Privacy Policy

This Privacy Policy (hereinafter referred to as the "Policy") sets out the manner in which TogelUp (hereinafter referred to as "TogelUp", "we", "our", or "the Platform") collects, processes, stores, shares, and protects personal data belonging to individuals (hereinafter referred to as "you", "the Member", "the User", or "the Data Subject") who access and use the TogelUp website located at https://togelup.cam and all associated services.

TogelUp is committed to processing personal data in a lawful, fair, and transparent manner, consistent with internationally recognised data protection principles including but not limited to those set out under the General Data Protection Regulation (GDPR) framework and applicable international privacy standards. While TogelUp primarily serves players in Malaysia, including those based in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam, this Policy applies to all members globally regardless of geographic location.

By registering an account with TogelUp or by continuing to use the Platform, you acknowledge that you have read, understood, and consent to the collection and processing of your personal data as described in this Policy. Where consent is relied upon as the legal basis for processing, you retain the right to withdraw that consent at any time without prejudice to the lawfulness of processing that occurred prior to withdrawal.

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

For the purposes of applicable data protection law, the Data Controller responsible for your personal data is TogelUp, the operator of the Platform at https://togelup.cam. TogelUp operates under an internationally recognised gaming licence and maintains appropriate data processing agreements with all third-party service providers that handle member data on its behalf.

If you have any questions regarding how your personal data is processed, or if you wish to exercise any of your data subject rights as described in Section 11 of this Policy, you may contact our Data Protection team using the contact details provided in Section 16.

TogelUp collects personal data in the following categories depending on the nature of your interaction with the Platform:

4.1 Registration Data

When you create a TogelUp account, we collect your full legal name, date of birth, email address, phone number, country and city of residence, preferred language, and a password of your choosing. This information is necessary to establish and maintain your account.

4.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) compliance obligations, we collect copies of government-issued identity documents (Malaysian MyKad, Passport, or Driver's Licence), proof of address documentation (utility bills, bank statements), and selfie photographs taken in real time. This data is processed by our compliance team and authorised KYC service providers only.

4.3 Financial Transaction Data

We record details of all deposits and withdrawal transactions including payment method type (e.g., Maybank2u, CIMB Clicks, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX), transaction reference numbers, amounts in Malaysian Ringgit (MYR), timestamps, and associated account identifiers. We do not store full bank account numbers or card numbers on our servers.

4.4 Gameplay and Betting Data

We maintain records of your wagering activity, including bet placement history, game session data, win and loss outcomes, bonus utilisation, and VIP tier progression. This data is used for account management, dispute resolution, regulatory reporting, and responsible gambling monitoring.

4.5 Technical and Device Data

Our servers automatically collect technical data including your IP address, browser type and version, device operating system, screen resolution, session timestamps, referring URLs, and pages visited. This data is processed for security, fraud prevention, and platform performance optimisation purposes.

4.6 Communications Data

If you contact our customer support team via live chat, email, or any other channel, we retain records of those communications including the content of messages, the date and time of contact, and your support ticket history. These records are maintained for quality assurance, dispute resolution, and training purposes.

4.7 Responsible Gambling Data

Where you voluntarily set deposit limits, loss limits, session reminders, or request self-exclusion, we process and store this information as part of our responsible gambling programme. In certain circumstances, where indicators of problem gambling are identified, we may process additional information in the interest of Member welfare, which may constitute Special Category Data under applicable privacy law.

TogelUp processes your personal data on the following legal bases, as applicable to each category of processing activity:

Where we rely on Legitimate Interests as a legal basis, we conduct a balancing test to ensure our interests do not override your fundamental rights and freedoms. You may request information about such assessments by contacting our Data Protection team.

TogelUp uses your personal data for the following purposes:

• Account Administration: To establish, maintain, and manage your member account, including processing login sessions and account settings changes.
• Payment Processing: To facilitate deposits and withdrawals via Malaysian payment methods including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect.
• Identity Verification: To comply with KYC and AML regulatory obligations and to prevent identity fraud, account takeover, and underage gambling.
• Gameplay Delivery: To provide access to sports betting markets (including Liga Super Malaysia, EPL, and UFC), live casino games, slots, and all other Platform services.
• Customer Support: To respond to enquiries, resolve disputes, process complaints, and provide technical assistance across English, Bahasa Melayu, and Mandarin support channels.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, unauthorised access, collusion, and money laundering activity.
• Responsible Gambling: To monitor for indicators of problem gambling, enforce self-imposed limits, and intervene where necessary to protect Member welfare.
• Marketing Communications: To send promotional offers, VIP tier updates, and platform news where you have provided consent or where we have a legitimate interest basis. You may opt out of marketing communications at any time.
• Platform Improvement: To analyse aggregated, anonymised usage data to enhance platform performance, user experience, and game offering.
• Legal Compliance: To meet obligations under applicable law, respond to court orders, subpoenas, or regulatory investigations.

TogelUp does not sell, rent, trade, or otherwise transfer your personal data to unaffiliated third parties for commercial or marketing purposes. We may share your personal data only in the following limited and controlled circumstances:

• Licensed Payment Processors: Your financial transaction data is shared with the payment providers facilitating your deposit or withdrawal (e.g., FPX network operators, e-wallet platforms such as Touch 'n Go, Boost, GrabPay). These providers are bound by their own data protection obligations and process your data only as necessary to complete the transaction.
• KYC and Identity Verification Providers: Identity documents submitted during account verification are shared with authorised third-party KYC service providers operating under binding data processing agreements. These providers are prohibited from using your data for any purpose other than identity verification on TogelUp's behalf.
• Game Technology Providers: Limited gameplay session data (such as bet placement and game outcome records) may be shared with third-party game studios for the purpose of delivering and auditing game integrity. No personally identifiable registration data is shared for this purpose.
• Regulatory and Law Enforcement Authorities: We may disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by law, court order, or official legal process. We will, where legally permissible, notify affected members of such disclosure.
• Professional Advisers: TogelUp may share limited personal data with legal counsel, auditors, or other professional advisers under strict confidentiality obligations where necessary for the conduct of our business operations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a material part of TogelUp's business, personal data may be transferred to the acquiring entity subject to equivalent privacy protections and member notification.

TogelUp uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are deployed:

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary or responsible gambling cookies may impair Platform functionality or disable safety features. TogelUp does not use third-party advertising or retargeting cookies.

TogelUp retains personal data for no longer than is necessary for the purposes for which it was collected, taking into account applicable legal, regulatory, and operational requirements. The following retention schedules apply:

• Account Registration Data: Retained for the duration of your active membership plus a minimum of 5 years following account closure, to meet anti-money laundering and regulatory record-keeping obligations.
• KYC Documentation: Retained for a minimum of 5 years from the date of verification or account closure, whichever is later, in accordance with applicable AML record-keeping standards.
• Financial Transaction Records: Retained for a minimum of 7 years to satisfy financial reporting, tax, and audit obligations.
• Gameplay and Betting History: Retained for a minimum of 3 years for dispute resolution and responsible gambling monitoring purposes.
• Customer Support Communications: Retained for 2 years from the date of last interaction for quality assurance and dispute resolution purposes.
• Technical and Session Logs: Retained for up to 12 months for security monitoring and fraud investigation purposes.
• Marketing Consent Records: Retained for the duration of your membership or until consent is withdrawn, whichever occurs first.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification, unless ongoing retention is required by applicable law or a legitimate dispute resolution need.

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

• Transport Layer Security: All data in transit between your device and TogelUp's servers is encrypted using TLS 1.2 or higher (256-bit encryption), the same standard used by major Malaysian financial institutions.
• Data Storage Encryption: Personal data, KYC documents, and financial records stored on TogelUp's infrastructure are encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is strictly limited to authorised personnel with a documented operational need. All internal data access is logged and subject to periodic audit.
• Penetration Testing: TogelUp's platform undergoes regular third-party security assessments and penetration testing to identify and remediate potential vulnerabilities before they can be exploited.
• Incident Response: TogelUp maintains a documented data breach response plan. In the event of a breach that poses material risk to your rights and freedoms, affected members will be notified promptly in accordance with applicable notification obligations.
• Staff Training: All TogelUp employees with access to personal data undergo data protection training and are bound by confidentiality obligations.

Subject to applicable law and certain limited exceptions, you hold the following rights in relation to your personal data held by TogelUp. You may exercise any of these rights by submitting a written request to our Data Protection team at the contact details in Section 16. We will respond within 30 days of receipt of a valid request.

Please note that certain rights are subject to limitations. For instance, we may be unable to fulfil an erasure request where data must be retained to comply with a legal obligation (such as AML record-keeping requirements) or to defend a legal claim. We will always explain clearly if we are unable to comply with a request and the reason for that limitation.

TogelUp operates exclusively for adults aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. Our KYC verification process is designed to detect and prevent registration by underage individuals.

If you are a parent or guardian and believe that a minor under your care has registered an account with TogelUp, please contact us immediately at the address provided in Section 16. Upon confirmation, we will close the account, delete all associated personal data to the extent permitted by law, and return any funds held in the account to the registered payment method.

As TogelUp operates an internationally licensed platform, your personal data may be transferred to, and processed in, countries outside of Malaysia and your country of residence. These transfers may occur in the context of cloud hosting infrastructure, KYC service providers, payment processors, or game technology providers operating in other jurisdictions.

Where such transfers take place, TogelUp ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to or exceeding that required in your home jurisdiction. Such safeguards may include binding contractual clauses with data processors, adherence to recognised international data transfer frameworks, or processing in jurisdictions subject to an adequacy determination by a recognised regulatory authority.

You may request details of the specific safeguards in place for any international transfer of your personal data by contacting our Data Protection team.

The TogelUp Platform does not include links to third-party websites for commercial or advertising purposes. However, certain operational integrations — such as payment processing gateways and game delivery platforms — may direct you to third-party interfaces as part of a transaction or game session.

Once you leave the TogelUp Platform and access a third-party service, that third party's own privacy policy and data protection practices apply. TogelUp is not responsible for the privacy practices or content of any third-party service, even where access to that service occurs as part of your use of the TogelUp Platform. We encourage you to review the privacy policies of any third-party services you interact with.

TogelUp reserves the right to amend or update this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, data processing practices, or Platform functionality. The "Last updated" date at the top of this Policy indicates the date of the most recent revision.

Where changes are material — meaning they significantly affect your rights or the way we process your personal data — TogelUp will notify members via email and/or a prominent in-platform notification prior to the changes taking effect. For minor or clarificatory updates, we may update the Policy without specific notification, although the updated date will always be visible at the top of the document.

Your continued use of the TogelUp Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of and agreement to the revised terms, to the extent permitted by applicable law. We recommend checking this page periodically for any updates.

If you have any questions about this Privacy Policy, wish to exercise any of your data protection rights as described in Section 11, or have concerns about how TogelUp processes your personal data, please contact our Data Protection team through the following channel:

If you are not satisfied with our response to a data protection concern, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. TogelUp takes all privacy complaints seriously and will cooperate fully with any regulatory investigation.