Privacy Policy — neo108

This Privacy Policy ("Policy") issued by neo108 ("Company", "PlatformWe", "Us", "Our") and applies to all personal data collected from individuals ("User", "Player", "You") who access or use the neo108 online gambling platform athttps://neo108.click and all related subdomains and mobile-optimised interfaces (collectively, the "Platform").

neo108 is committed to handling your personal information with the highest standards of data protection. This Policy is drafted in alignment with internationally recognised data protection principles, including those reflected in the General Data Protection Regulation (GDPR) framework, and is intended to provide full transparency to our users — particularly Malaysian players in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and across Malaysia.

By registering an account on the neo108 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read in conjunction with our Terms & Conditions.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

neo108 collects the following categories of personal data in the course of providing its services:

Personal data is collected through the following channels:

• Account Registration: Data provided by the User when completing the sign-up form on the Platform, including username, email address, date of birth, and contact details.
• KYC Submission: Identity and address documents uploaded to the Platform in connection with account verification requirements.
• Deposit & Withdrawal Transactions: Financial data transmitted during payment processing via Maybank, CIMB, Public Bank, Hong Leong Bank, DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, or cryptocurrency walets (BTC, ETH, USDT).
• Gameplay Sessions: Automatically logged data relating to game participation, bet placement, session duration, and financial outcomes.
• Customer Support Interactions: Communications exchanged through live chat, email to[email protected], or any other support channel.
• Automated Technical Collection: IP addresses, device identifiers, browser fingerprints, and session cookies collected automatically when you access the Platform.
• Third-Party Identity Verification Providers: Results of identity checks conducted by our licensed KYC service partners on data you have submitted.

neo108 processes personal data only where a valid legal basis exists. The applicable legal bases are as follows:

• Contractual Necessity: Processing required to perform the contract between you and neo108 — i.e., to operate your account, process your bets, execute deposits and withdrawals, and provide customer support.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC identity verification, anti-money laundering (AML) reporting, and age verification requirements under our international gaming licence.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gambling monitoring, and internal analytics, where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for non-essential marketing communications and optional personalisation features, where you have provided explicit, freely given, and withdrawable consent. You may withdraw consent at any time by updating your communication preferences in your account settings.

Your personal data is used for the following specific purposes:

• Account Creation & Management: Creating and maintaining your registered neo108 account, including authentication and access control.
• Age & Identity Verification: Confirming that you meet the minimum age requirement of21 years and that the identity information you have provided is accurate and not fraudulent.
• Payment Processing: Facilitating deposits and withdrawals through Malaysian payment channels including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay Maybank, CIMB, Public Bank, Hong Leong Bank, and supported cryptocurrency wallets.
• Fraud & Security Monitoring: Detecting and preventing fraudulent account activity, multi-accounting, bonus abuse, money laundering, and unauthorised access attempts.
• Responsible Gambling Compliance: Monitoring gambling patterns to identify signs of problematic behaviour, applying self-imposed limits, and meeting our licensing obligations in relation to player protection.
• Customer Support: Responding to enquiries, resolving disputes, and maintaining records of support interactions for quality assurance and compliance purposes.
• Platform Improvement: Analysing anonymised usage data to improve game offerings, payment flow, and user interface performance across desktop and mobile.
• Marketing Communications: Sending promotional emails, bonus notifications, and platform updates — only to Users who have opted in to marketing communications and compliance with applicable laws.
• Legal & Regulatory Compliance: Meeting our obligations under the terms of our international gaming licence, including record-keeping, audit trails, and cooperation with lawful requests from regulatory or law enforcement authorities.

neo108 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the following limited and controlled circumstances:

• Licensed Payment Processors: Financial data is shared with licensed payment service providers (including operators of DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, and banking institutions) strictly to process your deposit and withdrawal transactions.
• KYC & Identity Verification Partners: Identity documents submitted by Users are processed by contracted KYC service providers under strict data processing agreements. These providers are prohibited from using your data for any purpose other than identity verification on behalf of neo108.
• Gaming Technology Providers: Minimal technical data (such as anonymised session identifiers) may be shared with certified game studio partners to ensure seamless game delivery and to investigate technical disputes.
• Fraud Prevention Services: IP addresses, device fingerprints, and behavioural signals may be shared with contracted fraud detection technology providers to identify and prevent abuse.
• Legal & Regulatory Authorities: neo108 may disclose personal data to competent legal, regulatory, or law enforcement authorities where required by a valid legal order, court ruling, or regulatory requirement. We will notify affected Users of such disclosure where legally permitted to do so.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or substantially all of neo108's assets, personal data may be transferred to the successor entity, subject to equivalent data protection obligations.

neo108 operates under an international gaming licence, and certain data processing activities — including cloud data storage, payment gateway infrastructure, and KYC verification services — may involve the transfer of your personal data to countries outside of Malaysia.

Where personal data is transferred internationally, neo108 ensures that appropriate safeguards are in place, including the use of internationally recognised contractual standard clauses, transfers only to jurisdictions that provide an adequate level of data protection, or explicit contractual requirements imposed on the receiving party.

No international transfer of your personal data will occur for purposes beyond those described in this Privacy Policy.

neo108 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by applicable law or our licensing obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

The neo108 Platform uses cookies and similar tracking technologies to provide functionality, improve performance, and collect analytics data. The following categories of cookies are deployed:

• Essential Cookies: Required for basic Platform functionality, including maintaining your login session, remembering account preferences, and ensuring secure authenticated access. These cookies cannot be disabled without impairing Platform usability.
• Analytics Cookies: Used to collect anonymised information about how visitors use the Platform — including pages viewed, session duration, and navigation paths. This data helps us improve Platform performance and game lobby layout.
• Functional Cookies: Store optional preferences such as your preferred display language, game history, and notification settings to personalise your Platform experience.
• Security Cookies: Deployed to detect fraudulent activity, multi-accounting behaviour, and unauthorised access attempts by correlating session and device data.

You can manage and disable non-essential cookies through your browser's settings. Note that disabling essential cookies will affect your ability to log in and use core Platform features. For detailed instructions on managing cookies in your browser (Chrome, Safari, Firefox, Edge), please refer to your browser's official help documentation.

neo108 does not use advertising or cross-site tracking cookies. We do not deploy pixel tracking from third-party advertising networks on this Platform.

As a data subject, you have the following rights in relation to your personal data held by neo108. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request".

Right of Access: You may request a copy of all personal data we hold about you. We will respond within 30 calendar days of receipt of a verified request.

Right to Rectification: If any personal data we hold is inaccurate or incomplete, you may request that it be corrected. Some corrections may require submission of supporting documentation for verification.

Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data. Please note that we may be required to retain certain data under our licensing obligations, AML regulations, or financial record-keeping requirements, in which case we will inform you of the applicable retention basis.

Right to Data Portability: You may request a structured, commonly used, machine-readable export of personal data you have provided to us, where technically feasible.

neo108 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• Encryption at Rest: All personal data stored in neo108's systems is encrypted using AES-256 encryption standards.
• Encryption in Transit: All data transmitted between your browser or device and the neo108 Platform is protected by TLS 1.2 or higher (SSL) encryption. The Platform enforces HTTPS exclusively.
• Access Controls: Strict role-based access controls limit which employees and system components can access personal data. Access logs are maintained and audited regularly.
• Two-Factor Authentication: Account-level 2FA is available to all registered Players and is mandatory for administrative access to Platform backend systems.
• Penetration Testing: The Platform undergoes regular third-party security assessments and penetration testing to identify and remediate vulnerabilities.
• Incident Response: neo108 maintains a documented data breach response procedure. In the event of a security incident that poses a risk to your rights and freedoms, we will notify affected Users and relevant authorities in accordance with applicable obligations.

While we apply industry-standard security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account login credentials and should notify us immediately at [email protected] if you suspect unauthorised access to your account.

The neo108 Platform is strictly intended for persons aged21 years and above. We do not knowingly collect or process personal data from individuals under the age of 21. All accounts must pass KYC age verification before withdrawal features are activated.

If we become aware that personal data has been collected from a person under the age of 21 without verified parental consent — or in breach of our age restriction policy — we will immediately suspend the relevant account and delete the associated personal data, subject to any legal retention obligations.

If you have reason to believe that a minor has registered an account on neo108, please contact us immediately at [email protected] so that we can take prompt remedial action.

The neo108 Platform does not contain links to third-party websites for commercial or advertising purposes. All navigation links on the Platform point exclusively to internal pages within the neo108 domain. We do not embed third-party advertising iframes or affiliate tracking pixels.

Where you access neo108 through a third-party payment application (such as the Touch 'n Go eWallet, Boost, or GrabPay app) to initiate a deposit or withdrawal, that application's own privacy policy will govern the processing of your data within their environment. neo108 is not responsible for the data practices of third-party payment service providers, and we recommend reviewing their respective privacy policies independently.

neo108 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or Platform functionality. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page.
• Post a prominent notice on the Platform informing Users of the update.
• Where practicable, send an email notification to all registered Users' email addresses on file.

Your continued use of the neo108 Platform following the publication of any revised Privacy Policy constitutes your acceptance of the updated terms. We recommend reviewing this Policy periodically to remain informed of how your personal data is being handled.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by neo108, please contact our Data Privacy team using the details below. All privacy-related enquiries will be handled with strict confidentiality.