85xo Privacy Policy — How We Handle Your Personal Data

85xo ("we", "us", "our") is committed to protecting the privacy and personal data of every individual who uses the 85xo Platform — accessible at https://85xo.app — including all casino, live dealer, slots, and sportsbook products available thereon. This Privacy Policy has been prepared to inform you clearly and transparently about our data practices.

This Privacy Policy applies to all personal data processed in connection with your 85xo account — from initial registration through the full lifecycle of your customer relationship with us, including account closure and any post-closure retention required by law.

By registering an account or using the 85xo Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not consent, you must not create or use a 85xo account.

85xo is the data controller responsible for personal data collected and processed through the Platform. As data controller, 85xo determines the purposes and means of processing your personal data.

For all privacy-related queries, data subject requests, or concerns regarding this Privacy Policy, you may contact our designated Data Protection contact:

• Email: [email protected]
• Subject line: "Privacy / Data Request"
• Response time: Within 5 business days of receipt

85xo collects the following categories of personal data:

• Full legal name (as per government-issued identification);
• Date of birth;
• Residential address;
• Email address;
• Mobile phone number (Malaysian number accepted; used for OTP and account communications);
• Copy of government-issued photo identification (Malaysian MyKad, passport, or equivalent) collected during KYC verification.

• Payment method details (eWallet identifier, bank account number, FPX reference) — stored only in tokenised or masked form;
• Deposit and withdrawal transaction history;
• Account balance history;
• Bonus and promotional credit history.

• Game session history (titles played, duration, stakes, outcomes);
• Sportsbook betting history (markets, selections, stakes, settlement outcomes);
• Responsible gaming tool usage (limit settings, self-exclusion history);
• Bonus eligibility and wagering progress.

• IP address and approximate geolocation at the time of login;
• Device type, operating system, and browser;
• Session timestamps and login event log;
• Cookie and session identifiers.

• Customer support interaction records (live chat transcripts, email correspondence);
• Complaint and dispute records;
• Marketing communication preferences and opt-out status.

85xo collects personal data through the following channels:

• Directly from you — during account registration, KYC verification, deposit and withdrawal requests, customer support interactions, and when you update your Account Settings;
• Automatically — through your use of the Platform, including session cookies, server logs, and analytics tools that record technical and behavioural data;
• From third parties — including payment service providers (to confirm transaction status), identity verification services (to complete KYC), fraud prevention services, and where required, regulatory or law enforcement authorities.

85xo processes personal data on the following legal bases:

1. Contractual necessity: Processing required to perform the contract between you and 85xo — including operating your Account, processing deposits and withdrawals, and delivering gaming products;
2. Legal obligation: Processing required to comply with anti-money laundering regulations, licensing requirements, tax obligations, and reporting obligations to regulatory bodies;
3. Legitimate interests: Processing undertaken for fraud detection, platform security, responsible gaming monitoring, business analytics, and product improvement, where such interests are not overridden by your rights;
4. Consent: Processing of non-essential communications (marketing emails, SMS promotions) where consent has been obtained and not subsequently withdrawn.

85xo uses the personal data we hold for the following purposes:

• Account management: Registration, verification, login authentication, and account maintenance;
• Transaction processing: Handling deposits via Touch n Go eWallet, Boost, FPX, and bank transfer; processing withdrawal requests; crediting bonuses;
• KYC & regulatory compliance: Verifying identity and age (21+ requirement), conducting anti-money laundering checks, and reporting to regulatory authorities as required;
• Responsible gaming: Monitoring gaming behaviour for signs of problem gambling; enforcing self-exclusion periods and deposit limits set by the player;
• Fraud prevention: Detecting duplicate accounts, suspicious transaction patterns, and technical exploitation attempts;
• Customer support: Responding to account queries, payment disputes, and technical issues via live chat and email;
• Platform improvement: Analysing aggregate usage data to optimise the 85xo Platform, game catalogue, and user experience;
• Marketing communications: Sending personalised promotions, bonus offers, and platform news to players who have not opted out.

85xo does not sell your personal data to any third party. We share personal data only in the following circumstances:

• Payment service providers: To process deposits and withdrawals — including Touch n Go, Boost, and FPX-connected banks — in a tokenised or masked form sufficient to process the transaction;
• KYC and identity verification providers: Third-party verification services used to confirm identity documents and age during KYC, under contractual data processing agreements;
• Game software providers: Game studios and live dealer platform operators (such as Evolution, Pragmatic Play, PG Soft) receive session data necessary to operate the game — providers operate under their own data processing agreements with 85xo;
• Regulatory and law enforcement authorities: Where required by law, court order, or request from a competent regulatory or law enforcement body;
• Fraud prevention services: Aggregated or flagged account data may be shared with cross-operator fraud prevention networks under applicable regulatory frameworks;
• Corporate transactions: In the event of a merger, acquisition, or sale of substantially all assets of 85xo, personal data may be transferred to the acquiring entity subject to equivalent privacy protections.

Some of the third parties described in Section 7 may be located in jurisdictions outside Malaysia. Where personal data is transferred internationally, 85xo takes steps to ensure adequate protection is in place through contractual data processing agreements that require the recipient to protect the data to a standard equivalent to this Privacy Policy.

By using the 85xo Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Malaysia for the purposes described in this Policy, where such transfer is required to deliver the contracted services.

85xo retains personal data for the following periods:

• Active account data: Retained for the full duration your 85xo account remains open;
• Post-closure account data: Identity, transaction, and gaming records are retained for a minimum of five (5) years following account closure, as required under anti-money laundering regulations and gaming licence obligations;
• KYC documentation: Retained for the period required under applicable AML regulations — typically five (5) years from the end of the customer relationship;
• Customer support records: Retained for two (2) years from the date of the interaction;
• Technical logs: Server and access logs retained for twelve (12) months.

Where retention is based solely on consent and consent is withdrawn, 85xo will delete or anonymise the relevant data promptly, except where retention is required by law.

85xo uses the following categories of cookies on the Platform:

• Essential cookies: Required for the Platform to function — including session authentication tokens that maintain your 85xo login state. These cannot be disabled without impairing Platform functionality;
• Functional cookies: Store user preferences such as language settings, game lobby view preferences, and responsible gaming reminder intervals;
• Analytics cookies: Collect aggregated and anonymised data on Platform usage — including page visit frequency, game category preferences, and navigation flow — used internally to improve the Platform. No personal gaming data is shared with external analytics vendors in identifiable form;
• Security cookies: Used to detect fraudulent activity, duplicate account attempts, and automated access patterns.

85xo does not use third-party advertising cookies or cross-site tracking technology. You may manage cookie preferences in your browser settings; note that disabling essential cookies will affect Platform functionality, including the ability to maintain a logged-in session.

Subject to applicable law and 85xo's regulatory obligations, you hold the following rights regarding your personal data:

1. Right of Access: You may request a copy of the personal data 85xo holds about you;
2. Right to Rectification: You may request correction of inaccurate or incomplete personal data;
3. Right to Erasure: You may request deletion of personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations;
4. Right to Restrict Processing: You may request that processing of your data be restricted in certain circumstances;
5. Right to Data Portability: You may request that personal data be provided in a structured, machine-readable format where technically feasible;
6. Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing;
7. Right to Object: You may object to processing based on legitimate interests, including profiling for responsible gaming monitoring purposes.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Rights Request" and include your registered email address and Account username for verification. Requests will be acknowledged within 5 business days and fulfilled within 30 days.

85xo implements the following technical and organisational security measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data in transit between your device and 85xo servers;
• Encryption at rest for sensitive stored data including payment method tokens and identity documents;
• Role-based access controls limiting employee access to personal data to those with a legitimate need;
• Multi-factor authentication required for administrative access to systems containing personal data;
• Regular third-party penetration testing and security audits;
• Incident response procedures for detection, containment, and notification in the event of a data breach.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 85xo will notify affected users and relevant authorities in accordance with applicable breach notification obligations.

The 85xo Platform is strictly intended for adults who are 21 years of age or older. 85xo does not knowingly collect personal data from persons under 21. If we become aware that personal data has been submitted by or on behalf of a person under 21, the relevant Account will be suspended immediately, all data will be securely deleted (subject to any mandatory retention for regulatory reporting), and deposited funds will be returned following investigation.

If you believe a minor has created a 85xo account, please contact [email protected] immediately.

85xo may update this Privacy Policy from time to time to reflect changes in our data practices, Platform features, or applicable law. Material updates will be communicated to registered account holders via email to the address on file and/or via a prominent notice on the Platform prior to the change taking effect.

The "Last Updated" date at the top of this document indicates when the Policy was most recently revised. Continued use of the 85xo Platform following the effective date of a material update constitutes acceptance of the revised Privacy Policy.

For any questions, concerns, or requests related to this Privacy Policy or our data processing practices, please contact:

• Email: [email protected] (plain text only — not a clickable link)
• Subject: "Privacy Policy Enquiry" or "Data Rights Request"
• Live chat: Available 24/7 on 85xo.app when logged in to your account
• Response time: Within 5 business days for written requests; live chat responds immediately