Privacy Policy — sisil4d

Introduction

sisil4d ("we", "us", "our", "the Platform") is committed to protecting and respecting the privacy of every individual who registers an account, visits our website, or otherwise interacts with our services. This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

This Policy applies to all personal data processed through the website located at sisil4d.cam and any related services, applications, or communications. By creating a sisil4d account or using our Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy is to be read in conjunction with our Terms & Conditions. Capitalised terms not defined in this Policy carry the meanings assigned to them in our Terms & Conditions.

Definitions

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

• "Personal Data" means any information that identifies or could be used to identify a natural person, directly or indirectly. This includes name, date of birth, email address, phone number, IP address, device identifiers, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, sisil4d acts as the Data Controller in respect of all Personal Data submitted through the Platform.
• "Data Subject" means the natural person to whom Personal Data relates — in this context, you, the registered User or website visitor.
• "Third Party" means any natural or legal person other than you, sisil4d, or sisil4d's authorised service providers acting under instruction.
• "KYC Data" means identity verification documents and information submitted in connection with the Know Your Customer process, including but not limited to copies of government-issued identity cards (MyKad), passports, driver's licences, and proof of address documents.
• "Cookies" means small text files stored on your device by your web browser at our request, used to maintain session continuity and analyse user behaviour on the Platform.

Data We Collect

sisil4d collects Personal Data through the following means and in the following categories:

3.1 — Data You Provide Directly

• Registration data: full name, date of birth, email address, mobile number, preferred currency (MYR), and chosen username;
• KYC documents: government-issued Malaysian identity card (MyKad), passport, or driver's licence; proof of address (utility bill, bank statement); selfie photographs;
• Payment information: payment method type (e.g., Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, or cryptocurrency wallet address); transaction amounts and references. Note: sisil4d does not store full card numbers or online banking credentials;
• Support communications: the content of any live chat sessions, emails, or correspondence you submit to our support team.

3.2 — Data Collected Automatically

• Technical data: IP address, browser type and version, operating system, device type, screen resolution, and time zone;
• Usage data: pages visited, features used, bet and game history, session duration, click paths, and search queries within the Platform;
• Location data: approximate geographic location derived from IP address (country and city level only — we do not collect GPS-level location data);
• Cookie data: as described in Section 10 of this Policy.

3.3 — Data from Third Parties

• Identity verification services: results from third-party KYC verification providers, including document authenticity checks and sanction-list screening;
• Payment processors: transaction confirmation data from payment providers (not full account credentials);
• Fraud prevention services: risk scoring and device reputation data from third-party anti-fraud partners.

Purpose of Data Processing

The following table summarises the key purposes for which we process Personal Data and the corresponding data categories involved:

Legal Basis for Processing

sisil4d processes Personal Data under the following legal bases, applied as appropriate to each processing activity:

• Contractual necessity: Processing required to fulfil our obligations under the account agreement with you — including account management, payment processing, and service delivery;
• Legal obligation: Processing required to comply with applicable laws and regulatory requirements, including KYC/AML obligations under our international gaming licence and anti-money-laundering frameworks;
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud detection, platform security, responsible gambling monitoring, and service analytics — provided these interests are not overridden by your fundamental rights and freedoms;
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of promotional communications. You may withdraw consent at any time by contacting support or updating your account communication preferences.

Data Sharing & Disclosure

sisil4d does not sell, rent, or trade your Personal Data with third parties for marketing purposes. We may share your data with the following categories of recipient, strictly on a need-to-know basis and under appropriate data protection agreements:

• Payment processors: Companies facilitating transactions via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and cryptocurrency networks receive the minimum transactional data required to process your payment;
• KYC and identity verification providers: Third-party services that assist us in verifying the authenticity of identity documents and conducting age verification checks;
• Fraud prevention and security vendors: Partners that provide IP reputation, device fingerprinting, and transaction risk-scoring services;
• Technical infrastructure providers: Cloud hosting, database management, and content delivery network (CDN) providers who process data on our behalf under strict data processing agreements;
• Legal and regulatory authorities: We may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where required by applicable law, pursuant to a valid legal order, or where we believe disclosure is necessary to prevent imminent harm or criminal activity.

International Data Transfers

sisil4d operates internationally and may transfer your Personal Data to service providers located in countries outside Malaysia. Where such transfers occur, we take appropriate measures to ensure that your Personal Data receives a level of protection equivalent to that described in this Policy.

Appropriate safeguards for international transfers include:

• Standard Contractual Clauses (SCCs) approved under applicable data protection frameworks;
• Transfers to jurisdictions recognised as providing an adequate level of data protection;
• Binding corporate rules where applicable within our group structure.

If you would like more information about the specific safeguards applied to transfers affecting your Personal Data, please contact us at the details provided in Section 14.

Data Retention

sisil4d retains Personal Data for no longer than is necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulatory obligation. Retention periods for the principal data categories are summarised in Section 4 above.

Upon the closure of your account, your Personal Data will be retained for a post-closure period as specified above, primarily to comply with financial record-keeping obligations, respond to any unresolved disputes or complaints, and fulfil our responsible gambling monitoring obligations. Following expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents re-identification.

Where you have exercised a right to erasure (see Section 11) and there is no overriding legal basis for continued retention, Personal Data will be deleted within 30 days of our confirmation of your request.

Security Measures

sisil4d implements and maintains a comprehensive suite of technical and organisational security measures designed to protect Personal Data from unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption in transit: All data transmitted between your browser or device and the sisil4d Platform is encrypted using TLS 1.2 or higher (256-bit SSL);
• Encryption at rest: Sensitive data stored on our servers, including KYC documents and financial records, is encrypted at rest using AES-256 encryption;
• Access controls: Personal Data is accessible only to sisil4d employees and service providers who require it for the performance of their duties, under strict role-based access control policies;
• Two-factor authentication: Available to all registered Users to provide an additional layer of account security beyond password authentication;
• Regular security audits: We conduct periodic penetration testing and vulnerability assessments to identify and remediate potential security weaknesses;
• Incident response: In the event of a Personal Data breach that is likely to result in a risk to your rights and freedoms, sisil4d will notify affected Users without undue delay, in accordance with applicable notification obligations.

Cookies & Tracking Technologies

sisil4d uses cookies and similar tracking technologies to operate the Platform effectively, maintain the security of your session, remember your preferences, and analyse how the Platform is used. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the Platform. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery (CSRF). These cannot be disabled without significantly impairing Platform functionality.
• Functional Cookies: Used to remember your preferences, including your preferred language, currency display, and interface settings. These improve your experience but are not essential to core functionality.
• Performance & Analytics Cookies: Collect aggregated and anonymised data about how Users interact with the Platform — including which pages are visited most frequently and where Users encounter errors. This data is used exclusively to improve the Platform.

sisil4d does not use third-party behavioural advertising cookies or retargeting pixels. We do not participate in any cross-site tracking networks.

You may manage your cookie preferences through your browser settings. Disabling all cookies may prevent certain features of the Platform from functioning correctly. Strictly necessary cookies cannot be opted out of while using the Platform.

Your Data Rights

Subject to applicable law and certain exceptions, you hold the following rights in respect of your Personal Data held by sisil4d. To exercise any of these rights, please contact us via the details in Section 14. We will respond to all valid requests within 30 days.

Minors

The sisil4d Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect Personal Data from persons under 21. All account registrations are subject to mandatory KYC age verification before any gambling activity or withdrawal is permitted.

If sisil4d becomes aware, through any means, that a registered User is under the age of 21, the account will be immediately suspended, all gambling activity will be voided, and any deposited funds will be returned to the original payment source. We are committed to preventing underage gambling in Malaysia and any jurisdiction where we operate.

If you have reason to believe that a person under the age of 21 has registered an account with sisil4d, please contact us immediately at the details provided in Section 14.

Changes to This Privacy Policy

sisil4d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When material changes are made, we will notify you by posting the updated Policy on this page and updating the "Last updated" date at the top of the document.

Where we consider a change to be material — meaning it significantly affects how we handle your Personal Data or the rights you hold — we will also provide direct notice via your registered email address or an in-platform notification, where practically possible.

Your continued use of the sisil4d Platform following notification of any amendments constitutes your acknowledgement of the updated Policy. If you disagree with any changes, you should cease using the Platform and contact us to discuss your options, including account closure.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise a data right, or have a concern about how sisil4d handles your Personal Data, please reach out using the contact details below. We take all privacy enquiries seriously and will acknowledge your contact within 48 hours.

Please include your full name, registered email address, and a description of your request when contacting us about a data matter. This allows us to locate your records and respond accurately.