Privacy Policy

01 Introduction

This Privacy Policy is issued by mantul138 (hereinafter referred to as "the Company", "we", "us", or "our"), the operator of the online gaming platform located at https://mantul138.cam (the "Platform"). It governs the collection, use, storage, disclosure, and protection of personal data belonging to all registered Members, visitors, and any other individuals who interact with the Platform (collectively referred to as "you", "the User", or "the Data Subject").

mantul138 takes data privacy seriously. We operate with full respect for the personal information entrusted to us by our players — from Kuala Lumpur and Petaling Jaya to Penang, Johor Bahru, and Shah Alam — and we are committed to handling that data responsibly, transparently, and in compliance with applicable data protection principles.

This Privacy Policy should be read alongside our Terms & Conditions, which govern the overall use of the mantul138 Platform and form part of the contractual relationship between you and the Company.

02 Definitions

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

• "Personal Data" means any information that relates to an identified or identifiable natural person — including but not limited to name, identification number, contact details, financial information, device identifiers, and behavioural data.
• "Processing" means any operation performed on Personal Data, whether automated or manual — including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, erasure, or destruction.
• "Data Controller" means mantul138, which determines the purposes and means by which Personal Data is processed.
• "Data Processor" means any third party that processes Personal Data on behalf of mantul138, strictly pursuant to documented instructions.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for a specified purpose.
• "KYC Data" means identity and age verification documentation provided by a Member during the Know Your Customer process, including government-issued identification such as a MyKad or passport.
• "Cookies" means small text files placed on your device by the Platform for the purposes of session management, analytics, and personalisation.

03 Data We Collect Key Section

mantul138 collects only the Personal Data that is necessary to operate your Account securely, fulfil our regulatory obligations, and provide you with a high-quality gaming experience. The categories of data we collect are as follows:

04 How We Collect Your Data

mantul138 collects Personal Data through the following means:

1. Direct Submission: Data you provide voluntarily when registering an Account, completing KYC verification, making deposits or withdrawal requests, contacting support via live chat or email, or participating in promotions.
2. Automated Collection: Technical data collected automatically when you access or use the Platform, including via cookies, web beacons, server logs, and similar tracking technologies. This data is collected regardless of whether you are a registered Member.
3. Payment Processors: Financial data shared with mantul138 by authorised third-party payment providers — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency processors — when you initiate or complete a transaction.
4. Identity Verification Partners: Data provided to or received from third-party KYC verification service providers engaged to confirm the identity and age of Members in compliance with anti-money laundering (AML) obligations.
5. Third-Party Analytics Providers: Aggregated and anonymised behavioural data gathered via platform analytics tools used to improve the user experience and Platform performance.

05 Purposes of Data Processing

mantul138 processes your Personal Data for the following clearly defined purposes:

• Account Administration: Creating, maintaining, and managing your Member Account, including password resets, account settings updates, and verification of login credentials.
• Payment Processing: Facilitating deposits and withdrawals via supported Malaysian payment methods and cryptocurrency networks; reconciling transaction records; detecting and preventing fraudulent payment activity.
• Regulatory Compliance: Meeting obligations under applicable anti-money laundering (AML), counter-terrorism financing (CTF), and Know Your Customer (KYC) regulations as required by the gaming licence under which mantul138 operates.
• Responsible Gambling: Monitoring betting and deposit patterns to identify Members who may be exhibiting signs of problem gambling; administering self-exclusion requests, deposit limits, and session controls; complying with responsible gambling regulatory requirements.
• Customer Support: Responding to enquiries, resolving disputes, processing complaints, and delivering live chat assistance in English, Bahasa Melayu, and Chinese.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, account takeover attempts, and any conduct that violates our Terms and Conditions.
• Platform Improvement: Analysing aggregated usage data and behavioural patterns to improve game selection, user interface, payment flows, and overall Platform performance.
• Marketing Communications: Sending promotional offers, bonus notifications, and relevant gaming updates — only where you have provided explicit consent or where a legitimate interest applies and you have not opted out.

06 Legal Bases for Processing Transparency

mantul138 processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and mantul138 — including Account management, payment processing, and game delivery — is carried out on the basis that it is necessary to fulfil our contractual obligations to you.
• Legal Obligation: Processing required for mantul138 to comply with applicable legal obligations — including KYC, AML, CTF, and responsible gambling regulations — is carried out on the basis of legal compliance.
• Legitimate Interests: Processing carried out to protect the security of the Platform, prevent fraud, improve services, and conduct analytics is based on the legitimate interests of the Company, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Marketing communications and non-essential cookie placement are based on your explicit, freely given, and revocable consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

07 Data Sharing & Disclosure

mantul138 does not sell, rent, or trade your Personal Data to any third party for commercial gain. We share Personal Data only in the limited circumstances described below, and only to the extent strictly necessary for each stated purpose:

1. Payment Service Providers: Transaction data is shared with authorised payment processors — including but not limited to Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency processing partners — solely for the purpose of processing your deposits and withdrawals.
2. Identity Verification Partners: Identity and KYC documents are shared with accredited identity verification service providers engaged to support our regulatory compliance obligations. These providers are contractually bound to process data only for the specified purpose.
3. Gaming Platform Providers: Anonymised or pseudonymised session data may be shared with the licensed game studios and technology providers that supply games on the Platform, solely for the purpose of game delivery and RNG auditing.
4. Regulatory and Law Enforcement Authorities: mantul138 will disclose Personal Data to competent regulatory bodies, law enforcement agencies, or courts of law where required to do so by applicable law, court order, or binding regulatory direction — including in the context of AML investigations or responsible gambling enforcement.
5. Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of all or part of the Company's assets, Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

08 International Data Transfers

The mantul138 Platform operates with the support of technology infrastructure, payment processors, and service providers that may be located in jurisdictions outside Malaysia. Where your Personal Data is transferred to or processed in a country outside your country of residence, mantul138 takes appropriate measures to ensure that such transfers are conducted securely and in compliance with applicable data protection standards.

These measures may include: contractual data protection clauses with the receiving parties; confirmation that the receiving jurisdiction provides an adequate level of data protection; or other recognised transfer mechanisms as appropriate. By using the mantul138 Platform, you acknowledge and consent to the transfer of your Personal Data to jurisdictions where our service providers operate, under the safeguards described herein.

09 Data Retention

mantul138 retains 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 following retention guidelines apply:

• Active Account Data: Retained for the duration of the Member's active Account, plus a minimum of five (5) years following Account closure, in compliance with standard AML and gaming regulatory record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years following the conclusion of the business relationship, or longer if required by applicable law or regulatory guidance.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of each transaction, for AML compliance and audit purposes.
• Support Communications: Live chat transcripts and email correspondence are retained for three (3) years from the date of last contact, to support dispute resolution and quality assurance.
• Technical and Analytical Data: Anonymised or aggregated analytical data may be retained indefinitely for Platform improvement purposes, as it no longer constitutes Personal Data.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with our internal data lifecycle management procedures.

10 Cookies & Tracking Technologies Technical

mantul138 uses cookies and similar tracking technologies to enhance your experience on the Platform, ensure secure session management, and analyse usage patterns. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the operation of the Platform — including session authentication, login persistence, and security token management. These cookies cannot be disabled without impairing core Platform functionality.
• Performance and Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the Platform — including pages visited, time spent, and error occurrences — to help us improve performance and user experience.
• Functional Cookies: Remember your preferences and settings — such as language, currency display, and game history — to provide a more personalised experience on return visits.
• Marketing Cookies: Used, with your consent, to deliver relevant promotional content within the Platform based on your interaction history. These are not used for cross-site advertising tracking.

You may manage your cookie preferences through your browser settings or through any cookie preference tool provided on the Platform. Note that disabling certain categories of cookies may affect the availability and functionality of specific Platform features.

11 Security Measures Protected

The security of your Personal Data is a priority at mantul138. We implement a layered security architecture designed to protect your data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the mantul138 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Secure Data Storage: Personal Data and financial records are stored on secure, access-controlled servers with restricted personnel access governed by the principle of least privilege.
• Access Controls: Strict role-based access controls ensure that only authorised Company personnel can access Personal Data, and only to the extent required for their specific duties.
• Intrusion Detection and Monitoring: The Platform infrastructure is continuously monitored for suspicious activity, including automated intrusion detection systems and manual security reviews.
• Data Breach Response: In the event of a confirmed data breach that is likely to result in risk to your rights and freedoms, mantul138 will notify affected individuals and relevant regulatory authorities in accordance with applicable data protection obligations.

While mantul138 implements robust technical and organisational security measures, no system is entirely immune to all threats. We encourage you to use a strong, unique password for your Account and to enable two-factor authentication where available.

12 Your Data Rights Your Rights

As a data subject, you hold the following rights in relation to the Personal Data that mantul138 holds about you. These rights may be subject to certain limitations under applicable law, including where data is required to be retained for regulatory compliance purposes:

1. Right of Access: You have the right to request a copy of the Personal Data mantul138 holds about you, along with information about the purposes of processing, the categories of data held, and the recipients to whom it has been disclosed.
2. Right to Rectification: You have the right to request correction of any Personal Data that is inaccurate, incomplete, or out-of-date. Minor corrections (e.g., contact details) may be made directly through your Account settings.
3. Right to Erasure: You have the right to request deletion of 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 lawful basis for processing applies. Please note that certain data may need to be retained to fulfil legal obligations.
4. Right to Restrict Processing: You have the right to request that mantul138 restricts the processing of your Personal Data in certain circumstances — for example, while the accuracy of data is being contested or while an objection to processing is being considered.
5. Right to Data Portability: Where processing is based on consent or contractual necessity, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format, and to request that it be transmitted directly to another controller where technically feasible.
6. Right to Object: You have the right to object to processing carried out on the basis of legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease such processing immediately.
7. Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact our Data Privacy team at [email protected]. We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days. Where a request is complex or voluminous, we may extend this period by a further 30 days, with prior notification.

13 Children & Minors 21+ Only

The mantul138 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. Our registration process includes mandatory age declaration, and all accounts are subject to KYC age verification prior to the processing of any withdrawal.

If mantul138 discovers that an Account has been registered by, or Personal Data has been collected from, an individual under the age of 21, we will take the following immediate action: suspend the Account, securely delete the associated Personal Data to the extent permitted by law, return any deposited funds to the original payment source, and decline to pay any winnings accumulated.

If you have reason to believe that a minor has registered an Account on the Platform, please contact us immediately at [email protected]. We treat all such reports with the highest priority.

14 Third-Party Links & Services

The mantul138 Platform may, from time to time, contain references to or integrations with third-party services — including payment processors, identity verification providers, and analytics platforms. This Privacy Policy applies exclusively to data collected and processed by mantul138 as Data Controller.

Third-party services operate under their own independent privacy policies, which mantul138 does not control and is not responsible for. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of the mantul138 Platform, particularly in relation to payment processing via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and Hong Leong.

15 Amendments to This Policy

mantul138 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, our data processing practices, or the services we provide. Where changes are material — for example, the introduction of new categories of data collection or new purposes for processing — we will notify registered Members via email and display a prominent notice on the Platform prior to the changes taking effect.

The "Last Reviewed" date at the top of this page will be updated to reflect the date of the most recent revision. Your continued use of the Platform following publication of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you object to any changes, you should cease using the Platform and contact support to arrange Account closure.

16 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the Personal Data mantul138 holds about you, please contact us through any of the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the mantul138 Platform; average response time 3–5 minutes
• Support Languages: English, Bahasa Melayu, and Chinese

For data subject rights requests specifically — including access, rectification, erasure, or portability requests — please include "Data Rights Request" in the subject line of your email and provide sufficient information to verify your identity. We aim to acknowledge all data rights requests within 5 business days and resolve them within 30 calendar days.