Privacy Policy

01 Introduction

Holigambet ("we", "us", "our", "the Platform", "the Operator") operates the online gaming platform accessible at holigambet.cam and any associated applications or interfaces provided under the Holigambet brand. We are committed to safeguarding the privacy of every individual ("you", "the User", "the Player") who interacts with our platform.

This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect personal data in connection with your use of the Holigambet platform and services. It also sets out your rights in relation to your personal data and how you may exercise them.

By registering an Account, making a deposit, or otherwise using the Holigambet platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. This Policy should be read together with our Terms & Conditions and our Responsible Gambling Policy.

02 Definitions

The following terms carry the meanings assigned below throughout this Policy:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, date of birth, contact details, identification documents, financial information, and online identifiers.
• "Processing" — any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. Holigambet acts as Data Controller in respect of all personal data processed under this Policy.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller, under written instruction and subject to confidentiality obligations.
• "Consent" — a freely given, specific, informed, and unambiguous indication of the data subject's agreement to the processing of their personal data for a stated purpose.
• "KYC Data" — identity and verification documents submitted by a Player for the purpose of satisfying Know Your Customer compliance obligations, including government-issued photo identification and proof of address.
• "Transaction Data" — records of financial activity associated with a Player's Account, including deposits, withdrawals, wager histories, and payment method details.

03 Data Controller Identity

The Data Controller responsible for personal data collected and processed in connection with the Holigambet platform is the legal entity operating under the Holigambet brand pursuant to its international online gaming licence. For all privacy-related enquiries, the Controller can be reached at the contact details set out in Section 16 of this Policy.

Where Holigambet engages third-party service providers — such as payment processors, KYC verification services, live game studio operators, and fraud prevention analytics providers — those entities act as Data Processors on our behalf under contractual arrangements that require them to process personal data only on our documented instructions and to maintain appropriate security measures.

04 Personal Data We Collect

We collect personal data through a number of channels — directly from you when you register or interact with the platform, automatically through your use of the platform, and in some cases from third-party sources as part of our compliance obligations.

4.1 Data You Provide Directly

4.2 Data Collected Automatically

4.3 Data from Third Parties

We may receive personal data from third-party sources including payment processors (confirming transaction status and payment method ownership), KYC verification service providers (identity confirmation and sanctions screening results), and fraud prevention analytics platforms. Data received from these sources is processed in accordance with this Policy and the applicable contractual arrangements with those third parties.

05 Purposes of Data Processing

Holigambet processes your personal data for the following specific purposes:

• Account Registration & Management: Creating and maintaining your Holigambet Account, authenticating your identity at login, and managing your Account preferences and settings.
• KYC & Age Verification: Verifying that you meet the minimum age requirement of 21 years, confirming your identity in compliance with international anti-money laundering (AML) and Know Your Customer (KYC) obligations.
• Payment Processing: Facilitating deposits and withdrawals via your selected payment methods, including FPX, DuitNow, Maybank, CIMB, Public Bank, Hong Leong Bank, Touch 'n Go eWallet, Boost, GrabPay, and supported cryptocurrency networks.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, money laundering, and other illicit or prohibited conduct on the platform.
• Platform Provision & Improvement: Delivering and continuously improving the Holigambet platform, including sports betting markets, live casino services, and game library features.
• Responsible Gambling: Monitoring gambling patterns to identify signs of problem gambling behaviour, enforcing deposit limits and self-exclusion requests, and fulfilling our responsible gambling obligations.
• Customer Support: Responding to your enquiries, resolving complaints, and providing technical assistance through our 24/7 English-language support team.
• Marketing Communications: Sending promotional offers, bonus notifications, and news relevant to your Account — only where you have provided valid consent, and subject to your opt-out right at any time.
• Legal Compliance: Fulfilling obligations under international gaming licensing requirements, anti-money laundering regulations, and any applicable court orders or regulatory directives.

06 Legal Basis for Processing

Holigambet relies on the following legal bases to process your personal data, consistent with internationally recognised data protection frameworks:

• Contractual Necessity: Processing necessary to perform the contract between you and Holigambet — including Account creation, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable international laws and regulations, including AML/KYC obligations and international gaming licensing requirements.
• Legitimate Interests: Processing necessary for Holigambet's legitimate interests — including fraud prevention, platform security, and responsible gambling monitoring — where those interests are not overridden by your data protection rights.
• Consent: Processing based on your explicit consent, primarily for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Sharing of Personal Data

Holigambet does not sell, rent, or trade your personal data to third parties for their independent commercial use. We share personal data with third parties only in the following defined circumstances:

• Payment Service Providers: Sharing financial data necessary to process deposits and withdrawals with our integrated payment partners, including FPX operators, DuitNow, e-wallet providers (Touch 'n Go, Boost, GrabPay), and cryptocurrency transaction processors.
• KYC & Compliance Providers: Sharing identity documents and related data with third-party KYC verification services and sanctions screening databases for the purpose of regulatory compliance.
• Fraud & Security Analytics: Sharing technical and behavioural data with fraud prevention providers to detect and prevent illicit account activity.
• Game Studio Operators: Sharing limited Account data (session tokens, balance confirmations) with third-party live dealer studio operators and slot game providers to enable game access — these providers are bound by confidentiality obligations.
• Legal Authorities: Disclosing personal data to law enforcement, regulatory bodies, or courts where required by applicable law or valid legal process. We will notify you of such disclosure where legally permitted to do so.
• Corporate Restructuring: In the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred to the acquiring entity subject to equivalent privacy protections.

08 International Data Transfers

As an internationally licensed online gaming platform, Holigambet may process and store personal data on servers located outside Malaysia. Where personal data is transferred internationally — including to our payment processors, KYC providers, and infrastructure partners — we take reasonable steps to ensure that appropriate safeguards are in place to protect your personal data at the receiving end, including contractual data protection clauses with all third-party processors.

By using the Holigambet platform, you acknowledge and consent to the transfer of your personal data outside your country of residence to the extent necessary for the provision of our services.

09 Data Retention

We retain personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable international regulations. The following general retention periods apply:

• Active Account Data: Retained for the full duration of the active Account relationship.
• KYC & Identity Documents: Retained for a minimum of five (5) years following Account closure, in compliance with international AML record-keeping obligations.
• Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, or longer where required by applicable law.
• Support Communications: Retained for up to three (3) years following the resolution of the support interaction, unless the matter is subject to ongoing legal proceedings.
• Marketing Consent Records: Retained for the period of the consent plus a reasonable period thereafter for compliance demonstration purposes.

Upon expiration of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to an identified individual.

10 Data Security

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

• 256-bit TLS encryption for all data transmitted between your device and our servers;
• Encryption at rest for sensitive stored personal data using AES-256 or equivalent;
• Two-factor authentication (2FA) available for all player Accounts as an additional login security layer;
• Role-based access controls limiting internal data access to personnel with a legitimate business need;
• Regular third-party penetration testing and security audits of platform infrastructure;
• Dedicated fraud monitoring and intrusion detection systems operating in real time.

11 Cookies & Tracking Technologies

Holigambet uses cookies and similar tracking technologies on its platform. Cookies are small text files placed on your device to help us recognise you between sessions, maintain platform functionality, and gather analytics to improve the user experience.

11.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Store your preferences such as language settings, game lobby layout, and Account dashboard configurations.
• Analytics Cookies: Collect anonymised data about how users navigate the platform — which pages are visited most, session duration, and error occurrences — to help us improve performance.
• Security & Fraud Detection Cookies: Monitor session behaviour patterns to identify potentially fraudulent activity, bot traffic, or account takeover attempts.

11.2 Managing Cookies

You may configure your browser settings to refuse or delete cookies. Note that disabling strictly necessary cookies will impair your ability to log in and use the Holigambet platform. Disabling analytics cookies does not affect platform functionality but limits our ability to improve the platform based on usage data.

We do not use cookies to serve cross-site behavioural advertising or share your browsing data with advertising networks. Our cookie use is limited to the categories described above.

12 Your Data Rights

Subject to applicable data protection laws and the limitations necessitated by our legal and compliance obligations, you have the following rights in respect of your personal data held by Holigambet:

Note that certain rights may be limited where exercising them would conflict with Holigambet's legal obligations — for example, mandatory KYC record retention requirements may prevent immediate deletion of identity documents submitted for AML compliance purposes.

13 Minors & Age Policy

Holigambet's services are strictly intended for individuals aged 21 and above. We do not knowingly collect personal data from persons under the age of 21. Age verification is a mandatory step of the KYC process, and any Account found to belong to a person under 21 years of age will be immediately suspended.

If you become aware that a minor has registered an Account on Holigambet or has submitted personal data through our platform, please contact us immediately at the details in Section 16 so that we may take appropriate action, including deletion of the minor's data and closure of the Account.

14 Third-Party Services & Links

The Holigambet platform may display informational references to third-party services — such as payment method providers (Maybank, CIMB, Public Bank, Hong Leong Bank, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX) and game studio categories. We do not control the privacy practices of these third-party entities and are not responsible for their data handling.

Our platform does not contain hyperlinks to external third-party websites for advertising, marketing, or affiliate purposes. The navigation, payment, and service interactions on Holigambet are self-contained within the platform.

15 Amendments to This Policy

Holigambet reserves the right to update or amend this Privacy Policy at any time. Material changes to this Policy will be communicated to registered Players via the email address on file or through a prominent notice on the platform, with a minimum of fourteen (14) days' advance notice before the revised Policy takes effect — except where immediate amendment is required to comply with applicable legal obligations.

Your continued use of the Holigambet platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. The most current version of this Policy is always accessible at holigambet.cam/privacy-policy.

We recommend that you review this Policy periodically to stay informed about how Holigambet protects your personal data.

16 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the Holigambet Data Privacy team using the following details:

For requests to exercise your data rights — access, rectification, erasure, or portability — please include your full name and registered email address so we may verify your identity before fulfilling the request. Identity verification may be required prior to processing sensitive data requests.