Privacy Policy

1. Introduction

Hitogel ("we", "us", "our", "the Platform") operates the online casino and sports betting services accessible at hitogel.cam and any associated subdomains or applications. We are committed to protecting the privacy and personal data of all individuals who access, register on, or interact with our platform — including players located across Malaysia in cities such as Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam.

This Privacy Policy has been prepared to inform you clearly and honestly about how Hitogel handles your personal data. It describes what information we collect, why we collect it, how we use it, with whom we may share it, how long we retain it, and what rights you have in relation to it. This Policy applies to all registered players, prospective players who browse the platform without registering, and any individual who contacts our support team.

By accessing or using the Hitogel platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any aspect of this Policy, you should discontinue use of the platform and contact us to request account closure if you are a registered user.

2. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person. This includes, but is not limited to, names, identification numbers, location data, email addresses, IP addresses, and financial information.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Subject" means the individual whose Personal Data is being processed — in the context of this Policy, primarily the registered player or platform visitor.
• "KYC Data" means identity verification information collected during the Know Your Customer process, including government-issued identification documents such as a Malaysian MyKad or passport.
• "Third Party" means any entity other than Hitogel and the Data Subject, including payment processors, technology service providers, and regulatory authorities.
• "Cookies" means small text files placed on a user's device by the platform for the purposes of session management, analytics, and personalisation.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement by the Data Subject to the processing of their Personal Data for a stated purpose.

3. Data We Collect

Hitogel collects only the Personal Data that is necessary for the purposes set out in this Policy. The categories of data we collect are described below.

3.1 Registration and Account Data

• Full legal name as it appears on your government-issued identification
• Date of birth (required to verify the 21+ age eligibility requirement)
• Residential address, including postcode and state within Malaysia or other applicable jurisdiction
• Email address and contact telephone number
• Username and encrypted account password
• Preferred currency (Malaysian Ringgit — MYR)

3.2 Identity Verification (KYC) Data

• Copy of government-issued photo identification (Malaysian MyKad, Malaysian passport, or equivalent)
• Proof of residential address (utility bill, bank statement, or equivalent, not older than 90 days)
• Proof of payment method ownership, where required for withdrawal processing
• Facial verification data, where applicable as part of enhanced verification procedures

3.3 Financial and Payment Data

• Deposit and withdrawal transaction records, including amounts in MYR and timestamps
• Payment method identifiers (e.g., masked e-wallet account numbers for Touch 'n Go eWallet, Boost, GrabPay, DuitNow; bank account references for Maybank2u, CIMB Clicks, Public Bank, Hong Leong Connect, FPX)
• Cryptocurrency wallet addresses used for USDT TRC20 transactions
• Account balance history and withdrawal request records

3.4 Gameplay and Behavioural Data

• Game session logs, including games played, bet amounts, outcomes, and session duration
• Sports betting history, including markets selected, odds accepted, and results
• Bonus and promotion usage records
• VIP tier progression and loyalty program activity
• Responsible gambling tool usage, including deposit limit settings and self-exclusion requests

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Platform access logs, including login timestamps and session identifiers
• Cookie data and similar tracking identifiers (see Section 10)

3.6 Communications Data

• Records of live chat support conversations with the Hitogel support team
• Email correspondence submitted to [email protected]
• Feedback, complaints, or dispute records

4. How We Collect Your Data

Hitogel collects Personal Data through the following mechanisms:

• Direct submission: Information you provide when registering an account, completing KYC verification, submitting a deposit or withdrawal request, or contacting support.
• Automated collection: Technical data collected automatically as you browse and use the platform, including via cookies, server logs, and analytics tools.
• Third-party payment processors: Transaction confirmation data received from payment partners including e-wallet providers, Malaysian banks, and cryptocurrency networks when processing your deposits and withdrawals.
• Identity verification services: Where Hitogel engages third-party KYC providers to assist in verifying identity documents, data may flow between those providers and Hitogel in accordance with our data sharing agreements.
• Fraud and risk detection systems: Automated systems that analyse platform usage patterns to detect potentially suspicious activity, generating derived data used for security and compliance purposes.

5. Data Processing & Purpose of Use

Hitogel processes your Personal Data solely for the purposes described below. We do not process Personal Data for purposes incompatible with those stated in this Policy without first seeking your consent or establishing a separate lawful basis.

6. Legal Basis for Processing

Hitogel processes Personal Data on the following legal bases, which are individually identified against each processing activity in Section 5 above:

• Contractual Necessity: Processing is necessary to perform our contractual obligations to you as a registered player — including account management, payment processing, and game delivery.
• Legal Obligation: Processing is required to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) obligations, KYC requirements, responsible gambling regulations, and data retention obligations imposed by our licensing authority.
• Legitimate Interests: Processing is necessary for Hitogel's legitimate business interests — including fraud prevention, platform security, and analytical improvement of our services — provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where processing is based on your consent — such as marketing communications or certain analytics — you retain the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

Hitogel does not sell, rent, or trade your Personal Data to any third party for commercial purposes. We share your data only in the circumstances described below, and only to the extent strictly necessary for each stated purpose.

7.1 Payment Service Providers

To process your deposits and withdrawals, Hitogel shares relevant transaction data with authorised payment processors. For Malaysian players, this includes gateway providers that facilitate transactions via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect, and USDT TRC20 cryptocurrency networks. These providers are contractually obligated to process your data only for the stated payment purpose.

7.2 Identity Verification Providers

Hitogel may engage third-party KYC service providers to assist in verifying identity documents and conducting age verification (21+). These providers are bound by strict data processing agreements and may not use your data for any purpose beyond the verification service they provide.

7.3 Regulatory and Law Enforcement Authorities

Hitogel may be required by law, court order, or regulatory directive to disclose your Personal Data to competent authorities. This includes disclosures required under applicable anti-money laundering frameworks, gaming licensing conditions, or court-ordered discovery processes. We will endeavour to notify you of any such disclosure where permitted by law.

7.4 Technology and Infrastructure Providers

Hitogel uses third-party cloud hosting, security, and analytics infrastructure to operate the platform. These providers process data on Hitogel's behalf as data processors and are bound by data processing agreements that restrict their use of your information.

8. International Data Transfers

As an internationally licensed platform, Hitogel may transfer your Personal Data to countries outside of Malaysia in connection with the operation of its services — for example, to cloud infrastructure providers or KYC verification partners located in other jurisdictions.

Where such transfers occur, Hitogel ensures that appropriate safeguards are in place to protect your data, including the use of standard contractual clauses, data processing agreements with equivalent protections, or other lawful transfer mechanisms recognised under applicable data protection frameworks.

If you would like information about the specific safeguards governing any international transfer of your data, please contact us using the details in Section 15.

9. Data Retention

Hitogel retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulatory obligation.

• Account and KYC data: Retained for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping obligations.
• Financial transaction records: Retained for a minimum of five (5) years following each transaction date, as required by applicable financial regulations.
• Gameplay and betting history: Retained for the duration of account activity plus three (3) years following account closure, for responsible gambling monitoring and dispute resolution purposes.
• Customer support communications: Retained for three (3) years from the date of the relevant interaction.
• Technical and device data: Retained for up to twelve (12) months for platform security and fraud detection purposes, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with our internal data lifecycle procedures.

10. Cookies & Tracking Technologies

The Hitogel platform uses cookies and similar tracking technologies to support platform functionality, maintain your session when logged in, analyse usage patterns, and improve the overall player experience.

10.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for core platform functionality, including session authentication and security. These cannot be disabled without impairing your ability to use the platform.
• Functional Cookies: Used to remember your preferences, such as language settings and deposit method selections, to improve your experience on return visits.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate and use the platform, helping us identify areas for improvement. These are subject to your consent where required.
• Security Cookies: Used by fraud detection and platform integrity systems to identify and mitigate suspicious access patterns.

10.2 Managing Cookies

You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Hitogel platform. For full instructions on managing cookies in your specific browser, refer to your browser's help documentation.

11. Your Rights as a Data Subject

Subject to applicable data protection law, you have the following rights in relation to your Personal Data held by Hitogel. To exercise any of these rights, please contact us using the details in Section 15. We will respond to all valid requests within 30 days.

Note that certain rights may be subject to limitations where processing is required for legal compliance or regulatory purposes — for example, we cannot delete KYC data that is subject to mandatory anti-money laundering retention requirements.