atom108 Privacy Policy

Introduction

This Privacy Policy ("Policy") sets out the basis on which atom108 ("we", "us", "our", "the Platform") collects, processes, stores, and protects personal data provided by or collected about you ("User", "Member", "you") when you access or use the atom108 website located at atom108.cam and its associated services.

atom108 is committed to handling all personal data with the utmost care, in full compliance with applicable data protection principles. This Policy applies to all Users, including those who have registered accounts and those who browse the Platform without registration.

This Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the atom108 Platform, and our Responsible Gambling policy.

Definitions

In this Privacy Policy, the following terms carry the meanings defined below:

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, directly or indirectly. This includes name, email address, phone number, Malaysian IC number, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means atom108, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of atom108 under a data processing agreement.
• "KYC" means Know Your Customer — the identity and age verification process conducted upon account registration and prior to withdrawal.
• "Cookies" means small text files placed on your device by the Platform to store session, preference, and analytics data.
• "Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, financial information beyond that necessary for payment processing, or biometric data used for identification purposes.

Data We Collect

atom108 collects Personal Data through several channels: directly from you when you register or interact with the Platform, automatically through your use of the Platform, and from third-party service providers engaged in payment processing and identity verification.

3.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, Malaysian IC number (MyKad) or passport number, email address, phone number, and residential address (including city — for example, Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, or Shah Alam).
• KYC Documents: Scanned or photographed copies of government-issued identity documents, proof of address (such as a Tenaga Nasional or Syabas utility bill), and selfie verification images.
• Financial Data: Bank account details, e-wallet identifiers (such as Touch 'n Go eWallet, Boost, GrabPay), and transaction history as needed to process deposits and withdrawals via DuitNow, FPX, Maybank, CIMB, Public Bank, or Hong Leong.
• Support Communications: Records of any correspondence you send to atom108, including live chat transcripts and email communications directed to [email protected].

3.2 Data Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device model, screen resolution, and time zone.
• Usage Data: Pages visited, games played, bet history, session duration, click interactions, and navigation paths within the Platform.
• Cookies and Tracking Data: Session cookies, preference cookies, and analytics identifiers as described in Section 9 of this Policy.

3.3 Data Received from Third Parties

• Identity verification results from our KYC service providers.
• Payment confirmation and fraud screening signals from payment processors and financial institutions.
• Geolocation data sufficient to confirm that you are accessing the Platform from a permitted jurisdiction.

Purposes of Processing

atom108 processes your Personal Data for the following purposes:

Legal Basis for Processing

atom108 processes your Personal Data on one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and atom108 — including account setup, game access, and payment processing — in accordance with our Terms & Conditions.
• Legal Obligation: Processing is required to comply with applicable anti-money-laundering regulations, KYC obligations, and other statutory requirements that atom108 is subject to as an online gaming operator.
• Legitimate Interests: Processing is necessary for atom108's legitimate interests in fraud prevention, platform security, responsible gambling monitoring, and service improvement, provided such interests are not overridden by your rights and interests.
• Consent: Where atom108 relies on your consent as the legal basis for processing — for example, sending optional promotional communications — you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Disclosure

atom108 does not sell, rent, or trade your Personal Data to any third party. We share your data only in the circumstances described below, and only to the extent strictly necessary for the stated purpose:

• Payment Processors: We share financial data with payment service providers — including DuitNow, FPX, and approved bank partners such as Maybank, CIMB, Public Bank, and Hong Leong — to process your deposits and withdrawals. These providers are bound by their own data protection obligations.
• KYC and Identity Verification Providers: We share identity documents with third-party KYC service providers for the purpose of verifying your identity and age. These providers act as Data Processors under contract with atom108.
• Fraud Prevention and Security Services: We may share technical data and transaction metadata with fraud detection partners to protect the Platform and its users from financial crime and account abuse.
• Legal and Regulatory Authorities: We will disclose Personal Data to competent authorities, regulators, or law enforcement agencies where required by applicable law, court order, or regulatory direction. atom108 will only provide the minimum data necessary to satisfy such requests.
• Professional Advisors: We may share Personal Data with our legal counsel, auditors, or compliance advisors where strictly necessary in the context of professional advice, subject to enforceable confidentiality obligations.

Data Retention

atom108 retains your Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with atom108, and for a period of five (5) years following account closure, to satisfy our regulatory record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years from the date of the last transaction on your account, in accordance with applicable anti-money-laundering requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Support Communications: Retained for two (2) years from the date of last contact, unless the communication relates to an unresolved dispute in which case retention is extended until resolution.
• Analytics and Usage Data: Retained in aggregated or anonymised form indefinitely; identifiable usage logs retained for up to twelve (12) months.
• Marketing Consent Records: Retained until you withdraw consent, plus one (1) year thereafter as evidence of the consent having existed.

Upon the expiry of applicable retention periods, Personal Data is securely deleted or anonymised so that it can no longer be associated with you as an identifiable individual.

Security Measures

atom108 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:

• Transport Layer Security: All data in transit between your browser or device and atom108's servers is encrypted using TLS 1.3 protocol as a minimum standard.
• Data Encryption at Rest: Sensitive Personal Data — including KYC documents and financial records — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. All staff with access to personal data undergo security training and are bound by confidentiality obligations.
• Two-Factor Authentication: Member account access is protected by two-factor authentication (2FA), and administrative access to data systems requires multi-factor authentication.
• Regular Security Audits: atom108 conducts periodic security assessments and vulnerability testing to identify and remediate potential weaknesses in the Platform's infrastructure.
• Incident Response: atom108 maintains a documented data breach response procedure. In the event of a breach that poses a risk to your rights, we will notify affected users and take immediate containment action.

While atom108 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for maintaining the confidentiality of your account password and for logging out after each session, particularly when using shared or public devices.

Cookies & Tracking Technologies

atom108 uses cookies and similar tracking technologies to operate core Platform functions, improve user experience, and analyse site performance. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in during your visit. These cookies cannot be disabled without breaking core functionality.
• Functional Cookies: Store your preferences such as language settings, preferred payment method display, and responsible gambling tool configurations. These persist across sessions to improve your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how users navigate the Platform — which pages are visited most, where users exit, and general performance metrics. This data is used solely to improve atom108's service quality.
• Security Cookies: Used for fraud detection, bot identification, and account security purposes. These help atom108 distinguish legitimate user sessions from automated or malicious access attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling functional or analytics cookies may affect the quality of your Platform experience but will not prevent you from accessing core services.

Your Data Rights

Subject to applicable law and certain conditions, you have the following rights in relation to your Personal Data held by atom108. To exercise any of these rights, please contact our support team via live chat or at [email protected]. We will respond within thirty (30) calendar days of receiving a valid request.

Protection of Minors

atom108 is strictly an adult platform. Access to and use of the Platform is permitted only to individuals aged 21 years and above. atom108 does not knowingly collect, process, or retain Personal Data relating to individuals under the age of 21.

All account registrations are subject to age verification as part of our KYC process. Where atom108 has reasonable grounds to believe that an account has been registered by or is being used by a person under 21 years of age, the account will be suspended immediately, all deposits will be returned, and any associated winnings will be forfeited.

If you believe that atom108 has inadvertently collected data relating to a minor, please contact us immediately at [email protected] so that we can investigate and take appropriate action without delay.

International Data Transfers

atom108 primarily processes and stores Personal Data within infrastructure serving the Asian region. However, in the course of operating the Platform — particularly in connection with KYC verification, fraud screening, and payment processing — your Personal Data may be transferred to and processed by service providers operating in other jurisdictions.

Where such international transfers occur, atom108 takes appropriate steps to ensure that your Personal Data is afforded a level of protection equivalent to the standards applied within our primary operating environment. These steps include:

• Entering into data processing agreements with all third-party processors that include binding data protection obligations;
• Assessing the data protection laws and practices of destination jurisdictions prior to authorising transfers;
• Applying additional technical safeguards — such as encryption — where a transfer involves jurisdictions with materially lower data protection standards.

Amendments to This Policy

atom108 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. The date of the most recent revision is always displayed at the top of this page.

Where amendments are material — for example, changes to the categories of Personal Data we collect, new purposes for processing, or changes to your rights — atom108 will provide advance notice via a prominent notice on the Platform or by email to your registered address.

Your continued use of atom108 following the publication of any amended Privacy Policy constitutes your acceptance of those changes. If you do not agree to a material amendment, you must discontinue use of the Platform and may request account closure.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data by atom108, please contact our support team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week via the on-site chat widget on atom108.cam

Our team is available to assist players across Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and throughout Malaysia. Data access requests and erasure requests will be acknowledged within five (5) business days and fulfilled within thirty (30) calendar days.

For information about your account rights and platform rules, please also review our Terms & Conditions and Responsible Gambling page.