Odd11 Privacy Policy – Personal Data Protection for Malaysia's Platform

1. Personal Information We Collect

odd11 collect several categories of personal information depending on how you interact with our platform. Below are the full details of the data we may collect:

1.1 Personal Identity Information

• Full name as per MyKad or passport
• Malaysian identity card number (MyKad number) or passport number
• Date of birth for age verification
• Gender
• Photo of identity card (for the KYC process when required)

1.2 Contact Information

• Mobile phone number (used for OTP verification and account communications)
• Email address
• Current residential address (for certain KYC verification purposes)

1.3 Financial & Transaction Information

• E-wallet account details (Touch 'n Go eWallet, GrabPay, Boost, ShopeePay) used for deposits and withdrawals
• Registered DuitNow account information
• Bank account details associated with FPX transactions (Maybank2u, CIMB Clicks)
• Deposit, withdrawal, and gameplay transaction history
• Current account balance

1.4 Technical & Usage Information

• IP address of the device used to log in
• Web browser type and operating system
• Device information (phone model, OS version)
• Login and logout records including date and time
• Records of gaming activity and play sessions
• Cookie data and related tracking technologies

1.5 Communications Information

• Records of conversations with the odd11 customer support team
• Feedback, complaints and enquiries you submit to us
• Your responses to customer satisfaction surveys

2. How We Collect Your Information

odd11 collect your personal information through several different channels:

• Account Registration: You provide your identity and contact information directly when completing the odd11 account registration form.
• KYC Process: You submit identity verification documents during the Know Your Customer (KYC) process, which is carried out prior to your first withdrawal or upon request.
• Financial Transactions: Payment information is collected automatically when you make a deposit or withdrawal via Touch 'n Go eWallet, GrabPay, DuitNow or FPX.
• Platform Usage: Technical data and gaming activity are collected automatically via server log systems and cookie technology when you use the odd11 website or app.
• Communications: When you reach out to our support team via live chat, WhatsApp, Telegram, or email, those communication records are retained for quality control and dispute resolution purposes.
• Mobile Device: The official odd11 app may collect device information, including device type, operating system version, and unique device identifier, for security and verification purposes.

3. How We Use Your Personal Information

odd11 uses the personal information we collect solely for the following legitimate and necessary purposes:

4. Sharing of Personal Information

odd11 upholds strict confidentiality principles. We not sell, rent, or disclose your personal data for third-party marketing purposes. However, there are limited circumstances in which we may need to share your information:

• Payment Service Providers: Transaction information that must be shared with payment processors such as DuitNow, FPX, Touch 'n Go, GrabPay and other e-wallet providers used to process your deposits and withdrawals.
• Gaming Software Provider: Account technical details that must be shared with third-party game providers to ensure games function correctly on the odd11 platform.
• Regulatory Body: Information that is required to be disclosed to the relevant authorities or regulatory bodies under applicable Malaysian law.
• Law Enforcement Authorities: Information required by the police, courts or other Malaysian government agencies where a valid court order or legal requirement exists.
• Technical Service Providers: Limited technical data shared with odd11's server hosting providers, cloud services and cybersecurity vendors — all bound by strict confidentiality agreements.
• Business Transfer Process: Should odd11 undergo an acquisition, merger, or asset sale, user data may be transferred as part of the business assets, and all members will be notified in advance.

All third parties that receive personal data from odd11 are required to uphold data protection standards equivalent to or higher than PDPA 2010 and are not permitted to use the data for any purpose other than what has been agreed in writing with us.

5. Data Security & Protection Measures

odd11 continually invests in enterprise-grade cybersecurity infrastructure to ensure your personal and financial data remains protected at all times. The key security measures we implement are as follows:

• SSL 256-bit Encryption: All communications between your device and odd11's servers are encrypted using Transport Layer Security (TLS) with 256-bit encryption — the same standard used by international banking and financial institutions. This ensures no third party can intercept or read your data in transit.
• Data-at-Rest Encryption: Sensitive personal data stored in odd11's databases is also encrypted at rest (at-rest encryption), not only during transmission.
• Two-Factor Authentication (2FA): odd11 offers two-factor authentication for all user accounts. We strongly encourage all members to enable this security feature for added protection against unauthorised access.
• 24/7 Security Monitoring: The odd11 cybersecurity team monitors our systems and networks around the clock to detect and respond to any threats or suspicious activity without delay.
• Internal Access Control: Access to users' personal data within odd11 is strictly limited internally to staff on a need-to-know basis, and all such access is logged and audited on a regular basis.
• Penetration Testing: odd11 conducts regular security testing, including penetration testing by independent security experts, to identify and address any vulnerabilities before they can be exploited.
• Incident Response Procedures: We have a tested and documented security incident response procedure in place. In the event of a data breach, we will notify affected users and the relevant authorities within the timeframe prescribed by law.

6. Cookie Policy

Website and application odd11 uses cookies and similar tracking technologies to enhance your experience and enable certain features to function correctly. Below are the types of cookies we use:

• Required
  Essential Cookies: Required for the odd11 platform to function properly. This includes login session cookies, CSRF security tokens and cookies that remember your language preferences. These cookies cannot be disabled without affecting the platform's core functionality.
• Performance
  Performance Cookies: Helps us understand how users interact with the odd11 platform — which pages are visited most, where users drop off during the registration flow, and so on. This data is used in aggregate form (without identifying individual users) to improve the overall platform experience.
• Function
  Functional Cookies: Enables odd11 to remember your preferences — such as saved usernames, game preferences and display settings — to provide a more personalised experience throughout your gaming session.
• Marketing
  Marketing Cookies: Used only with your consent to display relevant odd11 promotions. You may decline these cookies on your first visit to our website without affecting your gaming experience.

You may manage or delete cookies through your web browser settings at any time. Please note, however, that disabling essential cookies may affect your ability to log in or use certain features within the platform odd11.

7. Your Rights as a Data Subject

Under the Malaysian Personal Data Protection Act 2010 (PDPA 2010), you as a data subject have certain rights in relation to the personal data we hold about you. odd11 fully respects these rights and will respond to your request within a reasonable timeframe:

To exercise any of the above rights, please submit a written request to [email protected] by stating the right you wish to exercise and your account information odd11 you. We will acknowledge your request within 3 business days and resolve it within 21 business days, in accordance with the requirements of PDPA 2010.

8. International Data Transfers

In the course of its business operations, odd11 may need to store or process your personal data on servers located outside Malaysia, particularly in relation to cloud infrastructure and data backup systems. Where international data transfers occur, odd11 ensure that:

• The destination country or region has data protection laws equivalent to those of Malaysia.
• Comprehensive, legally binding data transfer agreements have been signed with all overseas data recipients.
• Appropriate technical and organisational security standards have been implemented to protect your data both during and after any transfer.
• Transfers are carried out solely for the purposes stated in this Privacy Policy and do not exceed the scope required.

You may contact us for more information about the protections in place when your data is transferred outside Malaysia.

9. Data Retention Period

odd11 retain your personal data for as long as necessary to fulfil the purposes set out in this Privacy Policy, or as required under Malaysian law. The following are our data retention guidelines:

• Active Account Data: Retained for the duration of your odd11 account's active period and for 7 years after account closure to meet audit and legal compliance requirements.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with Malaysia's anti-money laundering and tax legal requirements.
• KYC & Identity Verification Records: Retained for a minimum of 5 years after account closure or the end of the business relationship.
• Technical Log Data: Retained for 12 months for fraud detection, security auditing and technical troubleshooting purposes.
• Support Communication Records: Retained for 2 years for quality control and complaint resolution reference purposes.
• Marketing Data: Retained until you withdraw your consent or request the deletion of your marketing data.

Once the relevant retention period has expired, odd11 will securely delete or anonymise your data using methods that ensure it cannot be recovered or accessed again.

10. Protection of Children & Minors

odd11 maintains a strict zero-tolerance policy on the use of our platform by minors. Our services are available exclusively to individuals aged 18 and above. We do not knowingly collect or process any personal data from minors.

• An automated age verification system is implemented during the registration process.
• The KYC process, which includes MyKad verification, helps ensure that all members are adults.
• Should we discover that we have inadvertently collected data from an individual under 18 years of age, the account in question will be closed immediately and the data will be deleted from our systems.
• Parents or guardians who discover that their child has accessed or registered with odd11 without authorisation are urged to contact us immediately at [email protected].

11. Links to Other Websites

Platform odd11 may contain links to third-party websites — such as payment provider sites (Touch 'n Go, GrabPay and others) — to facilitate your deposit and withdrawal process. Please note that:

• This Privacy Policy applies solely to the odd11 only.
• Odd11 is not responsible for the privacy practices or content of any third-party websites you access via links on our platform.
• We encourage you to read the Privacy Policy of any third-party website you visit before providing them with any personal information.

12. Changes to This Privacy Policy

odd11 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, new legal requirements or service improvements.

• You will be notified of any significant changes via email or in-platform notification odd11 at least 14 days before the changes take effect.
• The "Updated" date at the top of this document will always reflect the date of the latest version of the Privacy Policy.
• Continued use of the platform odd11 after the effective date of the changes will be considered as your acceptance of the updated Privacy Policy.
• We encourage you to review this page periodically to stay informed of how we protect your data.

13. Contact Us About Data Privacy

If you have any questions, concerns or complaints regarding how odd11 handling your personal data, or if you wish to exercise any of the data subject rights set out in this Privacy Policy, please contact us through the following channels:

• Email: [email protected] (mark the subject as "Data Privacy Enquiry")
• Live Chat: Available 24/7 on the odd11 website — response within 2–5 minutes
• WhatsApp & Telegram: Number available on the odd11 customer support page

odd11 is committed to responding to all data privacy enquiries within 3 business days and resolving requests within 21 business days, in line with PDPA 2010. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant Malaysian Personal Data Protection Commissioner.