Lemon212 Privacy Policy – Personal Data Protection for Malaysia Members

Lemon212 is an online casino and Sports Betting platform operating in Malaysia and designed specifically for Malaysian players. In the course of our operations, we collect and process various types of personal data from registered members. This Privacy Policy — drafted in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA) — transparently explains what we collect, why we need it, how we use it, and your rights in relation to that data.

This policy applies to all personal data we collect through the Lemon212 website at lemon212.click, the Lemon212 mobile app for Android and iOS, interactions with our customer support team, and all our official communication channels including email, WhatsApp, and in-platform live chat.

This policy does not cover third-party websites or services that may be linked from our platform, though we only work with third-party providers that maintain robust privacy policies and adhere to established data protection standards.

Lemon212 only collects personal data necessary for platform operations, legal compliance, and enhancing the user experience. Below are the categories of data we collect, along with the purpose for each:

We do not collect sensitive data such as medical information, religious beliefs, or political affiliations without your explicit consent and a clear necessity. Biometric data is also not collected during the registration or use of the Lemon212 platform.

Every piece of data collected by lemon212 serve a clear and legitimate purpose. We do not process data for purposes not stated in this policy without first obtaining your renewed consent. The primary purposes for which we use data are as follows:

• Conducting the registration process, identity verification (KYC), and member account management
• Processing deposits and withdrawals via the Malaysian payment methods used (Touch 'n Go, GrabPay, DuitNow, Boost, ShopeePay, FPX, Maybank2u, CIMB Clicks)
• Providing effective customer support and resolving complaints or disputes
• Detecting and preventing fraud, money laundering, game manipulation, and other unlawful activities
• Fulfilling legal compliance obligations, including requirements under PDPA 2010 and applicable financial regulations
• Analysing usage patterns for platform improvement and user experience purposes (in aggregated form without individual identification)
• Sending essential operational communications such as transaction confirmations, terms change notices, and account security alerts
• Sending marketing communications about promotions and new offers — subject to your opt-out preferences
• Monitoring usage patterns for responsible gambling purposes and identifying members who may need assistance

Lemon212 does not sell members' personal data to any party for marketing or commercial purposes. However, there are specific situations where we need to share data with third parties for legitimate operational purposes:

• Payment providers: Transaction information is shared with the relevant digital wallet providers and banks (such as Touch 'n Go, GrabPay, and DuitNow) to process deposits and withdrawals. Such sharing is limited strictly to the information required to complete the transaction.
• Third-party game providers: Usernames and account IDs are shared with the live casino and slots providers we use for game operation purposes. These providers have their own privacy policies, which we review before entering into any partnership.
• Legal authorities: Lemon212 will disclose personal data to Malaysian authorities when required to do so by law, court order, or for the purposes of financial crime investigation. Please be aware that compliance with lawful requests from authorities is a legal obligation on our part.
• Technical service providers: Companies that provide infrastructure, hosting, cybersecurity, and analytics services to Lemon212 may have limited access to certain data within the scope of their services. All such providers are bound by strict confidentiality and data protection agreements.

In all of the above cases, data sharing is kept to a minimum, limited to specific purposes, and protected by appropriate contractual agreements. Lemon212 is not responsible for the privacy practices of independent third-party providers, but we only work with partners who meet or exceed our data protection standards.

Protecting the personal data of Lemon212 members is our top technical and organisational priority. The following are the key security measures we have in place:

• 256-bit SSL encryption for all data communications between user devices and lemon212 servers
• At-rest encryption of sensitive data for financial records and personal identification information
• Two-factor authentication (2FA) is available and encouraged for all member accounts
• Role-based internal access controls — Lemon212 staff can only access the data necessary to perform their specific duties
• Audit logs for all internal staff access to sensitive member data
• Firewall and intrusion detection systems monitored 24/7
• Regular security assessments including penetration testing by independent third parties
• Mandatory security and privacy awareness training for all staff
• A clear security incident response procedure to ensure members are promptly notified in the event of a data breach

While we take all reasonable steps to protect your data, no security system is 100% impenetrable. You also play an important role in keeping your account safe — do not share your password, enable 2FA, and report to us immediately if you suspect your account has been compromised.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights in relation to the personal data held by Lemon212:

To exercise any of the rights above, please contact the lemon212 support team at support@lemon212.click, stating the right you wish to exercise and your account details for verification. We may need to verify your identity before processing your request to ensure the security of your data.

Lemon212 uses cookies and similar tracking technologies on our website and app to enhance the user experience, analyse usage patterns, and maintain platform security. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functionality — including login session management, account security, and bet processing. These cookies cannot be disabled without affecting platform functionality.
• Preference Cookies: Saving your preferences — such as language, theme, and display layout — for your future sessions.
• Analytics Cookies: Collecting aggregated, non-identifiable usage data to help us understand how the platform is used and where improvements are needed.
• Security Cookies: Helping us identify suspicious login attempts, bot activity, and other security threats to keep your account protected.

You can manage your cookie settings through your browser preferences. However, disabling essential cookies will affect your ability to use the lemon212 platform fully. We do not use third-party advertising cookies to track your activity outside of the lemon212 platform.

Lemon212 retains members' personal data only for as long as necessary for the stated purposes, or as required by Malaysian law. The following outlines our data retention guidelines:

• Active account data: Retained for the duration of the active account and for 7 years after account closure, in line with financial record-keeping requirements under Malaysian law
• Financial transaction records: Retained for a minimum of 7 years in compliance with Malaysia's Anti-Money Laundering Act requirements
• Support communication records: Retained for 3 years for reference purposes and the resolution of any disputes that may arise at a later date
• Log and security data: Retained for 12 months for fraud detection and security analysis purposes
• Marketing data (where permitted): Retained until you withdraw consent or request deletion — whichever comes first

When data is no longer needed and no applicable legal retention obligation exists, it will be securely deleted or anonymised within 90 days. Anonymised data (where all individual identifiers have been fully removed) may be retained for long-term statistical analytics purposes.

The Lemon212 platform is exclusively for users aged 18 and above. We do not knowingly collect or process personal data from individuals under the age of 18. This is not merely a privacy policy — it is a legal and ethical obligation we take seriously.

During registration, age verification is carried out using information provided by the applicant. For withdrawals above certain thresholds, or at the request of our security team, full identity verification (KYC) may be required, including official identification documents confirming age.

If we discover that we have inadvertently collected personal data from an individual under the age of 18, we will take the following steps immediately:

• Immediate account closure
• Permanently deleting all personal data associated with the account
• Returning any remaining funds to the payment method used, subject to the necessary investigation
• Reporting incidents to the appropriate authorities where required

Parents or guardians who suspect their child has registered for or is using the Lemon212 platform are advised to contact our support team at support@lemon212.click immediately.

Lemon212 reserves the right to amend this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or operational improvements. All updates will be published on this page with a revised effective date.

For material amendments — changes that significantly affect how we use your data — we will provide advance notice via email to your registered address, or through an in-platform notification on Lemon212, at least 14 days before the changes take effect.

Continued use of the lemon212 platform after any amendments take effect will be considered acceptance of the revised policy. If you disagree with any changes, you have the right to close your account and withdraw your balance before the amendments come into effect.