Tiv2 Privacy Policy – Personal Data Protection for Malaysian Players

1. Introduction – Who We Are and Why Privacy Matters

CLAUSE 1.1 – 1.4

1.1 tiv2 is an online casino platform operating under a valid international licence, offering a wide range of games including slots, live casino, Lightning Dice, Ultimate Holdem, Golden Farm, Triple Pandas, Mines, Craps, and Solar Queen to players in Malaysia. For the purposes of this Privacy Policy, tiv2 ("we", "platform" or "Company") acts as the data controller responsible for processing members' personal information.

1.2 We understand that your trust in tiv2 is not just about game quality or withdrawal speed – it also depends greatly on your confidence that your personal information is handled with integrity and professionalism. That is why privacy is one of the core pillars behind every operational decision at tiv2.

1.3 This Privacy Policy has been drafted in accordance with the requirements of Malaysia's Personal Data Protection Act (PDPA) 2010 and international best practices in data protection. We are committed to maintaining compliance with applicable laws and updating this policy whenever there are changes to legal requirements or tiv2's practices.

1.4 If you have any questions or concerns regarding how tiv2 manage your personal data, you may contact our Data Protection Officer at any time via email at [email protected].

2. Personal Data We Collect

CLAUSE 2.1 – 2.5

2.1 tiv2 only collects personal data that is strictly necessary to operate the platform and deliver quality services to members. We do not collect excessive or irrelevant data beyond the stated purposes.

2.2 Below are the categories of personal data we collect and the purposes for which they are collected:

2.3 Data you provide directly – during registration, the KYC process, making a deposit, or when contacting customer support tiv2 – collected on the basis of consent provided by you at the time of registration.

2.4 Data collected automatically when you use the platform tiv2 including IP address, device type, browser name, operating system, pages visited, time of visit and navigation patterns. This data is collected to maintain platform security and enhance the user experience.

2.5 tiv2 does not collect sensitive categories of personal data such as health data, biometric data, political opinions, or religious beliefs, unless directly relevant to responsible gambling requirements or mandated by law.

3. How We Use Your Personal Data

CLAUSE 3.1 – 3.6

3.1 tiv2 uses the personal data collected solely for the following purposes, which were disclosed to you at the time of registration:

• Account Management – Creating, maintaining, and managing your tiv2 account, including the login process, two-factor authentication, and password resets
• Transaction Processing – Processing deposits via DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, or FPX, and withdrawals of winnings to the same payment methods in MYR
• KYC and AML Compliance – Fulfils the Know Your Customer and anti-money laundering legal requirements mandated by tiv2's operating licence
• Security & Fraud Prevention – Identifying and preventing unauthorised access, fraud, platform abuse, and other unlawful activities
• Customer Service – Handling enquiries and resolving complaints through tiv2's Bahasa Malaysia-speaking support team, available 24/7
• Responsible Gaming – Detecting gaming patterns that may indicate problem gambling and reaching out to members who may need assistance
• Service Improvement – Analysing usage patterns to improve the platform, games, and overall tiv2 member experience
• Marketing Communications – Sending members who have opted in information about tiv2 promotions, bonuses, and new offers

3.2 tiv2 does not use your data to make automated decisions that significantly affect you without the possibility of human review. All key decisions relating to your account will involve review by a qualified human team.

3.3 You may withdraw your consent to receive marketing communications from tiv2 at any time by clicking the unsubscribe link in any marketing email or by contacting [email protected]. Withdrawing marketing consent does not affect the processing of data for other purposes that have a valid legal basis.

3.4 tiv2 may use aggregated and anonymised data for analytics, research, and industry reporting purposes. Such anonymised data cannot be re-identified to any individual and is not subject to the same data protection requirements.

3.5 In the context of responsible gambling, tiv2 monitors gaming activity patterns to identify early signs of problem gambling. This may include tracking play frequency, amounts wagered, and deposit patterns. Such monitoring is carried out on the basis of the legitimate interests of tiv2 and its members in maintaining a healthy gambling environment.

3.6 tiv2 uses an automated fraud detection system that analyses multiple data points to identify suspicious activity. This system helps protect all tiv2 members from fraud and platform abuse.

4. Legal Basis for Data Processing

CLAUSE 4.1 – 4.4

4.1 tiv2 only processes personal data where a valid legal basis exists. The legal bases we rely on are:

• Consent – When you provide clear and voluntary consent, such as when registering a tiv2 account or agreeing to receive marketing communications
• Performance of Contract – Processing required to fulfil the agreement between you and tiv2, including transaction processing and account management
• Legal Obligation – Processing required by Malaysian law or the direction of a competent authority, such as KYC and AML requirements
• Legitimate Interest – Processing for tiv2's legitimate business interests, such as fraud prevention and platform security, provided those interests do not override your fundamental rights and freedoms

4.2 Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to the withdrawal.

4.3 For processing based on legitimate interests, tiv2 has conducted a balancing assessment to ensure that our interests do not override your fundamental right to privacy. You may contact us for further information regarding that assessment.

4.4 In certain circumstances, tiv2 may need to process your data on the basis of vital interests, such as when processing is necessary to protect someone's life or safety. This is an extremely rare circumstance within the context of tiv2's operations.

5. Sharing and Disclosure of Personal Data

CLAUSE 5.1 – 5.6

5.1 tiv2 does not sell, rent or trade members' personal data to any third party for any commercial purpose whatsoever. This is an absolute and unchanging commitment.

5.2 Your personal data may only be shared with third parties under the following limited circumstances:

• Trusted Service Providers – Companies that assist tiv2 in operating the platform, including payment service providers (such as DuitNow gateway, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay and FPX), cloud infrastructure providers, identity verification services and game providers. All these providers are bound by strict data protection agreements and may only use your data for purposes specified by tiv2.
• Legal Authorities – When required by Malaysian law or a lawful directive from a competent law enforcement authority, tribunal, or court
• tiv2 Rights Protection – When necessary to investigate, prevent, or take action against illegal activity, fraud, or violations of tiv2's Terms & Conditions
• Business Transfer – In the event of a merger, acquisition or sale of tiv2's assets, members' personal data may be transferred as part of that transaction, with appropriate notice provided to members

5.3 When tiv2 sharing data with third-party service providers, we ensure that comprehensive data processing agreements are in place to protect your data. These providers act solely on tiv2's instructions and are not permitted to use your data for their own purposes.

5.4 tiv2 does not share your data with advertising companies, data aggregators or data brokers under any circumstances.

5.5 In circumstances where tiv2 receives a request from authorities to disclose member data, we will assess the validity of the request before releasing any information. We will inform the member concerned if we are permitted to do so under applicable law.

5.6 Any third party that receives data from tiv2 are contractually bound to use it only for the permitted purposes and to protect it to a standard at least equivalent to tiv2's own security standards.

6. Data Security – How We Protect Your Information

CLAUSE 6.1 – 6.5

6.1 tiv2 invests significantly in security infrastructure to protect members' personal data against unauthorised access, alteration, disclosure, or destruction. The security measures we have in place include:

• 256-bit SSL/TLS encryption for all communications between the tiv2 platform and your device
• Encryption of stored data for sensitive information, including financial details and KYC documents
• Two-factor authentication (2FA) for account logins and key transactions
• Role-based access controls ensuring that only authorised personnel can access member data
• Round-the-clock 24/7 security monitoring by tiv2's cybersecurity team
• Regular penetration testing by independent security specialists
• Secure, encrypted data backups to ensure service continuity
• Regular security training for all tiv2 staff who handle personal data

6.2 Although tiv2 takes reasonable steps to protect your data, no security system is entirely foolproof. You also play an important role in keeping your data safe by ensuring your tiv2 account password is strong and unique, not sharing your login credentials with anyone, and promptly reporting any suspicious activity to the tiv2 support team.

6.3 tiv2 maintains records of all data processing activities as required by data protection law. These records include details of the types of data collected, the purposes of processing, the parties with whom data is shared, and retention periods.

6.4 In the event of a data breach that may affect the rights and freedoms of members, tiv2 will take immediate action to contain the incident and notify affected members and the relevant authorities within the stipulated timeframe.

6.5 The KYC documents you submit to tiv2 – including copies of MyKad, passports, and proof of address – are stored in a secure, encrypted environment with strictly limited access granted only to authorised personnel.

7. Data Retention Period

CLAUSE 7.1 – 7.4

7.1 tiv2 retains your personal data only for as long as it is needed for the purposes for which it was collected, or as required by applicable law. Our guiding principle is to keep data to the minimum necessary and for no longer than required.

7.2 Retention periods for the different categories of data are as follows:

• Identity & KYC Data – Retained for the duration of active membership plus 7 years following account closure, as required under Malaysia's AML laws
• Financial Transaction Data – Retained for 7 years from the transaction date in accordance with accounting and legal compliance requirements
• Gaming Activity Data – Retained for 3 years from the date of activity, or for the duration of active membership, whichever is longer
• Customer Support Communication Data – Retained for 3 years from the date of interaction for dispute resolution purposes
• Marketing Data – Retained until you withdraw your consent or close your tiv2 account
• Technical Log Data – Retained for 12 months for security and technical troubleshooting purposes

7.3 Once the retention period expires, your data will be securely deleted or anonymised within 90 days of the expiry date. Anonymised data may be retained indefinitely for analytical purposes, as it can no longer be linked to you.

7.4 In circumstances where there is an unresolved dispute, an ongoing investigation, or a legal requirement to extend the retention period, tiv2 reserves the right to retain relevant data until the matter has been fully resolved.

8. Your Rights Regarding Personal Data

To exercise any of the rights listed above, please submit your request by email to [email protected] by specifying the particular right you wish to exercise and providing sufficient information to verify your identity. tiv2 will process requests within 14 business days and provide you with a response.

9. Cookies and Tracking Technologies

CLAUSE 9.1 – 9.5

9.1 Platform tiv2 uses cookies and similar tracking technologies to ensure optimal platform functionality and enhance the user experience. Cookies are small text files stored on your device when you visit tiv2.my.

9.2 Below are the types of cookies used by tiv2 and their respective purposes:

9.3 You can manage cookie usage through your web browser settings. Most browsers allow you to view, manage, and delete cookies. Please note, however, that disabling certain cookies may affect the functionality of the platform tiv2 and your gaming experience.

9.4 tiv2 does not use tracking technologies to monitor your activity outside the tiv2.my platform. We do not use tracking pixels or any technology that monitors your browsing on other websites.

9.5 Information collected through cookies and tracking technologies is used solely for platform operations and improvement purposes tiv2, and is not shared with third parties for advertising purposes.

10. Cross-Border Data Transfers

CLAUSE 10.1 – 10.3

10.1 In the course of platform operations tiv2, there are instances where your personal data may need to be transferred to or processed in countries other than Malaysia – for example, by cloud infrastructure service providers operating across multiple international locations.

10.2 When personal data is transferred outside Malaysia, tiv2 ensures that adequate safeguards are in place to protect such data. The protective measures we employ include approved standard contractual clauses and data transfer security assessments to ensure that recipients provide a comparable level of protection.

10.3 You may contact tiv2 at [email protected] for more information about the safeguards in place for cross-border data transfers involving your personal data.

11. Privacy of Children and Minors

CLAUSE 11.1 – 11.3

11.1 Platform tiv2 is restricted to individuals aged 21 and above only. We do not knowingly collect, use or disclose the personal data of individuals under the age of 21.

11.2 In the event that tiv2 discovers that personal data of an individual under the age of 21 has been collected without our knowledge, we will take immediate steps to delete that data and close the associated account.

11.3 If you believe that someone under the age of 21 has registered an account at tiv2, please contact us immediately at [email protected] so that we can take the appropriate action without delay.

12. Amendments to This Privacy Policy

CLAUSE 12.1 – 12.3

12.1 tiv2 reserves the right to amend this Privacy Policy from time to time to reflect changes in tiv2's practices, legal requirements or technological developments. Members will be notified of any material amendments via their registered email or in-platform notifications at least 14 days before the changes take effect.

12.2 The date of the most recent update to this Privacy Policy is always shown at the top of the document. We encourage you to review this Privacy Policy periodically to stay informed about how tiv2 protects your data.

12.3 Continued use of the platform tiv2 following any amendment to the Privacy Policy taking effect will be deemed as your acceptance of the revised policy. If you do not agree with the amendments, you must discontinue use of the platform and contact us to close your account.

13. Contact Us About Privacy

CLAUSE 13.1 – 13.3

13.1 If you have any questions, concerns or complaints regarding this Privacy Policy or the way tiv2 managing your personal data, please contact our Data Protection Officer through the following channels:

• Privacy Email: [email protected] (please state "Privacy Enquiry" in the email subject line)
• Live Chat: Available 24/7 via the chat icon on tiv2.my

13.2 tiv2 is committed to responding to all privacy-related enquiries within 3 business days and to processing data rights requests within 14 business days. If your request is complex or involves a significant volume of data, we may require additional time of up to 30 business days, and we will notify you of the need for this extension.

13.3 If you are not satisfied with the response tiv2 regarding your privacy complaint, you have the right to escalate the matter to the relevant data protection authority in Malaysia or the applicable jurisdiction.