Privacy Policy

Vivo4D ("the Company", "we", "us", "our") operates the online gaming and sports betting platform accessible at vivo4d.click and all associated subdomains and digital services (collectively, "the Platform"). We are committed to protecting and respecting the privacy of all persons who interact with our Platform, including registered members, prospective members, and casual visitors.

This Privacy Policy ("Policy") describes the categories of personal data we collect, the purposes for which that data is processed, the conditions under which it may be shared with third parties, the measures we take to keep it secure, and the rights available to you as a data subject. This Policy should be read alongside our Terms & Conditions, which form an integral part of your agreement with Vivo4D.

By registering an account, accessing the Platform, or otherwise providing personal data to Vivo4D, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not accept the terms of this Policy, you must not use the Platform.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial data, location data, and online identifiers.
• "Processing" — Any operation performed on personal data, including collection, storage, use, disclosure, erasure, and destruction.
• "Data Controller" — Vivo4D, as the entity that determines the purposes and means of processing personal data collected via the Platform.
• "Data Processor" — A third-party entity that processes personal data on behalf of Vivo4D under a data processing agreement, solely for the purposes specified by Vivo4D.
• "Member" / "User" — Any individual who has registered an account on the Platform or who accesses the Platform in any capacity.
• "KYC" — Know Your Customer. The identity verification process conducted to confirm the identity and age of Members and to comply with anti-money laundering obligations.
• "Cookies" — Small text files placed on your device by the Platform to enable core functionality, personalisation, analytics, and security features.
• "Consent" — A freely given, specific, informed, and unambiguous indication of a data subject's agreement to the processing of their personal data for a specified purpose.

Vivo4D collects personal data from Members and visitors through a variety of means, including account registration forms, identity verification processes, transaction records, and automated platform interactions. The categories of personal data we collect are set out below:

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond what is strictly necessary for age and identity verification purposes. Where verification of age or identity requires the submission of a government-issued identification document, the data contained therein is processed solely for KYC purposes and is retained only for the period required under applicable law.

Vivo4D processes your personal data for the following specific and legitimate purposes:

• Account Registration and Management: To create, maintain, and manage your player account on the Platform, including authentication and account security.
• Identity and Age Verification (KYC): To verify that you are at least 21 years of age and that your identity matches the payment instruments linked to your account, as required for anti-money laundering compliance.
• Transaction Processing: To process deposits and withdrawals in MYR via your chosen payment method, including FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank Online, and Hong Leong Connect.
• Fraud Prevention and Security: To monitor account activity for signs of fraudulent behaviour, unauthorised access, and money laundering, and to protect the security and integrity of the Platform.
• Responsible Gambling Compliance: To monitor gaming patterns, enforce self-exclusion orders and deposit limits, and identify Members who may be at risk of problem gambling, in fulfilment of our responsible gaming obligations.
• Service Improvement and Analytics: To analyse aggregated usage data to improve the performance, reliability, and user experience of the Platform.
• Communications: To send you transactional emails (account verification, withdrawal confirmations, security alerts) and, where you have opted in, promotional communications about Vivo4D offers and updates.
• Legal Compliance: To comply with applicable laws, regulations, and lawful requests from regulatory and law enforcement authorities.
• Dispute Resolution: To investigate and resolve complaints, disputes, or allegations of misconduct raised by Members or third parties.

Vivo4D processes your personal data on the basis of one or more of the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and Vivo4D, including account creation, transaction processing, and service delivery.
• Legal Obligation: Processing is required to comply with applicable legal and regulatory obligations, including anti-money laundering laws, age verification requirements, and data retention obligations.
• Legitimate Interests: Processing is necessary to pursue the legitimate interests of Vivo4D, including fraud prevention, platform security, responsible gambling monitoring, and service improvement, provided those interests are not overridden by your fundamental rights.
• Consent: Where processing is based on consent (for example, for marketing communications), you have the right to withdraw that consent at any time by contacting us at [email protected] or updating your account preferences. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Vivo4D does not sell, rent, or otherwise commercially transfer your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and only for the purposes described in this Policy:

• Payment Service Providers: Entities facilitating your deposits and withdrawals, including FPX, DuitNow, PayNet, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, and Hong Leong. These providers operate under their own privacy policies and applicable Malaysian financial regulations.
• KYC and Identity Verification Providers: Third-party services engaged to verify your identity and age in connection with our KYC obligations. These providers process only the minimum data necessary for verification purposes.
• Game Content Providers: Licensed game studios supplying game content to the Platform. These providers may receive anonymised or pseudonymised gameplay data for audit and RNG certification purposes only.
• IT Infrastructure and Security Providers: Cloud hosting, cybersecurity, and technical service providers engaged to maintain the Platform's infrastructure. All such providers are contractually bound to process data only on Vivo4D's instructions and in accordance with applicable data protection law.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or regulatory directive, Vivo4D will disclose personal data to the relevant authority. We will notify affected Members where permitted by law.
• Fraud Prevention Agencies: Where we suspect fraud, money laundering, or other financial crime, we may share relevant data with fraud prevention agencies or financial intelligence bodies.

All third-party processors engaged by Vivo4D are required to enter into a data processing agreement that obligates them to maintain appropriate security standards and restricts their use of your data to the purposes specified by Vivo4D.

The Vivo4D Platform uses cookies and similar tracking technologies (including web beacons and local storage) to enable core Platform functionality, improve user experience, and analyse usage patterns. Cookies do not contain executable code and cannot carry viruses or install malware on your device.

We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled without affecting core functionality.
• Functional Cookies: Used to remember your preferences (such as language settings and game display preferences) to personalise your experience on return visits.
• Analytics Cookies: Used to collect anonymised data about how visitors interact with the Platform, including pages visited, session duration, and navigation paths. This data helps us improve Platform performance and usability.
• Security Cookies: Used to detect and prevent fraudulent activity, including login anomalies and bot activity patterns.

You may manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform. Strictly necessary and security cookies cannot be disabled as they are essential to the operation of the Platform.

Vivo4D retains personal data only for as long as is necessary for the purposes set out in this Policy, or as required by applicable law. The following general retention periods apply:

On expiry of the relevant retention period, personal data is securely deleted or anonymised in accordance with our internal data destruction procedures.

Vivo4D implements robust technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security framework includes:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the Vivo4D Platform is encrypted using 256-bit SSL/TLS encryption, consistent with the standard employed by major Malaysian banking institutions.
• Encryption at Rest: Personal data stored on our servers is encrypted using industry-standard symmetric encryption, ensuring that data remains protected even in the event of unauthorised server access.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All internal access to member data requires multi-factor authentication and is subject to role-based access controls.
• Real-Time Fraud Monitoring: Our platform operates a 24/7 automated fraud detection system that flags anomalous account activity, including unusual login patterns and suspicious transaction behaviour.
• Regular Security Audits: We conduct periodic security assessments, including penetration testing and vulnerability scanning, to identify and address potential weaknesses in our infrastructure.
• Incident Response: In the event of a data security incident that is likely to result in a risk to your rights, Vivo4D will notify affected Members and relevant authorities without undue delay, in accordance with applicable law.

As a data subject, you have the following rights with respect to your personal data held by Vivo4D. These rights are available to all Members regardless of location, subject to applicable law and the limitations described below:

To exercise any of the rights above, please contact our Data Protection team at [email protected] with the subject line "Data Subject Request". We will acknowledge your request within 5 business days and respond substantively within 30 days. In certain cases, we may request proof of identity before processing your request.

The Vivo4D Platform is strictly intended for persons aged 21 years and above. We do not knowingly collect or process personal data from individuals under the age of 21. Any account found to have been registered by a person under 21 will be immediately suspended and all personal data associated with that account will be deleted, save for the minimum data necessary to fulfil any applicable legal reporting obligation.

If you believe that a person under the age of 21 has registered on the Platform, please notify us immediately at [email protected] so that we may investigate and take appropriate action.

In delivering its services, Vivo4D may transfer personal data to service providers and infrastructure partners located in jurisdictions outside Malaysia. Where such transfers occur, we take steps to ensure that adequate safeguards are in place to protect your personal data, consistent with the requirements of applicable data protection law.

Safeguards may include standard contractual clauses, binding corporate rules, or transfers to jurisdictions that have received a formal adequacy determination. By using the Platform, you acknowledge and consent to such transfers where necessary for the delivery of Vivo4D's services.

Vivo4D reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. When material changes are made, we will notify registered Members by email to their registered address and/or via a prominent notice on the Platform, with a minimum of 7 days' advance notice before the revised Policy takes effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the Platform following the effective date of any updated Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or to your personal data held by Vivo4D, please contact our Data Protection team using the details below. We are committed to responding to all privacy-related enquiries promptly and transparently.