Konohatoto Privacy Policy

Introduction

This Privacy Policy ("Policy") issued by Konohatoto ("we", "us", "our", "Platform") and describes how we collect, use, store, disclose, and protect personal data in connection with the operation of the Konohatoto platform at https://konohatoto.cam and all associated services.

Konohatoto is committed to handling your personal data responsibly and in accordance with applicable data protection and privacy laws. This Policy is intended to give you clear and transparent information about our data practices so that you can make informed decisions about your use of the Platform.

By registering an account on the Konohatoto Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you should not use the Platform.

Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, identification number, IP address, and transaction records.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transfer, and deletion.
• "Data Controller" means Konohatoto, as the entity that determines the purposes and means of processing personal data.
• "Data Processor" means a third party that processes personal data on behalf of Konohatoto under a data processing agreement.
• "Data Subject" means the individual whose personal data is being processed — in most cases, you as the registered player or website visitor.
• "KYC" means Know Your Customer — the identity verification process required prior to processing withdrawals.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data for a specific purpose.
• "Cookies" means small text files placed on your device by the Platform for session management, analytics, and personalisation purposes.

Data We Collect

Konohatoto collects personal data in the following categories:

3.1 Registration Data

When you create a Konohatoto account, we collect your full legal name, date of birth, residential address, email address, and contact number. This information is required to establish and maintain your account.

3.2 Identity Verification (KYC) Data

To comply with applicable anti-money laundering and counter-terrorism financing obligations, we collect copies of government-issued identification documents (such as your MyKad or passport), proof of address, and where applicable, source of funds documentation.

3.3 Transaction Data

We maintain records of all deposits, withdrawals, and wagers made through your account. This includes payment method details (such as bank account identifiers, FPX reference numbers, Touch 'n Go eWallet transaction IDs, DuitNow transaction references, and cryptocurrency wallet addresses) and transaction amounts in MYR.

3.4 Technical & Device Data

When you access the Platform, we automatically collect certain technical information including your IP address, browser type and version, operating system, device identifiers, screen resolution, and referring URL. This data is used for security monitoring, fraud prevention, and platform optimisation.

3.5 Communication Data

We retain records of your communications with our customer support team, including live chat transcripts and any emails sent to our support address. These records are maintained for quality assurance, dispute resolution, and compliance purposes.

3.6 Behavioural & Usage Data

We collect data on how you interact with the Platform, including pages visited, games played, session duration, betting patterns, and promotional offers viewed or claimed. This data supports responsible gambling monitoring, fraud detection, and personalisation of your experience.

3.7 Data Collected from Third Parties

We may receive personal data about you from third parties including identity verification service providers, payment processors, fraud prevention agencies, and publicly available sources, where this is necessary to verify your identity or comply with regulatory obligations.

Legal Basis for Processing

Konohatoto processes your personal data one or more of the following legal bases:

How We Use Your Data

Konohatoto uses the personal data we collect for the following purposes:

• Account operation: To create, maintain, and secure your player account, including processing login authentication and account recovery.
• Transaction processing: To facilitate deposits and withdrawals via DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency channels in MYR.
• Identity verification: To conduct KYC checks prior to processing withdrawals, in compliance with applicable financial crime prevention obligations.
• Fraud and security: To detect, investigate, and prevent fraudulent transactions, account compromise, money laundering, and other unlawful activity.
• Responsible gambling: To monitor betting patterns, identify indicators of potential problem gambling, and enforce deposit limits, cooling-off periods, and self-exclusion requests.
• Customer support: To respond to your enquiries, process complaints, and resolve disputes.
• Platform improvement: To analyse usage patterns and player feedback to enhance the performance, reliability, and usability of the Konohatoto Platform.
• Legal compliance: To comply with applicable laws, regulations, court orders, and requests from competent regulatory authorities.
• Marketing: To send you promotional communications about Konohatoto offers, bonuses, and new features, where you have given your consent to receive such communications.

Data Sharing & Disclosure

Konohatoto does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We may share your personal data in the following limited circumstances:

6.1 Payment Service Providers

We share transaction data with payment processors and financial institutions to facilitate your deposits and withdrawals. These include FPX-connected banks (Maybank, CIMB, Public Bank, Hong Leong), Touch 'n Go eWallet, Boost, GrabPay, DuitNow operators, and cryptocurrency processing services. These processors act as Data Processors under contractual obligations to protect your data.

6.2 Identity Verification Providers

We engage third-party identity verification and KYC service providers to assist in verifying the identity documents and personal information you submit. These providers process data strictly in accordance with our instructions and applicable law.

6.3 Fraud Prevention & Security

We may share data with fraud prevention agencies, cybersecurity service providers, and shared industry databases where necessary to detect and prevent financial crime, account fraud, and other unlawful activity. Such sharing is conducted under appropriate data sharing agreements.

6.4 Legal and Regulatory Disclosure

We may disclose personal data to regulatory authorities, law enforcement agencies, courts, or other competent bodies where required by applicable law, a court order, or a legitimate regulatory request. We will notify you of any such disclosure where legally permitted to do so.

6.5 Corporate Transactions

In the event of a merger, acquisition, business restructuring, or sale of all or part of Konohatoto's business, your personal data may be transferred to the relevant successor entity. You will be notified of any material change in data controllership.

International Data Transfers

Some of the third-party service providers engaged by Konohatoto operate outside of Malaysia. Where personal data is transferred to a jurisdiction that does not provide the same level of data protection as Malaysia, Konohatoto will take appropriate steps to ensure that adequate safeguards are in place, such as standard contractual clauses or other approved transfer mechanisms.

By using the Konohatoto Platform, you acknowledge that your personal data may be transferred to and processed in countries outside Malaysia in connection with the operation of our services.

Data Retention

Konohatoto retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention principles apply:

• Active account data: Retained for the duration of your account relationship with Konohatoto.
• KYC and identity documents: Retained for a minimum of five (5) years following account closure, in accordance with anti-money laundering recordkeeping requirements.
• Transaction records: Retained for a minimum of five (5) years following the date of each transaction.
• Support communications: Retained for three (3) years following the resolution of the relevant matter.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year for compliance audit purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

Data Security

Konohatoto implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS 1.2 or higher) for all data transmitted between your device and our servers
• AES-256 encryption for personal data stored in our systems
• Role-based access controls limiting personal data access to authorised personnel with a documented operational need
• Multi-factor authentication for all internal administrative system access
• Continuous security monitoring, intrusion detection systems, and regular penetration testing
• Formal data breach response procedures with defined notification timelines

While we employ robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorised account access.

Cookies & Tracking Technologies

Konohatoto uses cookies and similar tracking technologies to operate the Platform, maintain your session, prevent fraud, and improve user experience. The following types of cookies may be placed on your device:

You may configure your browser to decline non-essential cookies. Please note that disabling certain cookies may affect the functionality of the Konohatoto Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the service.

Minors & Age Policy

The Konohatoto Platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been submitted by a person under the age of 21, we will immediately suspend the relevant account and delete the associated personal data without processing any transactions.

Parents and guardians who believe that a minor has registered an account on the Konohatoto Platform should contact our support team immediately. We will take appropriate action upon verification.

We encourage parents and guardians to utilise parental control software and internet filtering tools to prevent minors from accessing online gambling platforms. For guidance on available tools, please visit our Responsible Gambling page.

Your Rights

Subject to applicable law, you have the following rights in relation to the personal data we hold about you:

• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is being used.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you. You may update basic account information directly through your account settings.
• Right to Erasure: You may request deletion of your personal data in certain circumstances. Note that we are required by law to retain certain categories of data (such as KYC documents and transaction records) for minimum statutory periods regardless of any erasure request.
• Right to Restrict Processing: You may request that we restrict processing of your personal data where you contest its accuracy, object to its processing, or require it for legal claims.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format, or that we transmit it directly to another controller where technically feasible.
• Right to Object: You may object to processing of your personal data where we rely on legitimate interests as the legal basis, including profiling for marketing purposes. You also have an unconditional right to object to processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of your rights, please contact our Data Protection team at [email protected]. We will acknowledge your request within five (5) business days and respond fully within thirty (30) days. We may require identity verification before processing your request.

Marketing Communications

With your consent, Konohatoto may send you promotional communications about bonuses, new games, special offers, and platform updates. These communications may be delivered by email or via in-platform notifications.

You may withdraw your consent to receive marketing communications at any time by updating your communication preferences in your account settings or by contacting our support team at [email protected]. Withdrawal of marketing consent does not affect the delivery of transactional communications related to your account (such as deposit confirmations, withdrawal notifications, and security alerts), which are sent as part of our contract with you.

Konohatoto does not share your contact information with third parties for their own marketing purposes.

Policy Amendments

Konohatoto may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the services we provide. When material changes are made, we will notify you by posting a prominent notice on the Platform or, where appropriate, by sending a notification to your registered email address.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically. Your continued use of the Konohatoto Platform following any update constitutes your acknowledgement of the revised Policy.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Konohatoto handles your personal data, please contact our Data Protection team using the details below:

For matters relating to responsible gambling tools or self-exclusion, please visit our Responsible Gambling page. For questions about account terms, bonuses, and platform rules, please review our Terms & Conditions.