Privacy Policy

1 Introduction

ltdtoto ("we", "us", "our") is the operator of the online betting and casino platform accessible at https://ltdtoto.cam (the "Platform"). We are committed to handling the personal data of our users ("you", "your", "User") with transparency, integrity, and respect for individual privacy rights.

This Privacy Policy ("Policy") describes the categories of personal data we collect, the purposes for which that data is processed, the circumstances under which it may be disclosed to third parties, how long we retain it, and the rights available to you as a data subject. This Policy applies in full to all visitors, registered users, and account holders of the ltdtoto Platform.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall relationship between ltdtoto and its users. In the event of any conflict between this Policy and the Terms & Conditions on matters of data handling, this Policy prevails.

2 Definitions

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

• "Account" — the personal user profile created upon registration on the ltdtoto Platform.
• "Data Controller" — ltdtoto, which determines the purposes and means of processing personal data.
• "Data Processor" — any third party that processes personal data on behalf of and under the instruction of ltdtoto.
• "Data Subject" — you, the individual to whom personal data relates.
• "KYC" — Know Your Customer: the identity and age verification process required before withdrawals or certain account features are enabled.
• "Personal Data" — any information that identifies or can reasonably be used to identify a living individual, including name, email address, IP address, and payment information.
• "Platform" — the ltdtoto website, applications, and any associated digital services operated at https://ltdtoto.cam.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
• "Sensitive Data" — categories of personal data warranting heightened protection, including financial account details and identification documents.

3 Data We Collect

ltdtoto collects personal data across several categories depending on how you interact with the Platform:

3.1 Registration and Account Data

When you create an Account, we collect your full legal name, date of birth, residential address, email address, phone number, and a username and password of your choosing. This information is necessary to establish and manage your Account.

3.2 Identity Verification (KYC) Data

To comply with anti-money laundering requirements and to verify your age (minimum 21 years), we may request copies of your Malaysian National Identification Card (MyKad), passport, and proof of residential address such as a recent utility bill or bank statement issued to an address in Malaysia.

3.3 Financial Data

When you make deposits or request withdrawals, we collect relevant payment information including your bank account details, eWallet identifiers (e.g., Touch 'n Go eWallet, Boost, GrabPay, DuitNow), FPX transaction references, and cryptocurrency wallet addresses where applicable. Full card numbers or bank login credentials are never stored on ltdtoto's servers.

3.4 Transaction and Gaming Data

We record all deposits, withdrawals, bets placed, games played, session durations, and wagering history associated with your Account. This data is used for account management, dispute resolution, fraud prevention, and regulatory compliance.

3.5 Technical and Device Data

We automatically collect technical data when you access the Platform, including your IP address, browser type and version, operating system, device identifiers, referring URL, and Platform interaction logs.

3.6 Communications Data

Records of your communications with ltdtoto support staff — including live chat transcripts, email correspondence, and any submitted queries — are retained for quality assurance, training, and dispute management purposes.

4 How Data is Collected

ltdtoto collects personal data through the following channels:

• Direct submission: Information you provide when registering, completing KYC, making deposits or withdrawals, or contacting support;
• Automated collection: Technical data gathered automatically through cookies, log files, and tracking technologies when you access the Platform;
• Payment processors: Transaction confirmation data received from our integrated payment service providers, including local Malaysian banking and eWallet systems;
• Third-party verification services: Identity verification outcomes from KYC service providers used to confirm your age and identity;
• Fraud prevention tools: Data received from fraud detection and anti-money laundering screening services.

5 Data Processing & Purposes

ltdtoto processes your personal data for the following defined purposes:

6 Legal Basis for Processing

Each category of processing at ltdtoto rests on one of the following legal bases:

• Performance of contract: Processing necessary to fulfil our obligations to you under the Terms & Conditions, including operating your Account, processing transactions, and providing access to games;
• Legal obligation: Processing required for compliance with applicable laws and regulations, including anti-money laundering screening, age verification, and record-keeping obligations;
• Legitimate interests: Processing that serves ltdtoto's reasonable business interests — such as fraud prevention, Platform security, and analytics — where those interests are not overridden by your rights and freedoms;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including the sending of direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

ltdtoto does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate confidentiality obligations:

• Payment service providers: Local Malaysian banks, eWallet operators, and payment gateways to process your financial transactions in MYR;
• Identity verification providers: Third-party KYC service providers used to verify your age and identity in compliance with regulatory requirements;
• Game content suppliers: Licensed third-party game studios that host or supply games available on the Platform may receive your Account identifier for purposes of game delivery and dispute resolution;
• Fraud prevention and security services: Third-party providers offering transaction monitoring, anti-fraud, and anti-money laundering screening tools;
• Legal and regulatory authorities: Government bodies, law enforcement agencies, or regulatory authorities where disclosure is required by applicable law, court order, or regulatory obligation;
• Corporate transactions: In the event of a merger, acquisition, or sale of business assets, your data may be transferred to a successor entity, subject to equivalent privacy protections being maintained.

8 Data Retention

ltdtoto retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations. The following general retention periods apply:

Where data is no longer required for any legitimate purpose, it is securely deleted or anonymised in a manner that prevents re-identification.

9 Security Measures

ltdtoto implements a range of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the Platform;
• Encrypted storage of sensitive data, including financial records and identity documents;
• Role-based access controls ensuring that only authorised personnel can access personal data on a need-to-know basis;
• Optional two-factor authentication (2FA) for User Account login;
• 24/7 automated and manual fraud monitoring and anomaly detection;
• Regular security assessments and penetration testing of Platform infrastructure.

While ltdtoto employs robust security practices, no internet transmission is completely secure. You are responsible for maintaining the confidentiality of your Account password and for notifying us immediately of any suspected unauthorised access.

10 Cookies & Tracking Technologies

ltdtoto uses cookies and similar tracking technologies to operate the Platform, improve user experience, analyse Platform performance, and where applicable, to deliver relevant promotional content to registered users. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for core Platform functionality, including session management, login authentication, and security. These cannot be disabled without impacting Platform usability.
• Performance and Analytics Cookies: Collect anonymous data on how users interact with the Platform, such as pages visited, time on site, and error logs, to help us improve functionality and performance.
• Functional Cookies: Remember your preferences such as language settings, game display options, and notification choices to personalise your experience.
• Marketing and Targeting Cookies: Used only with your explicit consent to track engagement with promotional content and to deliver relevant offers to your Account. You may opt out at any time.

You can manage or withdraw your consent to non-essential cookies through your browser settings or the cookie preference controls on the Platform. Disabling strictly necessary cookies may affect core Platform functionality.

11 Your Rights as a Data Subject

Depending on applicable data protection law, you may have the following rights in relation to your personal data held by ltdtoto:

To exercise any of the above rights, please contact our support team at [email protected]. We will respond within a reasonable timeframe and in accordance with applicable law. We may require identity verification before processing certain requests.

12 Protection of Minors

ltdtoto strictly prohibits participation by individuals under 21 years of age. We do not knowingly collect, retain, or process personal data belonging to any person below this minimum age threshold. Where we discover or have reasonable suspicion that an Account is held by or on behalf of an underage individual, we will immediately suspend the Account, initiate KYC verification, and if confirmed, permanently close the Account and return any verified real-money deposits via the original payment method.

If you are a parent or guardian and believe that a minor under your care has accessed or registered on the Platform, please contact us immediately at [email protected] so that we can take immediate action.

13 Third-Party Services

The ltdtoto Platform integrates services and content provided by third-party partners, including game studios, payment processors, and analytics tools. Each third-party provider operates under its own privacy policies and data handling practices, which are independent of this Policy.

Where third-party providers process personal data on ltdtoto's behalf, they do so under written data processing agreements that impose equivalent obligations of confidentiality, security, and compliance. ltdtoto does not permit third-party processors to use your data for their own independent purposes.

ltdtoto is not responsible for the privacy practices of any third-party services operating independently of the ltdtoto Platform, including any external platforms linked from the Platform (if applicable). You are encouraged to review third-party privacy policies directly.

14 International Data Transfers

ltdtoto's Platform infrastructure may involve the storage and processing of personal data on servers located outside of Malaysia. Where personal data is transferred internationally, ltdtoto ensures that appropriate safeguards are in place, including contractual protections, to ensure that your data receives a level of protection equivalent to that provided under applicable data protection standards.

By using the Platform, you acknowledge that your data may be processed in jurisdictions other than Malaysia. We will take all reasonable steps to ensure that any international transfer is conducted securely and in compliance with our obligations under this Policy.

15 Amendments to This Policy

ltdtoto reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform functionality. Where amendments are material, we will provide notice to registered users via the email address on file and will display a prominent notice on the Platform.

Continued use of the Platform after any amendment becomes effective constitutes your acceptance of the revised Policy. The "Last Updated" date at the top of this document indicates when the most recent revision was made. We encourage you to review this Policy periodically.

16 Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy, your personal data, or the exercise of your data rights, please contact our support team using the details below. All privacy-related enquiries are handled in confidence.