Privacy Policy

1. Introduction

This Privacy Policy (the "Policy") is issued by abutogel (hereinafter referred to as "the Company", "we", "us", or "our"), the operator of the online gaming platform accessible at https://abutogel.cam (the "Platform"). It describes how we collect, use, store, disclose, and otherwise process personal data relating to users of the Platform ("you", "your", or "User"), in accordance with applicable international data protection principles and our licensing obligations.

This Policy applies to all personal data processed in connection with your use of the Platform, including data collected during account registration, deposits, withdrawals, gameplay, customer support interactions, and marketing communications. It should be read together with our Terms & Conditions, which govern the overall relationship between you and the Company.

We are committed to handling your personal data with care, transparency, and respect. If you have any questions about how we handle your data, please do not hesitate to contact us using the details provided in Section 16 of this Policy.

2. Definitions

For the purposes of this Policy, the following terms shall have the meanings ascribed to them below:

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, directly or indirectly, including name, identification number, location data, online identifier, or any combination of factors specific to the individual's physical, psychological, economic, or social identity.
• "Processing" means any operation performed on personal data, including collection, recording, storage, organisation, adaptation, retrieval, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, the Data Controller is the Company.
• "Data Processor" means any entity that processes personal data on behalf of the Data Controller, such as payment service providers or fraud detection partners.
• "KYC Data" means personal data collected during the Know Your Customer identity verification process, including government-issued identification documents and proof of address.
• "Sensitive Data" means categories of personal data that require a higher level of protection, such as financial information, identification documents, and data relating to a person's gambling behaviour.
• "Cookie" means a small text file placed on your device by a website server for the purpose of tracking browsing behaviour, maintaining sessions, and facilitating analytics.

3. Data Controller

The Data Controller responsible for your personal data is abutogel, operating the Platform at https://abutogel.cam. The Company holds an international gaming licence and processes personal data in accordance with the data protection requirements of its licensing jurisdiction and applicable international standards.

For all data protection enquiries, requests to exercise your rights, or to raise concerns about how your data is handled, please contact us at the details provided in Section 16 of this Policy.

4. Data We Collect

abutogel collects personal data from you directly (when you provide it) and indirectly (through your use of the Platform). The categories of personal data we collect are set out in the table below:

4.1 Data We Do Not Collect

abutogel does not intentionally collect special categories of sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data (other than as may be implied by responsible gambling tool usage), or biometric data (other than facial verification images submitted during KYC where required by our verification provider). Where any such data is incidentally disclosed in correspondence, it will not be processed for any purpose other than responding to your enquiry.

5. Purposes of Data Processing

We process your personal data for the following purposes:

• Account Registration and Management: To create, maintain, and administer your abutogel account, including processing login authentication and updating your account settings.
• Identity Verification (KYC): To verify your identity and age (21+) as required by our licensing obligations, to prevent underage gambling, and to fulfil anti-money-laundering (AML) compliance requirements.
• Payment Processing: To process deposits and withdrawals via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency networks; to verify payment method ownership; and to detect and prevent fraudulent transactions.
• Platform Operation and Service Delivery: To enable your use of all gaming, betting, and platform features, including processing wagers, calculating winnings, and administering loyalty programme rewards.
• Fraud Prevention and Security: To monitor for suspicious account activity, detect and prevent fraud, money laundering, collusion, and other prohibited conduct, and to protect the integrity of the Platform.
• Customer Support: To respond to your enquiries, complaints, and requests submitted via live chat, email, or other channels.
• Responsible Gambling: To administer the self-exclusion, deposit limit, and session control tools available on the Platform, and to identify players who may be exhibiting signs of problem gambling behaviour.
• Legal and Regulatory Compliance: To comply with applicable laws, regulations, licensing requirements, and lawful requests from regulatory or law enforcement authorities.
• Marketing and Communications: To send promotional offers, reload bonus notifications, tournament announcements, and other marketing materials where you have provided your consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.
• Platform Improvement and Analytics: To analyse usage patterns, game preferences, and technical performance data for the purpose of improving the Platform's features, design, and reliability.

6. Legal Basis for Processing

Where data protection law requires us to identify a legal basis for each processing activity, we rely on the following bases:

• Contract Performance: Processing that is necessary to fulfil our contractual obligations to you under the Terms & Conditions — primarily account management, payment processing, and service delivery.
• Legal Obligation: Processing required by law or our regulatory licensing obligations, including KYC/AML verification, record keeping, and reporting to competent authorities where required.
• Legitimate Interests: Processing that is necessary for our legitimate business interests, provided those interests are not overridden by your rights — including fraud prevention, platform security, responsible gambling monitoring, and service analytics.
• Consent: Processing based on your freely given, specific, and informed consent — primarily in the context of direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

abutogel does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your data with third parties only in the following circumstances:

7.1 Service Providers and Data Processors

We engage third-party service providers who process data on our behalf to support Platform operations. These include:

• Payment processing and e-wallet providers (including the operators of Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and local Malaysian banks).
• Identity verification and KYC solution providers.
• Fraud detection and risk assessment platforms.
• Cloud hosting and data storage infrastructure providers.
• Customer support software providers.
• Analytics platforms used for Platform performance and user experience improvements.

All third-party processors are required to process your data only on our instructions, to maintain appropriate security measures, and are prohibited from using your data for any purposes beyond those specified in their contractual agreement with us.

7.2 Legal and Regulatory Disclosure

We may disclose your personal data to law enforcement agencies, regulatory bodies, or other public authorities where we are required to do so by law, court order, or in connection with legal proceedings. We will notify you of any such disclosure where we are lawfully permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving the Company, your personal data may be transferred to the successor entity. In such circumstances, we will provide reasonable notice and ensure that your data continues to be protected by standards no less rigorous than those set out in this Policy.

8. International Data Transfers

As an internationally licensed platform, abutogel may transfer your personal data to countries outside your home jurisdiction. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data, including the use of contractual clauses that impose equivalent data protection obligations on the receiving parties.

Malaysian users should be aware that their data may be processed in jurisdictions whose data protection laws differ from those applicable in Malaysia. By using the Platform, you consent to such transfers subject to the safeguards described in this Policy.

9. Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or our regulatory obligations. The following indicative retention periods apply:

• Account and Transaction Data: Retained for a minimum of 5 years following account closure or the last transaction, as required by applicable AML and gaming regulations.
• KYC Documents: Retained for the duration of the account relationship and for a minimum of 5 years thereafter.
• Customer Support Records: Retained for up to 3 years from the date of the interaction.
• Marketing Preference Data: Retained until you withdraw your consent or opt out, plus a reasonable period thereafter to record the opt-out.
• Technical and Log Data: Typically retained for up to 12 months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised so that it can no longer be associated with you.

10. Data Security

abutogel implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• End-to-end 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Secure password hashing using industry-standard algorithms; we do not store passwords in plain text.
• Access controls and role-based permissions that restrict access to personal data to authorised personnel only.
• Regular security assessments and vulnerability testing of Platform infrastructure.
• Physical and logical security controls for data centre environments used to host Platform infrastructure.
• Incident response procedures to detect, report, and address data security breaches in a timely manner.

11. Cookies & Tracking Technologies

abutogel uses cookies and similar tracking technologies to operate the Platform, maintain your session, remember your preferences, and gather analytics data about how the Platform is used. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in during your visit. They cannot be disabled without affecting your ability to use the Platform.
• Functional Cookies: Used to remember your preferences, such as your preferred language, display settings, and last-used payment method.
• Analytics Cookies: Used to collect aggregated, anonymised information about how visitors use the Platform, which pages are most popular, and where errors occur. This information is used to improve the Platform.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats. These may include device fingerprinting tokens and challenge verification data.

You may control cookie behaviour through your browser settings. Disabling certain cookies may affect the functionality of the Platform. We do not use third-party advertising cookies or behavioural tracking cookies for the purpose of serving advertisements on external websites.

12. Your Data Rights

Subject to applicable data protection law and our regulatory obligations, you have the following rights in relation to your personal data held by abutogel:

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is processed. We will provide this information within a reasonable period of receiving a verified request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update certain details directly through your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw your consent (where consent was the legal basis for processing). Note that this right may be limited where we are required to retain data by law or for the establishment, exercise, or defence of legal claims.
• Right to Restrict Processing: In certain circumstances, you may request that we restrict the processing of your data — for example, while you contest the accuracy of the data we hold.
• Right to Data Portability: Where processing is based on your consent or on a contract, and is carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
• Right to Object: You have the right to object to processing based on our legitimate interests, including profiling, and to object to the processing of your data for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact our support team via live chat or email (see Section 16). We may require you to verify your identity before processing your request. We aim to respond to all verified requests within 30 calendar days.

13. Minors & Age Policy

The abutogel Platform is strictly for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account.

We employ automated and manual age verification mechanisms during the registration and KYC process to enforce this requirement. If you believe that a minor has registered an account on our Platform, please contact us immediately using the details in Section 16.

14. Third-Party Services & Links

The Platform may from time to time reference or direct you to third-party services, including payment providers such as Touch 'n Go eWallet, Boost, GrabPay, and Malaysian banking institutions. These third parties operate under their own privacy policies, and abutogel accepts no responsibility for the data practices of such third parties.

We encourage you to review the privacy policies of any third-party service you use in connection with your abutogel account, particularly before providing payment information or personal data to such services.

15. Amendments to This Policy

abutogel reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or Platform features. Where changes are material, we will provide reasonable advance notice by email to registered users or by displaying a prominent notice on the Platform.

The "Effective Date" at the top of this Policy indicates when the current version came into force. Your continued use of the Platform following the publication of a revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the manner in which abutogel processes your personal data, please contact us through one of the following channels:

• Live Chat: Available 24/7 directly from your account dashboard. This is the fastest channel for all enquiries, including data access requests.
• Email: [email protected] (displayed as plain text — not a clickable link).

For formal data subject requests (access, erasure, rectification, etc.), please clearly state "Data Subject Request" in the subject line of your email or live chat message, and include your registered username and email address to assist us in locating your records promptly.