Privacy Policy

1 Introduction

This Privacy Policy (hereinafter "Policy") is issued by hl365 (hereinafter "hl365", "we", "us", or "our"), the operator of the online gaming platform accessible at https://hl365.cam (hereinafter "the Platform"). This Policy applies to all natural persons (hereinafter "Users", "Players", "you", or "your") who access, register on, or otherwise interact with the Platform.

hl365 is committed to processing personal data in a lawful, fair, and transparent manner. This Policy explains: (a) what personal data we collect from you; (b) the purposes for which we process that data; (c) the legal basis on which we rely for each processing activity; (d) with whom we share your data; (e) how long we retain it; and (f) your rights as a data subject.

By creating an account on the Platform, making a deposit, or otherwise using hl365's services, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference.

2 Definitions

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

3 Data We Collect

3.1 Data You Provide Directly

When you register an account, verify your identity, make deposits or withdrawals, contact support, or participate in promotions, you provide us with the following categories of personal data:

• Identity data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., NRIC/MyKad number, passport number).
• Contact data: Email address, Malaysian mobile telephone number, and residential address (including postcode and state).
• Verification documents: Scanned copies or photographs of identity documents and proof of address submitted during KYC verification.
• Payment data: Payment method identifiers (e.g., GrabPay account reference, Touch 'n Go eWallet ID, FPX bank account last four digits, cryptocurrency wallet addresses, Maybank or CIMB account references). We do not store full payment card numbers or complete bank account numbers.
• Account credentials: Username and hashed password. We do not store passwords in plain text.
• Support communications: Records of all interactions with hl365 customer support, including live chat transcripts and email correspondence.

3.2 Data Collected Automatically

When you access the Platform, we automatically collect the following technical and behavioural data:

• Device data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Log data: Access timestamps, pages visited, features used, session duration, clickstream data, and error logs.
• Gaming activity data: Game session records, bet history, wagering amounts, win/loss records, bonus usage, and deposit and withdrawal transaction logs.
• Geolocation data: Approximate location derived from your IP address. We do not collect GPS-level location data.
• Cookie and tracking data: As described in Section 7 of this Policy.

4 How We Use Your Data

hl365 processes your personal data for the following specific purposes:

5 Legal Basis for Processing

hl365 processes personal data only where a valid legal basis exists. The primary legal bases on which we rely are as follows:

• Contractual necessity: Processing required to perform our contract with you as a Player — including account creation, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable laws — including KYC and AML verification, regulatory reporting, and retention of transaction records mandated by our operating licence.
• Legitimate interests: Processing conducted in pursuit of hl365's legitimate business interests — including fraud prevention, security monitoring, platform analytics, and responsible gambling monitoring — where those interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for direct marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing already carried out.

6 Data Sharing & Disclosure

hl365 does not sell or rent personal data to third parties. We share personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

6.1 Service Providers (Data Processors)

We engage trusted third-party service providers to support the operation of the Platform, including payment gateway operators (who process transactions through GrabPay, Touch 'n Go, DuitNow, FPX, and bank transfer systems), KYC and identity verification providers, cloud hosting and database infrastructure providers, fraud detection and security services, and customer support software providers. All service providers are bound by data processing agreements that restrict their use of your data to the specific services they provide on our behalf.

6.2 Regulatory and Law Enforcement Authorities

hl365 may disclose personal data to governmental bodies, regulatory authorities, licensing bodies, or law enforcement agencies where required to do so by applicable law, court order, or in response to a lawful request — including disclosures required under anti-money-laundering and counter-terrorism financing obligations.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of substantially all of hl365's assets, personal data held by hl365 may be transferred to the relevant successor entity. You will be notified of any such transfer and your rights in relation to the transferred data prior to the transfer taking effect.

6.4 Responsible Gambling Partners

Where a Player requests referral to external responsible gambling support services, limited personal data (name and contact details) may be shared with accredited support organisations to facilitate that referral, with the Player's knowledge and consent.

7 Cookies & Tracking Technologies

hl365 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit the Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling non-essential cookies will not affect your ability to use the core features of the Platform, but may limit personalisation features. hl365 does not use third-party advertising cookies or cross-site tracking technologies.

8 Data Retention

hl365 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to the following minimum retention periods required by law and licensing obligations:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by anti-money-laundering regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction in accordance with financial record-keeping obligations.
• KYC verification documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Support communications: Retained for three (3) years from the date of the last communication, unless the matter involves an unresolved legal dispute.
• Marketing consent records: Retained until consent is withdrawn, and for one (1) year thereafter as evidence of the consent previously granted.
• Self-exclusion records: Retained for the duration of the self-exclusion period and for five (5) years thereafter, to prevent re-registration in breach of the exclusion.

Upon expiry of the applicable retention period, personal data is securely deleted, destroyed, or anonymised so that it can no longer be associated with any identifiable individual.

9 Data Security

hl365 implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security measures include but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and hl365's servers;
• Encrypted storage of sensitive personal data at rest, including identity documents and payment information;
• Role-based access controls restricting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication (MFA) for internal administrative access to production systems;
• Regular security audits, vulnerability assessments, and penetration testing;
• Incident response procedures for detecting, containing, and reporting data breaches within required timeframes.

Notwithstanding these measures, no digital platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, hl365 will notify affected Players and relevant regulatory authorities within the timeframes required by applicable law.

10 Your Rights as a Data Subject

You have the following rights in relation to your personal data held by hl365. To exercise any of these rights, please contact us using the details in Section 15. We will respond to all valid requests within thirty (30) days of receipt.

Please note that some of these rights are subject to conditions and exceptions — for example, the right to erasure does not apply where hl365 is required to retain data to comply with a legal obligation. We will explain any applicable limitations when responding to your request.

11 Minors & Age Restriction

The hl365 Platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect, store, or process personal data from any person under the age of 21. Age verification is a mandatory component of our account registration and KYC processes.

If hl365 becomes aware — through our verification processes, player reports, or any other means — that personal data has been collected from a person under 21 years of age, we will take the following immediate steps: (a) permanently close the associated Account; (b) delete all personal data associated with that Account from our active systems; and (c) refund any deposits held in the Account to the extent possible after tracing the original payment source.

If you are a parent or guardian who believes that your child has registered on hl365, please contact us immediately via the details in Section 15 so that we can take prompt remedial action.

12 International Data Transfers

Some of hl365's data processors — including cloud infrastructure providers and KYC verification services — may be located outside Malaysia. Where personal data is transferred to a jurisdiction that does not provide the same level of data protection as the country in which the data was originally collected, hl365 ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by relevant data protection authorities;
• Binding corporate rules where applicable to group entities;
• Transfer only to countries recognised as providing an adequate level of data protection by the relevant supervisory authority;
• Supplementary technical measures (such as encryption) where additional protection is required.

You may contact us at the details in Section 15 if you wish to obtain a copy of the safeguards we have in place for any particular international transfer.

13 Third-Party Services & Links

The hl365 Platform may contain references to third-party payment processors and service providers whose privacy practices are governed by their own privacy policies — including but not limited to GrabPay, Touch 'n Go eWallet, Boost, and FPX payment services. hl365 is not responsible for the privacy practices of these third-party services and encourages you to review their privacy policies separately.

hl365 does not embed third-party advertising trackers, social media pixels, or cross-site behavioural analytics tools on the Platform. Any analytics tools used are configured to collect anonymised or pseudonymised data only and do not transmit personally identifiable information to external analytics platforms.

14 Amendments to This Policy

hl365 reserves the right to update or amend this Privacy Policy at any time. Material changes — including changes to the types of data we collect, the purposes for which we process it, or the third parties with whom we share it — will be communicated to registered Players via email notification at least fourteen (14) days before the amendment takes effect.

Minor administrative updates (such as corrections to contact details or typographical fixes) may be made without prior notice. The "Last updated" date at the top of this document will always reflect the date of the most recent revision. We recommend reviewing this Policy periodically.

Continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to any material change, you may close your Account before the amendment takes effect.

15 Contact Us & Complaints

If you wish to exercise any of your data subject rights, have a question about this Privacy Policy, or wish to lodge a complaint about how hl365 has handled your personal data, please use the following contact channels:

If you are not satisfied with hl365's response to a privacy complaint, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. hl365 will cooperate fully with any regulatory investigation conducted by a competent authority.