Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how club33 ("club33", "we", "us", or "our") collects, uses, stores, and discloses personal data in connection with the club33 online casino and sports betting platform accessible at club33.win (the "Platform"). This Policy applies to all visitors and registered members of the Platform, including members located in Malaysia and any other jurisdiction from which the Platform is accessed.

By accessing the Platform or registering as a club33 member, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with the terms of this Policy, you should not use the Platform.

This Policy should be read together with the club33 Terms and Conditions and Responsible Gaming Policy. In the event of any inconsistency between this Policy and the Terms and Conditions on a specific matter relating to data privacy, this Policy shall prevail.

2. Data Controller

club33 is the data controller in respect of personal data collected through the Platform. As data controller, club33 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable data protection principles and this Policy.

For all data-related enquiries, you may contact the club33 data team via the live chat support facility on the Platform or at the email address set out in Section 14 of this Policy.

3. Personal Data We Collect

club33 collects personal data from members and visitors through various means, including account registration, Platform usage, payment transactions, and support interactions. The categories of personal data we collect include:

Category	Examples	Collection Method
Identity Data	Full name, date of birth, gender, identity document details	Registration, KYC verification
Contact Data	Email address, phone number, residential address	Registration, account updates
Financial Data	Payment method details, transaction history, wallet balance	Deposit/withdrawal processing
Usage Data	Login timestamps, game sessions, bet history, Platform navigation	Automated Platform logging
Technical Data	IP address, device type, browser type, operating system	Automated collection via cookies
Communication Data	Support chat transcripts, email correspondence	Direct interaction with support

club33 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, or health data, except where strictly required by applicable anti-money laundering or responsible gaming obligations (for example, information relating to problem gambling self-assessments provided voluntarily by a member).

4. How We Use Your Personal Data

club33 uses the personal data collected from members and visitors for the following purposes:

• Account Management: To create, verify, maintain, and administer your club33 member account, including processing your identity verification (KYC) in accordance with applicable anti-money laundering requirements.
• Service Delivery: To provide you with access to the Platform's gaming and betting features, process your deposits and withdrawals, and deliver promotional offers you are eligible for.
• Security and Fraud Prevention: To monitor Platform activity for suspicious behaviour, prevent unauthorised account access, detect and investigate fraud or money laundering, and protect the security and integrity of the Platform.
• Responsible Gaming: To monitor gaming patterns in connection with responsible gambling obligations, administer self-exclusion requests, and apply account-level protections where required.
• Customer Support: To respond to your support requests, resolve disputes, and maintain records of communications for quality assurance and regulatory compliance purposes.
• Legal Compliance: To comply with applicable laws, regulations, court orders, and instructions from competent authorities, including anti-money laundering, counter-terrorism financing, and data protection obligations.
• Platform Improvement: To analyse aggregate and anonymised usage data in order to improve Platform performance, game selection, and member experience.
• Communications: To send you transactional communications relating to your account, and promotional communications where you have opted in or where we have a legitimate interest in doing so subject to your right to opt out at any time.

5. Legal Basis for Processing

club33 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and club33, including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable legal obligations, including anti-money laundering verification, age verification, and regulatory reporting.
• Legitimate Interests: Processing for purposes of Platform security, fraud prevention, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications, where your prior consent has been obtained and not subsequently withdrawn.

6. Disclosure of Personal Data

club33 does not sell or rent your personal data to third parties. club33 may disclose your personal data to the following categories of recipients in the circumstances described:

• Payment Service Providers: Financial institutions and e-wallet operators (including Touch n Go eWallet, Boost, Maybank, CIMB, and Public Bank) as necessary to process your transactions.
• Identity Verification Providers: Third-party KYC and anti-money laundering service providers used to verify member identities in accordance with applicable regulatory requirements.
• Technology Providers: Hosting, infrastructure, and software providers who process personal data on our behalf under contractual data processing agreements that require them to maintain appropriate security standards.
• Game Software Providers: Third-party game studios and live casino operators whose games are made available through the Platform, to the extent necessary to deliver those games to you.
• Regulatory Authorities: Competent governmental and regulatory authorities, where disclosure is required by law, court order, or lawful instruction.
• Professional Advisers: Legal, financial, and compliance advisers, subject to confidentiality obligations.

All third-party processors engaged by club33 are required to process personal data only for the specified purpose and in accordance with club33's instructions and applicable data protection standards.

7. Cookies and Tracking Technologies

The club33 Platform uses cookies and similar tracking technologies to provide core Platform functionality, maintain your login session, analyse Platform usage, and deliver relevant content. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for Platform operation, including session management and security tokens. These cannot be disabled without rendering the Platform non-functional.
• Functional Cookies: Used to remember your preferences, such as language settings and display preferences, to personalise your Platform experience.
• Analytical Cookies: Used to collect anonymised usage data to understand how members use the Platform and to identify areas for improvement.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair Platform functionality, including the ability to log in to your club33 account.

8. Data Retention

club33 retains personal data for the period necessary to fulfil the purpose for which it was collected, subject to the following minimum retention periods required by applicable regulations:

• Identity and financial verification records: minimum five (5) years from account closure, as required by anti-money laundering regulations.
• Transaction records: minimum five (5) years from the date of transaction.
• Support and communication records: three (3) years from the date of the relevant interaction.
• Marketing preference records: retained until you withdraw consent or request deletion, subject to any applicable legal retention requirement.

Following the expiry of applicable retention periods, personal data will be securely deleted or anonymised in accordance with club33's data disposal procedures.

9. Data Security

club33 implements technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include SSL/TLS encryption for all data in transit, access-controlled data storage, two-factor authentication options for member accounts, regular security assessments, and staff training on data handling obligations.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed as completely secure. club33 will notify affected members and relevant authorities of any data breach in accordance with applicable notification obligations.

10. Your Rights

Subject to applicable law and the terms of this Policy, you have the following rights in respect of your personal data held by club33:

• Right of Access: To request a copy of the personal data club33 holds about you.
• Right to Rectification: To request correction of inaccurate or incomplete personal data.
• Right to Erasure: To request deletion of your personal data, subject to club33's legal retention obligations.
• Right to Restriction: To request that processing of your personal data be restricted in specified circumstances.
• Right to Object: To object to processing of your personal data based on legitimate interests, including direct marketing.
• Right to Data Portability: To receive your personal data in a structured, machine-readable format where processing is based on consent or contractual necessity.

To exercise any of the above rights, please contact the club33 support team through live chat or at the email address provided in Section 14. club33 will respond to verified data subject requests within a reasonable timeframe and in any event within thirty (30) days of receipt.

11. Children and Age Restriction

The club33 Platform is strictly restricted to individuals aged 21 years 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 minor, that data will be deleted promptly and the associated account will be closed. If you believe a minor may have registered an account with club33, please notify us immediately through the live chat support facility.

12. Responsible Gaming and Data

club33 may use your usage and transaction data to identify patterns indicative of problem gambling behaviour, in fulfilment of our responsible gaming obligations. Where such patterns are identified, club33 may take protective action on your account, including restricting deposits, applying cooling-off periods, or initiating contact with you regarding responsible gaming support resources. This processing is carried out in your interests and in accordance with applicable responsible gaming guidelines.

Self-exclusion requests submitted through your club33 account settings are recorded and retained for the duration of the exclusion period and for a minimum of five (5) years thereafter. For more information on responsible gaming tools available to club33 members, please visit our Responsible Gaming page.

13. Changes to This Policy

club33 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, club33 will provide reasonable notice to members through the Platform or by email to the registered account address. The "Last updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the Platform following the publication of an updated Policy constitutes your acceptance of the revised terms.

14. Contact and Data Enquiries

For all privacy-related enquiries, data subject rights requests, or concerns regarding this Policy, please contact the club33 data team through the 24/7 live chat facility available on the Platform, or by email at: [email protected]

club33 is committed to resolving all privacy-related concerns promptly and transparently. If you are not satisfied with the outcome of a data enquiry, you may escalate your concern through the formal dispute resolution procedures described in the club33 Terms and Conditions.