1rokok Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") is issued by 1rokok ("1rokok," "we," "us," "our") and applies to all personal data processed in connection with your use of the 1rokok website at 1rokok.win and all associated services including online casino games, live dealer tables, sportsbook, and arcade products (collectively, the "Platform").

1rokok operates as an online gaming platform under an international gaming authority licence. As part of our licensing obligations, we are required to implement robust data protection measures and to be transparent with players about how their personal information is handled. This Policy fulfils that transparency obligation.

By registering an account on 1rokok or continuing to use the Platform, you acknowledge that you have read this Policy and understand how your data is processed. If you do not agree with this Policy, you should not register or continue to use the Platform. For questions at any time, contact us at [email protected].

2. Personal Data We Collect

1rokok collects personal data from you in the following categories, depending on how you interact with the Platform:

1rokok does not collect sensitive personal data (such as biometric data, health data, or political opinions) except where expressly required by our licensing authority for identity verification purposes, in which case you will be separately informed.

3. How We Use Your Personal Data

1rokok uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your 1rokok player account, including processing your registration, verifying your identity, and managing your account credentials.
• Service Delivery: To provide you with access to all games and betting services on the Platform, process your deposits and withdrawals, and credit bonuses and promotional rewards.
• Regulatory Compliance: To comply with our obligations under our international gaming authority licence, including anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and age verification mandates. 1rokok is required by its licence to retain certain player data and to report specified activity to licensing and regulatory bodies.
• Responsible Gaming: To monitor player activity for signs of problem gambling behaviour and to enforce responsible gaming tools including deposit limits, session limits, and self-exclusion requests.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, multi-accounting, and other prohibited conduct outlined in our Terms & Conditions.
• Customer Support: To respond to your enquiries, complaints, and technical support requests submitted via live chat or email.
• Platform Improvement: To analyse aggregate usage patterns (using anonymised or pseudonymised data where possible) to improve the Platform's performance, game selection, and user experience.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates via email or SMS, where you have opted in to receive such communications. You may opt out at any time by contacting support.

4. Legal Basis for Processing

1rokok processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 1rokok (i.e., the Terms & Conditions you agree to upon registration), including account creation, game access, and payment processing.
• Legal Obligation: Processing is required to comply with applicable legal and regulatory obligations, including AML legislation, KYC requirements, and data retention mandates under our gaming licence.
• Legitimate Interests: Processing is carried out pursuant to 1rokok's legitimate interests in fraud prevention, platform security, responsible gaming enforcement, and business analytics, provided these interests are not overridden by your fundamental rights.
• Consent: Where processing is based on your consent (e.g. optional marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

1rokok does not sell your personal data to third parties. We may share your data with the following categories of recipients in the circumstances described:

• Payment Processors: Your financial data is shared with licensed payment service providers (including operators of Touch n Go eWallet, DuitNow, Boost, GrabPay, and banking partners such as Maybank and CIMB) strictly to the extent necessary to process your deposits and withdrawals.
• KYC & Identity Verification Providers: We use accredited third-party identity verification services to assist with document verification. These providers process your identity documents solely for verification purposes and are bound by confidentiality obligations.
• Regulatory Authorities: 1rokok is required to disclose certain player data to its licensing authority, AML compliance bodies, and law enforcement agencies when required by law or court order.
• Game Providers: The game software providers whose titles are hosted on 1rokok may receive anonymised or pseudonymised session data for technical operation and RTP audit purposes. No directly identifiable personal data is shared with game providers without your knowledge.
• IT Infrastructure & Security Providers: Our hosting, cybersecurity, and fraud detection service providers may access technical data as necessary to provide their services, subject to data processing agreements.

Any third party that processes data on 1rokok's behalf is bound by contractual data protection obligations consistent with applicable law and our licensing requirements.

6. Cookies & Tracking Technologies

1rokok uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly Necessary Cookies: Required for the Platform to function, including session management, login persistence, and security tokens. These cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and game history within a session.
• Analytics Cookies: Used to collect anonymised data on how players navigate the Platform, which pages are visited most frequently, and where technical errors occur. This data informs Platform improvements.
• Fraud Detection Cookies: Assist in identifying suspicious patterns, bot activity, and multi-account behaviour as part of 1rokok's security and fraud prevention framework.

You may manage cookie preferences through your browser settings. Note that disabling non-essential cookies does not affect strictly necessary cookies and will not prevent you from accessing the Platform, though some features may be limited.

7. Data Retention

1rokok retains your personal data for as long as is necessary for the purposes set out in this Policy, subject to the following minimum retention periods mandated by our licensing obligations:

• Account & KYC Data: Retained for a minimum of five (5) years following account closure, as required by AML and gaming licence regulations.
• Transaction & Gaming Records: Retained for a minimum of five (5) years from the date of each transaction, for audit and regulatory reporting purposes.
• Support & Communication Records: Retained for a minimum of three (3) years following the resolution of the relevant matter.
• Technical Logs: Generally retained for twelve (12) months, unless required for longer for security investigation or regulatory purposes.

Upon expiry of the applicable retention period, data is securely deleted or irreversibly anonymised. Data subject to a legal hold or active regulatory inquiry will be retained until the relevant proceeding is concluded.

8. Security Measures

1rokok implements technical and organisational security measures appropriate to the risk posed by the processing of your personal data. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 1rokok Platform;
• Encryption at rest for sensitive data categories including identity documents and financial data;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Multi-factor authentication required for all administrative access to systems holding personal data;
• Regular penetration testing and third-party security audits of the Platform infrastructure;
• Incident response procedures for the detection, reporting, and remediation of personal data breaches.

Notwithstanding the above, no internet-based system can be guaranteed to be completely secure. You are responsible for maintaining the confidentiality of your 1rokok account credentials. If you suspect unauthorised access, contact the 1rokok support team immediately.

9. Your Data Rights

Subject to applicable law and the limitations imposed by our regulatory obligations, you have the following rights in respect of your personal data held by 1rokok:

• Right of Access: You may request a copy of the personal data we hold about you. 1rokok will respond within 30 days of receiving a verified request.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Certain data (such as your legal name on KYC documents) may require documentary evidence to update.
• Right to Erasure: You may request deletion of your personal data in certain circumstances. Note that this right is subject to our legal obligation to retain certain data for the minimum periods described in Section 7.
• Right to Restriction: You may request that we restrict processing of your data in circumstances where accuracy is disputed or processing is unlawful.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and carried out by automated means, you may request your data in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing. We will cease marketing communications immediately upon receiving your objection.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, contact 1rokok at [email protected] with the subject line "Data Rights Request." We will verify your identity before processing the request.

10. Children & Minors

The 1rokok Platform is strictly restricted to individuals aged 21 years and over. 1rokok does not knowingly collect personal data from persons under 21 years of age. Age verification is a mandatory component of the KYC process, and accounts found to belong to persons under 21 will be permanently closed and all associated data securely deleted (subject to any mandatory retention obligations).

If you become aware that a minor has registered on the 1rokok Platform, please notify us immediately at [email protected]. 1rokok will investigate and act promptly upon receipt of such a report.

11. International Data Transfers

1rokok's Platform infrastructure is hosted in data centres that may be located outside Malaysia. Where personal data is transferred to jurisdictions outside of your country of residence, 1rokok ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections afforded within Malaysia.

Such safeguards may include standard contractual clauses, data processing agreements incorporating internationally recognised data protection standards, or transfers to jurisdictions recognised as providing adequate data protection. Details of the specific safeguards in place for any given transfer are available upon written request to [email protected].

12. Changes to This Privacy Policy

1rokok reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our licensing obligations. Where changes are material, we will notify you by email to your registered address or by prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the 1rokok Platform following any update constitutes your acceptance of the revised Policy. We recommend reviewing this Policy periodically.

13. Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 1rokok, please contact our Data Protection team:

• Email: [email protected] (subject line: "Privacy Enquiry")
• Live Chat: Available 24/7 on the 1rokok Platform, Malaysia time (MYT)

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction, or to the dispute resolution body designated by 1rokok's gaming licensing authority.