Privacy Policy

markas138 ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of every individual who visits, registers on, or interacts with the markas138 website at markas138.cam. This Privacy Policy ("Policy") sets out in clear and structured terms how we collect, process, store, share, and protect your personal information when you use our Platform.

This Policy applies to all users of markas138, including registered Players, prospective Players who browse the Platform without registering, and individuals who contact our customer support team. It covers all personal data that markas138 processes as the data controller.

By accessing or using markas138, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data in the manner described herein. If you do not agree to this Policy, please discontinue use of the Platform immediately.

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

• "Personal Data" means any information that identifies or can reasonably be used to identify you as an individual, including your name, email address, phone number, residential address, date of birth, payment details, and device identifiers.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, storage, use, transmission, analysis, and deletion.
• "Data Controller" means markas138, the entity that determines the purposes and means of Processing your Personal Data.
• "Data Processor" means any third party engaged by markas138 to Process Personal Data on its behalf, including payment processors, KYC verification providers, and analytics platforms.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the Processing of your Personal Data for a stated purpose.
• "Cookie" means a small text file stored on your device by the Platform's servers, used to remember preferences, session state, and usage patterns.
• "KYC" means Know Your Customer — the identity verification process required to comply with anti-money laundering obligations and to authorise withdrawal transactions.

markas138 collects only the data necessary to deliver a secure, compliant, and high-quality gaming experience. The categories of Personal Data we collect are outlined in the table below.

We do not 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 identity verification in compliance with KYC obligations.

markas138 collects Personal Data through the following channels:

4.1 Directly From You

We collect data that you provide to us directly when you register a Player Account, complete KYC verification, make a deposit or withdrawal request, contact our customer support team, respond to a survey or promotion, or update your account settings. This includes all form fields you complete on the Platform, as well as documents you submit for verification purposes.

4.2 Automatically Through Platform Use

When you browse or use the Platform, we automatically collect Technical Data and Usage Data via server logs, session tracking technologies, and analytics tools. This includes your IP address, the pages you visit, the games you play, how long you remain on the Platform, and the device and browser you use to access it. This data is collected regardless of whether you are logged in to a Player Account.

4.3 From Third-Party Service Providers

In certain circumstances, we receive data about you from third parties who assist us in operating the Platform. These include payment processors who confirm transaction status, KYC and identity verification providers who validate submitted documents, fraud prevention services that flag suspicious activity patterns, and analytics providers that help us understand how the Platform is used in aggregate. All such third-party Data Processors are bound by confidentiality obligations and data processing agreements consistent with this Policy.

4.4 From Cookies and Similar Technologies

We use cookies, local storage, and similar tracking technologies to collect data about your interactions with the Platform. Full details of our cookie practices are set out in Section 8 of this Policy.

markas138 processes your Personal Data only for clearly defined, legitimate purposes. The primary purposes for which we use your data are:

• Account Management: To create, maintain, and administer your Player Account, including authentication, account settings management, and password recovery.
• KYC & Age Verification: To verify your identity, confirm that you are at least 21 years of age, and satisfy our anti-money laundering obligations before processing withdrawals.
• Transaction Processing: To facilitate deposits and withdrawals via your chosen payment method, whether via Touch 'n Go eWallet, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, Boost, GrabPay, USDT TRC20, or 7-Eleven CLiQ.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Fraud Detection & Security: To identify, prevent, and respond to fraudulent transactions, unauthorised account access, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible Gambling Monitoring: To monitor usage patterns for indicators of problem gambling behaviour and to activate protective tools such as deposit limits or cooling-off periods where warranted.
• Platform Improvement: To analyse aggregate usage data for the purpose of optimising the Platform's performance, navigation, and game offering.
• Marketing Communications: Where you have provided consent, to send you relevant promotional offers, bonus notifications, and platform updates via email or SMS. You may withdraw consent at any time.
• Legal Compliance: To comply with applicable legal obligations, regulatory requirements, and lawful instructions from competent authorities.

markas138 processes your Personal Data one or more of the following legal grounds, depending on the specific Processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you have accepted, including account management, transaction processing, and customer support.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering obligations, KYC verification requirements, and responses to lawful authority requests.
• Legitimate Interests: Processing carried out in furtherance of markas138's legitimate business interests — including fraud prevention, platform security, and service improvement — where such interests are not overridden by your privacy rights.
• Consent: Processing based on your explicit consent, primarily in respect of marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of prior Processing.

markas138 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We share your data only in the limited circumstances described below, and only with parties who are bound by appropriate data protection obligations.

7.1 Service Providers (Data Processors)

We engage third-party service providers to assist in operating the Platform. These processors may receive access to your Personal Data solely to perform specific functions on our behalf, including payment processing (e-wallet providers, FPX, DuitNow, and bank partners), identity verification (KYC providers), customer support software, and platform analytics tools. All such processors operate under contractual obligations that restrict their use of your data to the designated purpose.

7.2 Legal & Regulatory Authorities

We may disclose your Personal Data to law enforcement agencies, regulatory bodies, courts, or other competent authorities where we are required to do so by law, where disclosure is necessary to comply with a lawful order, or where disclosure is necessary to protect the rights, property, or safety of markas138, its users, or others.

7.3 Anti-Money Laundering Partners

In the context of our AML compliance obligations, we may share transaction data and identity information with financial crime prevention networks and screening services. Such sharing is strictly limited to what is required by our legal obligations.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of the assets of markas138, your Personal Data may be transferred as part of that transaction. We will provide reasonable notice of any such transfer and of any material changes to the way your data is handled as a result.

markas138 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather aggregate usage analytics. The types of cookies we use are described below.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies — particularly essential cookies — may affect the functionality of the Platform, including your ability to log in or complete transactions.

markas138 retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The retention periods applicable to key categories of data are summarised below.

• Account & Identity Data: Retained for the duration of your active Player Account, and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping obligations.
• Transaction Data: Retained for a minimum of five (5) years following each transaction, in accordance with financial record-keeping requirements.
• KYC Verification Documents: Retained for a minimum of five (5) years following submission, unless a longer period is required by applicable law.
• Customer Support Communications: Retained for a period of three (3) years from the date of the interaction, to support dispute resolution and service quality improvement.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years thereafter, to demonstrate compliance with consent obligations.
• Technical & Usage Data: Typically retained in identifiable form for up to twenty-four (24) months, after which data may be anonymised for aggregate analytics purposes.

Following the expiry of applicable retention periods, Personal Data is securely deleted or anonymised in manner that prevents reconstruction of the original data. Requests for early deletion are handled in accordance with your rights as described in Section 11.

markas138 implements a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security infrastructure includes, but is not limited to:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Two-Factor Authentication (2FA): Players are strongly encouraged to enable 2FA on their Accounts, adding an additional verification layer to the login process.
• Access Controls: Access to Personal Data within our organisation is restricted on a strict need-to-know basis. Staff with access to Personal Data receive regular data protection training.
• Intrusion Detection Systems: Our platform is monitored around the clock for anomalous access patterns and potential security threats.
• Secure Data Centres: Personal Data is stored in data centres that meet recognised physical and environmental security standards.

While we take all reasonably practicable steps to safeguard your Personal Data, no data transmission over the internet can be guaranteed to be completely secure. You are responsible for keeping your login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your Account.

As a data subject, you hold a number of rights in relation to the Personal Data that markas138 holds about you. We are committed to honoring those rights promptly and without undue burden. Your rights include:

• 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: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update certain details directly through your Account settings.
• Right to Erasure ("Right to be Forgotten"): You may request that we delete your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies. Please note that this right is subject to our legal obligations — for instance, we cannot erase data we are required to retain under AML regulations.
• Right to Restriction of Processing: You may request that we temporarily restrict the Processing of your data in certain circumstances, such as while the accuracy of data is being contested.
• Right to Data Portability: Where Processing is based on consent or contractual necessity, you may request that we provide your Personal Data to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object to Processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease that Processing immediately.
• Right to Withdraw Consent: Where Processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of Processing that occurred before withdrawal.

To exercise any of the rights above, please contact our data privacy team via the email address set out in Section 14. We will acknowledge your request within five (5) business days and aim to respond in full within thirty (30) days. Complex or multiple requests may require up to sixty (60) days, in which case we will notify you of the extended timeline.

If we become aware that we have inadvertently collected Personal Data from an individual who is under 21 years of age, we will take immediate steps to delete that data from our records and close the associated account. Any winings associated with an underage account will be forfeited in accordance with our Terms & Conditions.

If you have reason to believe that an individual under the age of 21 has registered on markas138, we encourage you to contact our support team immediately so that we can investigate and take appropriate action.

markas138 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable legal requirements, or operational procedures. Where amendments are material — meaning they significantly affect how we collect, use, or share your Personal Data — we will notify you via the email address associated with your Player Account prior to the changes taking effect.

Non-material amendments, such as clarifications of existing provisions or minor typographical corrections, will be reflected on this page without separate notice. The effective date at the top of this Policy will be updated to reflect the date of any revision.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any amendment, you should cease using the Platform and may close your account in accordance with our Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way markas138 handles your Personal Data, please contact our data privacy team using the details below. We are committed to addressing all privacy-related enquiries promptly and professionally.

Data Privacy Enquiries:
Email: [email protected]

Live Chat Support:
Available 24 hours a day, 7 days a week, directly through the markas138 Platform. Accessible from any page on the site.

For account-related data requests — such as access requests, rectification requests, or erasure requests — please contact us via the above email address and include "Data Privacy Request" in the subject line along with your registered account username. We will verify your identity before processing any such request to protect against unauthorised data access.

For responsible gambling-related enquiries, including self-exclusion requests and deposit limit settings, please visit our dedicated Responsible Gambling page or speak with a support agent directly via live chat.