers
As Siritogel operates as an internationally licensed platform, some of the third-party service providers we engage may process personal data in jurisdictions outside Malaysia. Where such international transfers occur, Siritogel ensures that appropriate safeguards are in place to protect your personal data, including one or more of the following mechanisms:
- Transferring data only to countries recognised as providing an adequate level of data protection by applicable regulatory authorities.
- Implementing standard contractual clauses or equivalent contractual protections that bind the recipient to processing your data only in accordance with this Policy.
- Ensuring that the receiving party has in place technical and organisational security measures equivalent to those maintained by Siritogel.
By using the Siritogel platform, you acknowledge that your personal data may be transferred to and processed in countries outside Malaysia where data protection laws may differ from those applicable in your jurisdiction. We will always take reasonable steps to ensure that such transfers are carried out in a manner that protects your fundamental rights.
Cookies & Tracking Technologies
Siritogel uses cookies and similar tracking technologies (including web beacons and local storage) to support platform functionality, improve user experience, and gather anonymised analytics. Cookies are small data files stored on your browser or device when you visit siritogel.cam.
We use the following categories of cookies:
| Cookie Type | Purpose | Can Be Disabled? |
|---|---|---|
| Essential | Required for platform operation — session management, login authentication, account security, payment gateway integration | No — required for platform function |
| Functional | Remember your language preferences, game settings, responsible gambling configuration, and display preferences | Yes — via browser settings |
| Analytics | Aggregate, anonymised data on page views, session durations, navigation paths, and feature usage to improve platform performance | Yes — via browser settings |
| Security | Fraud detection signals, device fingerprinting for multi-account detection, and suspicious activity monitoring | No — required for security |
You may adjust your browser settings to block or delete cookies at any time. Please note that disabling essential or security cookies may impair platform functionality and may prevent you from accessing your account or completing transactions.
Data Retention
Siritogel retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligation. The following general retention periods apply:
- Active Account Data: Retained for the duration of your Player Account, plus any legally mandated post-closure retention period.
- KYC Documentation: Retained for a minimum of five (5) years following account closure, in compliance with anti-money laundering regulatory requirements.
- Transaction Records: Retained for a minimum of five (5) years following each transaction, for AML and tax compliance purposes.
- Customer Support Communications: Retained for up to three (3) years following the close of a support interaction, for dispute resolution and quality assurance purposes.
- Technical and Usage Logs: Typically retained for up to twelve (12) months, after which they are anonymised or deleted.
- Marketing Consent Records: Retained for as long as your marketing consent remains active, plus six (6) months following withdrawal of consent to demonstrate compliance.
Upon expiry of the applicable retention period, personal data is either securely deleted or anonymised such that it can no longer be associated with any identifiable individual. Where anonymisation is not technically practicable, data is retained in a restricted archive pending scheduled deletion.
Data Security
Siritogel takes the security of your personal data seriously and implements comprehensive technical and organisational measures to protect it against unauthorised access, loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:
- Encryption in Transit: All data transmitted between your browser and siritogel.cam is encrypted using TLS 1.2 or higher (256-bit SSL).
- Encryption at Rest: Sensitive personal data and financial records stored on our servers are encrypted using AES-256 encryption.
- Access Controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis. All access is logged, monitored, and subject to regular audit.
- Two-Factor Authentication: Administrative access to systems holding personal data is protected by mandatory multi-factor authentication.
- Penetration Testing: The Platform undergoes regular independent security assessments to identify and remediate vulnerabilities.
- Incident Response: We maintain a documented data breach response procedure. In the event of a breach that poses a material risk to your rights and freedoms, affected Players will be notified in accordance with applicable regulatory requirements.
Your Role in Security: While Siritogel implements robust platform-level security, you share responsibility for protecting your account. Use a strong, unique password, enable two-factor authentication, and never share your login credentials. Report suspected unauthorised account access to our support team immediately.
Your Data Rights
Subject to applicable law and Siritogel's legal retention and compliance obligations, you have the following rights in respect of your personal data:
You have the right to request a copy of the personal data we hold about you, along with information about how it is used and shared. We will respond to access requests within 30 calendar days.
You may request correction of any inaccurate or incomplete personal data we hold about you. Where data accuracy directly affects your account or transactions, we will prioritise rectification.
You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected. This right is subject to legal retention obligations — for example, AML regulations require us to retain KYC and transaction records for a minimum of five years after account closure.
You may request that we temporarily restrict processing of your personal data while a dispute regarding its accuracy or lawfulness is under review.
Where processing is based on consent or contract, and is carried out by automated means, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
You may object to the processing of your personal data where it is based on Siritogel's legitimate interests, including profiling for fraud prevention. We will consider your objection and cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
Where processing is based on your consent (e.g., marketing emails), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
To exercise any of these rights, please contact our Data Protection team using the details provided in Section 16. We may need to verify your identity before processing a rights request. We will respond to all valid requests within 30 calendar days. Where requests are complex or numerous, we may extend this period by a further 30 days, with prior notification.
Children & Minors
The Siritogel platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. Registration by a minor constitutes a material breach of our Terms & Conditions and will result in immediate account closure.
If Siritogel becomes aware that personal data has been submitted by or on behalf of an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you have reason to believe that a minor has accessed the Platform using your payment method or personal details, please contact our support team immediately via Live Chat.
Parental Controls: We strongly recommend that adults who share devices with minors make use of parental control software and browser-level content filters to prevent access to gambling platforms. For guidance on keeping minors safe from gambling content, please visit our Responsible Gambling page.
Third-Party Services & Links
The Siritogel platform integrates with third-party services including payment gateways, identity verification providers, and game content suppliers. These third parties operate under their own privacy policies, which govern their collection and use of any personal data shared with them in the course of their service delivery.
Siritogel takes reasonable steps to ensure that all third-party service providers engaged by the Platform maintain adequate data protection standards. However, Siritogel cannot be held responsible for the privacy practices of third-party services accessed independently by Players outside of the Siritogel platform.
The Platform does not include links to external third-party websites other than those necessary for payment processing and licensing verification. If you access any external service via a link provided by Siritogel, please review that service's privacy policy independently.
Amendments to This Policy
Siritogel reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The "Last Updated" date at the top of this Policy reflects the most recent revision.
Where amendments are material — meaning they meaningfully affect your rights or how your data is used — Siritogel will notify you via email to your registered address or via a prominent notice on the Platform at least 14 days before the changes take effect. For minor amendments that do not materially affect your rights, we may update the Policy without separate notification.
Your continued use of the Siritogel platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not agree with the revised Policy, you should cease using the Platform and may request account closure as provided in our Terms & Conditions.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 12, please contact the Siritogel Data Protection team through one of the following channels:
For responsible gambling inquiries, self-exclusion requests, or deposit limit management, please visit our Responsible Gambling page. For general platform terms and account rules, please review our Terms & Conditions.