club33 Privacy Policy

club33 operates the online gambling platform accessible at club33.one ("the Platform"). In this Privacy Policy, "club33," "we," "our," and "us" refer to the operator of club33.one. We act as the data controller for personal data collected through the Platform.

This Privacy Policy applies to all visitors, registered users, and players of the Platform. If you are accessing the Platform on behalf of another person or entity, you represent that you have the authority to bind that person or entity to this policy.

club33 collects personal data only to the extent necessary to provide, maintain, and improve the Platform and to comply with applicable legal and regulatory obligations. The categories of personal data we collect are as follows:

club33 collects personal data through the following channels:

• Direct interactions: Data you provide when registering an account, completing KYC, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including via cookies, session tokens, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud risk signals from payment processors; and publicly available information used to verify your identity or comply with anti-money laundering obligations.

club33 does not purchase personal data from data brokers or other commercial data aggregators for marketing purposes.

club33 uses your personal data for the following purposes:

• Account management: Creating and maintaining your registered account; verifying your identity; processing deposits and withdrawals; managing bonus credits and wagering requirements.
• Service delivery: Providing access to casino games, the sportsbook, live dealer tables, and all other Platform features.
• Legal and regulatory compliance: Meeting Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations; responding to lawful requests from regulatory authorities; age verification enforcement.
• Fraud prevention and security: Detecting and investigating suspicious activity; identifying unauthorised access; preventing bonus abuse and collusion.
• Responsible gaming: Monitoring for patterns indicative of problem gambling; applying self-imposed limits; enforcing self-exclusion periods.
• Communications: Sending transactional messages (deposit confirmations, withdrawal receipts, OTPs); responding to support enquiries; sending promotional communications where you have opted in.
• Platform improvement: Analysing aggregate usage patterns to improve game selection, interface design, and service reliability.

club33 processes your personal data on the following legal grounds:

• Contract performance: Processing necessary to provide the services you have registered for, including account management, game access, and payment processing.
• Legal obligation: Processing required to comply with KYC, AML, age verification, and other regulatory requirements applicable to the operation of online gambling services.
• Legitimate interests: Processing for fraud prevention, platform security, service improvement, and responsible gaming monitoring, where our interests do not override your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw this consent at any time.

club33 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary:

• Payment service providers: Touch n Go, Boost, Maybank, CIMB, and Public Bank, for processing deposits and withdrawals in MYR.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify identity documents and screen against sanctions lists.
• Game technology providers: Software providers whose games are integrated into the Platform, to the extent necessary for gameplay audit trails and technical support.
• Regulatory authorities: Where required by law, court order, or the lawful direction of a competent regulatory authority.
• Fraud prevention networks: Where sharing is necessary to identify, prevent, or investigate fraud affecting the Platform or its users.

All third parties with whom club33 shares personal data are contractually required to handle it in accordance with applicable data protection requirements and to use it solely for the specified purpose.

club33 uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used are:

• Strictly necessary cookies: Required for the Platform to function — session authentication, security tokens, load balancing. These cannot be disabled without impairing Platform functionality.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and display options across sessions.
• Analytics cookies: Collect aggregate, anonymised data on how users interact with the Platform to help club33 improve navigation and game discovery.

You can manage cookie preferences through your browser settings. Disabling all cookies may affect your ability to log in to the Platform or use certain features.

club33 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, to comply with AML and regulatory record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Retained for two (2) years from the date of the interaction.
• Technical and usage logs: Retained for twelve (12) months on a rolling basis.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to any individual.

Subject to applicable law, you have the following rights in relation to your personal data held by club33:

• Right of access: Request a copy of the personal data club33 holds about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of your personal data, subject to club33's legal retention obligations.
• Right to restriction: Request that club33 restrict processing of your data in certain circumstances.
• Right to data portability: Request transfer of your personal data to another service provider in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: Withdraw consent for processing activities based on consent at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact club33 at [email protected] with the subject line "Data Rights Request." club33 will respond within thirty (30) days of receiving a valid request.

club33 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Security measures in place include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and club33 servers;
• Encrypted storage of sensitive personal data at rest;
• Access controls limiting personal data access to authorised personnel on a need-to-know basis;
• Regular security audits and penetration testing of Platform infrastructure;
• Two-factor authentication available for all user accounts.

The Platform integrates third-party game software and payment infrastructure. These third-party services operate under their own privacy policies and terms. club33 is not responsible for the privacy practices of third-party game providers or payment processors, except to the extent that our data sharing agreements govern the handling of personal data transferred to them.

The Platform does not contain links to external websites. All content accessible through club33.one is operated by or under agreement with club33.

The Platform is strictly restricted to individuals aged twenty-one (21) and above. club33 does not knowingly collect personal data from individuals under the age of 21. If club33 becomes aware that personal data has been collected from a person below this age threshold, that data will be deleted immediately and the associated account terminated.

If you have reason to believe that a minor has registered on the Platform, please notify us immediately at [email protected].

club33 reserves the right to update this Privacy Policy at any time. Material changes will be notified to registered users via email to the address on record no less than seven (7) days before the amended policy takes effect. The date of the most recent revision is displayed at the top of this page.

Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with any amendment, you should close your account and cease using the Platform before the amendment takes effect.

For all privacy-related enquiries, data subject requests, or concerns about club33's data handling practices, please contact: