lele4d Privacy Policy

This Privacy Policy ("Policy") is published by lele4d ("Company", "we", "us", "our"), the operator of the online gaming platform accessible at lele4d.click. This Policy governs the collection, use, storage, sharing, and protection of personal data belonging to our Members and website visitors ("you", "User", "Data Subject").

lele4d is committed to safeguarding the privacy of every individual who interacts with our platform. We operate in compliance with applicable international data protection standards and the personal data protection frameworks relevant to our licensed operating jurisdiction. Our data practices are guided by principles of transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and accountability.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy. In the event of any conflict between this Policy and our Terms & Conditions, the Terms & Conditions shall prevail with respect to the contractual relationship between you and lele4d.

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

• "Personal Data" means any information that identifies or could reasonably identify a living natural person, either directly or in combination with other data.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, erasure, or destruction.
• "Data Controller" means lele4d, the entity that determines the purposes and means of Processing Personal Data.
• "Data Processor" means any third-party service provider that Processes Personal Data on behalf of lele4d under a binding data processing agreement.
• "Member" means any individual who has completed registration and holds an active or previously active Account on the lele4d Platform.
• "Account" means the registered user profile created upon completion of the lele4d registration process.
• "KYC" means Know Your Customer — the identity and age verification procedures required under applicable regulatory and anti-money-laundering obligations.
• "Cookies" means small data files stored on a user's device by the Platform's web server for session management, analytics, and personalisation purposes.
• "Platform" means the lele4d website, mobile applications, and all associated digital services operated at lele4d.click.

lele4d collects and processes the following categories of Personal Data in connection with your use of the Platform:

lele4d collects Personal Data through the following channels and mechanisms:

• Direct Provision by You: When you register an Account, complete KYC verification, make a deposit or withdrawal, contact our support team, participate in promotions, complete surveys, or otherwise communicate with us, you directly provide Personal Data to lele4d.
• Automated Technical Collection: When you access the Platform, our servers automatically record Technical Data including your IP address, device type, browser, and session behaviour through server logs, cookies, and similar tracking technologies.
• Payment Service Providers: When you conduct financial transactions using services such as DuitNow, FPX, Touch 'n Go eWallet, Maybank, CIMB, Public Bank, Hong Leong Bank, Boost, or GrabPay, our payment processing partners may transmit limited transactional confirmation data to us to verify the completion of your deposit or withdrawal.
• Identity Verification Partners: For KYC and age verification purposes, we may work with licensed third-party identity verification service providers who process your submitted ID documents on our behalf and return a verification outcome to us.
• Fraud Prevention and Analytics Providers: We use reputable third-party analytics and fraud detection tools that collect aggregated or pseudonymised behavioural and technical data to assist us in maintaining Platform security and improving user experience.

lele4d processes your Personal Data under the following lawful bases, as applicable to each specific Processing activity:

1. Contractual Necessity: Processing that is necessary to perform the contract between you and lele4d — specifically, to operate your Account, process your wagers and financial transactions, and deliver the gaming services you have requested. Without this Processing, we cannot provide you with Platform services.
2. Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money-laundering (AML) requirements, age verification mandates, gaming licence conditions, tax reporting obligations, and responses to lawful requests from regulatory authorities or law enforcement agencies.
3. Legitimate Interests: Processing necessary for the legitimate interests of lele4d where such interests are not overridden by your rights and freedoms — including fraud detection, Platform security, responsible gambling monitoring, internal analytics, and service improvement activities.
4. Consent: Where you have provided explicit, freely given, and informed consent for specific Processing activities — such as receiving optional marketing communications or participating in voluntary research surveys. You may withdraw consent at any time without affecting the lawfulness of prior Processing.

lele4d uses your Personal Data for the following specific purposes, each underpinned by a lawful basis identified in Section 5:

• Account Management: Creating, maintaining, and administering your Member Account, including processing login authentication and managing Account preferences.
• Gaming Services Delivery: Enabling your participation in sports betting (including Liga Super Malaysia, EPL, UFC), live casino games, slots, 4D lottery, and arcade games on the Platform.
• Financial Transaction Processing: Processing your deposits in MYR via your chosen payment method and processing withdrawal requests to your verified payment instrument.
• KYC and Age Verification: Verifying that you are aged 21 or above and that your identity matches the information provided during registration, as required by our regulatory obligations.
• AML and Fraud Prevention: Monitoring transactions and Account activity to detect, investigate, and prevent money laundering, fraudulent activity, and other financial crimes.
• Responsible Gambling Compliance: Administering self-exclusion requests, deposit limits, session limits, and reality checks; monitoring gaming patterns to identify potential problem gambling behaviours.
• Customer Support: Responding to your queries, resolving disputes, processing complaints, and providing technical assistance.
• Promotional Communications: Where you have given consent, sending you information about new promotions, bonus offers, and Platform updates relevant to your gaming preferences.
• Platform Improvement: Analysing aggregated and pseudonymised usage data to improve Platform features, user experience, and game content selection.
• Legal Compliance: Meeting our obligations to gaming regulators, tax authorities, and law enforcement agencies under applicable international frameworks.

lele4d does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data only in the following limited and controlled circumstances:

• Payment Service Providers: To process your financial transactions via DuitNow, FPX, Touch 'n Go eWallet, Maybank, CIMB, Public Bank, Hong Leong Bank, Boost, GrabPay, and cryptocurrency payment processors. These providers access only the data necessary to complete the specific transaction.
• Identity Verification Providers: To conduct KYC and age verification as required by our regulatory obligations. Providers operate under binding data processing agreements and are prohibited from using your data for any purpose beyond verification.
• Fraud Prevention and Security Partners: To support real-time fraud detection, IP analysis, and account security monitoring. Data shared with these partners is limited to technical and transactional identifiers.
• Game Content Providers: Our licensed international game studio partners receive limited technical session data necessary to render and record your participation in their respective games. Game providers do not receive your financial or identity data.
• Regulatory and Law Enforcement Authorities: Where we are legally required or compelled by a lawful order, warrant, or regulatory directive to disclose Personal Data to competent authorities. lele4d will notify affected Members of such disclosures where legally permitted to do so.
• Corporate Transactions: In connection with a merger, acquisition, restructuring, or sale of substantially all of lele4d's assets, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.

lele4d retains Personal Data for no longer than is necessary to fulfil the specific purpose for which it was collected, subject to overriding legal, regulatory, or contractual retention requirements. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of your Account's active status plus a minimum of five (5) years following Account closure, in compliance with AML regulatory retention mandates.
• Financial Transaction Records: Retained for a minimum of seven (7) years following each transaction, in accordance with applicable financial record-keeping regulations.
• KYC Documentation: Retained for a minimum of five (5) years from the date of submission or the date of Account closure, whichever is later.
• Gaming Activity Logs: Retained for five (5) years from the date of each recorded gaming session, for dispute resolution and regulatory audit purposes.
• Customer Support Communications: Retained for three (3) years from the date of the final communication in each support case.
• Technical and Behavioural Data (Cookies, Logs): Retained for periods between 30 days and 24 months depending on the specific data type and tracking purpose, as detailed in our Cookie Policy (Section 9).

Upon expiry of the applicable retention period, Personal Data is securely destroyed or permanently anonymised in accordance with our data deletion procedures. Where anonymisation is not technically feasible, pseudonymisation is applied.

lele4d uses cookies and similar tracking technologies (including pixel tags and local storage objects) to operate, secure, and improve the Platform. The following categories of cookies are employed:

• Strictly Necessary Cookies: Essential for the Platform to function. These cookies enable session management, user authentication, security token maintenance, and fraud prevention. They cannot be disabled without impairing your ability to use the Platform. No consent is required for their placement.
• Functional Cookies: Enable personalised features such as remembering your language preferences, last game played, and display settings. These improve your experience on the Platform but are not strictly necessary for core functionality.
• Analytics Cookies: Used to collect aggregated and pseudonymised data about how Members navigate and use the Platform, helping us identify popular features, page performance issues, and areas for improvement. These cookies do not directly identify individual users.
• Security and Fraud Detection Cookies: Used to identify unusual access patterns, automated bot activity, and potential Account compromise attempts. These work alongside our real-time fraud monitoring systems.

You may manage your cookie preferences through your browser settings. Please note that disabling Strictly Necessary Cookies will impair your ability to log in and use core Platform features. For a complete list of cookies used on the Platform and their specific retention periods, please contact our support team at [email protected].

lele4d implements a comprehensive, multi-layered information security framework to protect your Personal Data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the lele4d Platform is encrypted in transit using industry-standard Secure Sockets Layer (SSL) and Transport Layer Security (TLS) protocols.
• Encryption at Rest: Sensitive Personal Data stored in our databases — including identity documents, payment details, and account credentials — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data within lele4d is restricted on a strict need-to-know basis. All staff with data access are bound by confidentiality obligations and undergo regular data protection training.
• Two-Factor Authentication (2FA): Members are strongly encouraged to enable 2FA on their Accounts to add an additional layer of authentication security.
• Penetration Testing & Security Audits: Our Platform undergoes regular independent penetration testing and security audits to identify and remediate vulnerabilities proactively.
• Data Breach Response: lele4d maintains an incident response procedure for personal data breaches. In the event of a breach likely to result in risk to your rights, we will notify you and relevant regulatory authorities within the timeframes required by applicable law.

As a Data Subject whose Personal Data is processed by lele4d, you hold the following rights under applicable data protection frameworks. You may exercise these rights at any time by contacting us at [email protected]:

lele4d will respond to all verified data rights requests within 30 days of receipt. In complex cases, this period may be extended by a further 30 days, and you will be notified of the extension and the reason for it. We will not charge a fee for processing rights requests unless they are manifestly unfounded or excessive.

The lele4d Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain Personal Data belonging to persons under the age of 21.

lele4d enforces mandatory KYC age verification for all Accounts. Members who cannot demonstrate that they are aged 21 or above will not be permitted to access real-money gaming features, and their Accounts will be suspended pending investigation.

The lele4d Platform may contain references to or integrations with third-party payment processors, identity verification services, and game content providers. This Policy applies solely to Personal Data collected and processed by lele4d in its capacity as Data Controller.

Third-party service providers — including payment gateways such as DuitNow, Maybank, CIMB, Touch 'n Go eWallet, Boost, and GrabPay — operate under their own independent privacy policies. lele4d is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of lele4d.

All third-party Data Processors engaged by lele4d are bound by written data processing agreements that require them to process Personal Data only in accordance with our documented instructions, to implement appropriate security measures, and to assist us in meeting our data protection obligations.

lele4d reserves the right to revise, update, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or Platform features. The "Last Updated" date at the top of this page will be revised upon each update.

Where amendments are material — meaning they significantly affect your rights or the way we process your Personal Data — we will provide advance notice via email to your registered address and by displaying a prominent notification on the Platform for a minimum of 14 days prior to the revised Policy taking effect.

Your continued use of the Platform following the effective date of a revised Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you must cease using the Platform and close your Account before the effective date.

For any queries, concerns, or requests relating to this Privacy Policy or your Personal Data rights, please contact our Data Protection team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week directly on the lele4d Platform. Average first response under 3 minutes.
• Email: [email protected] — responses within 2 to 6 hours for general enquiries; formal data rights requests acknowledged within 3 business days.

For formal data protection correspondence, please include the subject line "Data Privacy Request" in your email to ensure it is routed directly to our compliance team. We aim to acknowledge all data rights requests within 3 business days and provide a substantive response within 30 days.