Privacy Policy

This Privacy Policy ("Policy") is published by Sontogel ("Company", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at sontogel.cam ("Platform"). This Policy applies to all visitors, registered players, and any other individuals who interact with the Platform or communicate with the Company.

Sontogel is committed to protecting the privacy and personal data of all individuals whose information we process. This Policy explains what personal data we collect, the purposes for which it is used, the conditions under which it may be shared, how it is protected, and the rights available to you as a data subject.

This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform and form part of your legal agreement with Sontogel. In the event of any conflict between this Policy and the Terms & Conditions regarding data matters, this Policy shall prevail.

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly — including name, identification number, contact details, and online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, or deletion.
• "Data Controller" means Sontogel, as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party engaged by Sontogel to process Personal Data on its behalf — for example, payment gateway providers.
• "Data Subject" means you — the individual whose Personal Data is being processed.
• "KYC" means Know Your Customer — the identity and age verification process used to confirm a player's identity and eligibility.
• "Cookies" means small text files placed on your device by the Platform to store session information and usage preferences.

Sontogel collects the following categories of personal data depending on your interaction with the Platform:

We collect personal data through the following channels:

• Directly from you: When you register an Account, complete the KYC process, make a deposit or withdrawal, contact our support team, or respond to a survey or promotion;
• Automatically through the Platform: Technical and usage data is collected automatically via server logs, cookies, and similar technologies when you access the Platform;
• From payment providers: Transaction confirmation data is received from verified Malaysian payment partners including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect in the course of processing deposits and withdrawals;
• From identity verification services: During the KYC process, verification data may be cross-referenced with authorised third-party identity verification providers to confirm document authenticity;
• From fraud prevention systems: Risk and fraud management tools may generate or receive data about transaction patterns and device fingerprints to protect the integrity of the Platform.

Sontogel processes your personal data for the following specific purposes:

1. Account administration: Creating and maintaining your player Account, verifying your identity and age, managing your Account settings and preferences;
2. Payment processing: Executing deposits and withdrawals through your chosen Malaysian payment method, maintaining transaction records, reconciling payments, and investigating disputes;
3. Regulatory compliance: Fulfilling obligations under applicable anti-money laundering (AML) laws, KYC requirements, and any directions issued by relevant Malaysian regulatory authorities including Bank Negara Malaysia;
4. Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, cheating, multi-accounting, money laundering, and other prohibited conduct as defined in our Terms & Conditions;
5. Customer support: Responding to your enquiries, resolving complaints, processing responsible gambling requests such as self-exclusion and deposit limits;
6. Platform improvement: Analysing aggregated and anonymised usage data to improve Platform performance, identify technical issues, and optimise the player experience;
7. Responsible gambling: Monitoring account activity to identify patterns consistent with problem gambling behaviour, in support of our responsible gaming obligations;
8. Direct communications: Sending account-related notifications, security alerts, and promotional communications where you have provided consent or where it is necessary for contractual performance.

Sontogel relies on the following legal bases for processing your personal data, as applicable to each processing activity:

• Contractual necessity: Processing required to perform our contract with you, including operating your Account, processing payments, and providing gaming services;
• Legal obligation: Processing required to comply with applicable laws, including AML regulations, KYC requirements, and responses to lawful requests from Malaysian regulatory authorities;
• Legitimate interests: Processing necessary for Sontogel's legitimate business interests — including fraud prevention, platform security, and responsible gambling monitoring — where those interests are not overridden by your privacy rights;
• Consent: Processing based on your freely given, specific, and informed consent — primarily for optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Sontogel does not sell, rent, or trade your personal data. We may share your data with third parties only in the following strictly defined circumstances:

• Payment service providers: Transaction data is shared with verified Malaysian payment partners (DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank, Hong Leong Connect) solely to process your deposits and withdrawals. These providers are bound by their own data protection obligations;
• Identity verification providers: KYC document data may be shared with authorised third-party identity verification services engaged to verify document authenticity and confirm player eligibility;
• Fraud and AML monitoring services: Transaction and account data may be processed by third-party fraud detection and anti-money laundering screening systems. These processors act under strict data processing agreements with Sontogel;
• Regulatory and law enforcement authorities: We may disclose personal data to competent Malaysian authorities — including Bank Negara Malaysia, the Royal Malaysia Police (PDRM), or the Malaysian Anti-Corruption Commission (MACC) — where required by law, court order, or other lawful regulatory demand;
• Corporate transactions: In the event of a merger, acquisition, or sale of substantially all assets, your personal data may be transferred to the successor entity subject to equivalent privacy protections.

Sontogel retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual. Where anonymisation is not technically feasible, data is placed in secure archive with access strictly restricted pending scheduled deletion.

Sontogel implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our security framework includes:

• Encryption in transit: All data transmitted between your browser and our servers is protected by 256-bit SSL/TLS encryption, consistent with the security standards of Malaysia's major financial institutions;
• Encryption at rest: Sensitive personal data and financial records stored on our infrastructure are encrypted using industry-standard encryption protocols;
• Access controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged and subject to regular audit;
• Infrastructure security: Our servers are hosted in secure data centres with physical access controls, 24/7 monitoring, and redundant systems;
• Regular security assessments: Our systems undergo periodic independent security assessments to identify and remediate vulnerabilities.

You are also responsible for keeping your Account credentials — including your password and any two-factor authentication codes — strictly confidential. Sontogel will never ask for your full password in any communication.

The Sontogel Platform uses cookies and similar technologies to provide a functional and consistent user experience. We use the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function — including session management, authentication state, and security tokens. These cannot be disabled without breaking Platform functionality;
• Functional cookies: Remember your preferences such as language settings and display options to personalise your experience;
• Analytics cookies: Collect anonymised data about how players use the Platform — such as page views and game loading times — to help us improve performance. No personally identifiable information is stored in analytics cookies;
• Security cookies: Used to detect and prevent fraudulent activity, including session hijacking attempts and bot traffic.

Sontogel does not use third-party advertising cookies, cross-site tracking pixels, or retargeting technologies. You can manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies will affect your ability to log in and use core Platform features.

As a data subject, you have the following rights in relation to your personal data held by Sontogel. To exercise any of these rights, contact our support team using the details in Section 14.

The Sontogel Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the registration and KYC process, and any Account found to belong to a minor will be immediately closed.

If you have reason to believe that a minor has registered an Account or provided personal data to Sontogel, please contact our support team immediately. Upon confirmation, we will delete all personal data associated with that Account and return any deposits made.

Sontogel may update this Privacy Policy from time to time to reflect changes in applicable law, our data processing practices, or the services we offer. The effective date at the top of this page will always reflect the date of the most recent revision.

For material changes — such as new categories of data collected, new purposes of processing, or significant changes to your rights — we will notify registered players via a prominent notice on the Platform or by direct communication to the email address associated with your Account, at least 14 days before the changes take effect.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you must close your Account and discontinue use of the Platform.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the Sontogel Data Protection team through any of the following channels:

• Email (plain text — not clickable): [email protected] — please use the subject line "Privacy Request" for data rights enquiries
• Live Chat: Available 24/7 through the Platform interface — average first response under 90 seconds
• Business correspondence: Kuala Lumpur, Malaysia

We take all privacy enquiries seriously and aim to respond to all requests within 5 business days, with formal data rights requests resolved within 30 calendar days. If you are dissatisfied with our response, you have the right to escalate your complaint to the relevant Malaysian data protection authority.