Club 33 Privacy Policy – Personal Data Protection for Malaysian Members

01 Introduction & Scope of Privacy Policy

Welcome to Club 33's Privacy Policy. This document clearly explains how Club 33 ("we", "our platform") collects, uses, stores, protects, and discloses your personal information as a member or visitor of our platform at club33.click.

Club 33 is committed to protecting the privacy of every member. We understand that your trust is the foundation of our relationship — and that trust starts with full transparency about how we handle your data. This Privacy Policy is written in plain, straightforward language rather than confusing legal jargon, because we want every Malaysian player on Club 33 to truly understand their rights.

This Privacy Policy applies to all information collected through the Club 33 web platform, including all gaming sections, financial transactions, customer support interactions, and any written communications between you and our team. By registering an account or using Club 33's services, you agree to the practices described in this Privacy Policy.

02 Types of Personal Data We Collect

Club 33 only collects data that is necessary to provide its members with a safe, fair and high-quality service. The following are the categories of data we collect:

We do not collect information that is irrelevant to the delivery of our services. For example, Club 33 does not collect information about religious beliefs, political views, or any other sensitive data unrelated to your use of the platform.

03 How We Collect Your Data

Club 33 collects personal data through several transparent and lawful methods:

• Account Registration: When you register a Club 33 account, you provide basic information such as your phone number or email address and password. Additional details such as your full name and date of birth may be required during the identity verification process for your first withdrawal.
• Platform Usage: When you play, make deposits or withdrawals, and interact with the Club 33 platform, our systems automatically log those activities for security and technical support purposes.
• Deposits & Financial Transactions: When you make a deposit via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow or FPX (Maybank2u, CIMB Clicks), the required transaction information is processed through secure, encrypted payment channels.
• Communications with Support: When you contact the Club 33 support team via live chat or email, the contents of that conversation are retained to ensure continuity of service and for staff training purposes.
• Cookies & Tracking Technologies: The Club 33 platform uses cookies and similar tracking technologies to enhance the user experience. Please refer to Section 9 for more information on our use of cookies.

04 How Your Data Is Used

Every piece of data we collect has a clear and legitimate purpose. Club 33 uses your data to:

• Account Management: Creating and maintaining your account, processing secure logins, and ensuring you have access to all services you are entitled to as a Club 33 member.
• Financial Transaction Processing: Processing deposits, verifying withdrawals, and ensuring all financial transactions between you and Club 33 are handled accurately and securely.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, money laundering, duplicate account usage, and any unauthorised access attempts. This is our commitment to all members — keeping the platform safe for everyone.
• Legal Compliance: To meet applicable legal and regulatory requirements, including mandatory Know Your Customer (KYC) identity verification and financial reporting obligations.
• Customer Support: Providing technical assistance, resolving disputes, and ensuring a smooth and satisfying user experience for every Club 33 member.
• Responsible Gaming: Monitoring gameplay patterns to identify early signs of problem gambling and offering assistance or self-control tools to players who may need them.
• Platform Improvements: Analysing aggregated and anonymised usage data to understand how members use Club 33 and make meaningful improvements to the platform.
• Marketing Communications: Sending notifications about promotions, bonuses and platform updates — only to members who have opted in to receive such communications. You may unsubscribe from marketing emails at any time.

Club 33 does not use your data for any purpose beyond those stated above without first obtaining your explicit consent.

05 Data Sharing & Disclosure to Third Parties

Club 33 does not sell, rent, or trade your personal data to any third party for their own marketing purposes. This is our absolute promise to every member.

However, there are limited situations where Club 33 needs to share your data with certain parties to enable our services to function properly:

• Payment Service Providers: When you make a deposit or withdrawal, the required transaction information is shared with the relevant payment provider — such as Touch 'n Go, GrabPay, DuitNow, FPX and Malaysian banking institutions — solely for the purpose of processing that transaction.
• Game Providers: To enable you to play slots, live casino, or Sports Betting on Club 33, relevant session information may be shared with the applicable game software providers. These providers are bound by strict confidentiality agreements with Club 33.
• Regulatory Authorities: Club 33 will disclose your data to government authorities, law enforcement agencies, or courts when required by Malaysian law or a valid court order. In such situations, we will notify you if we are permitted to do so under the law.
• Audit & Certification: Independent audit bodies that verify Club 33's RNG systems and game fairness may access certain technical data — but not members' personal data — as part of their audit process.

In all cases where data is shared with third parties, Club 33 ensures that the relevant parties have adequate data protection measures in place and are bound by confidentiality agreements.

06 Data Security & Protection Measures

Protecting your data is more than a policy — it is an ongoing investment Club 33 makes in our platform's security infrastructure and processes. The security measures we have implemented include:

• 256-bit SSL Encryption: All communications between your web browser and club 33's servers are secured with 256-bit SSL encryption — the same standard used by Malaysia's top financial institutions, including Maybank and CIMB. This ensures that any data transmitted cannot be intercepted or read by unauthorised parties.
• Stored Data Encryption: Sensitive personal data stored in Club 33's databases is also encrypted using encryption-at-rest methods as an additional layer of protection.
• Internal Access Controls: Access to members' personal data within the Club 33 organisation is restricted on a need-to-know basis. Only staff who require access to carry out specific duties are permitted to view the relevant data.
• 24/7 Security Monitoring: Club 33's security team monitors platform activity in real time, around the clock, to detect any unauthorised access attempts, cyberattacks, or suspicious activity.
• Two-Factor Authentication (2FA): Club 33 offers two-factor authentication for all member accounts. We encourage all players to enable 2FA as an added layer of protection for their account.
• Regular Security Audits: The Club 33 platform undergoes regular security audits conducted by independent cybersecurity experts to identify and address any potential vulnerabilities.

While we take all reasonable steps to protect your data, no digital system is entirely impenetrable. We encourage you to take personal security precautions as well — such as using a strong and unique password, never sharing your login credentials with anyone, and reporting to us immediately if you suspect any suspicious activity on your account.

07 Data Retention Period

Club 33 does not retain your personal data for longer than necessary. Retention periods vary depending on the type of data and the purpose for which it was collected:

• Active Account Data: For as long as your account remains active, Club 33 will retain all account-related data in order to provide our services to you.
• Financial Transaction Records: Deposit records, withdrawal records, and other financial history are retained for a minimum of 7 years after the transaction date, in accordance with Malaysia's financial and tax regulatory requirements.
• Game Data: Betting history and game data are retained for 2 years after the game date for technical support, dispute resolution and regulatory compliance purposes.
• Communication Data: Customer support conversation records are retained for 1 year after the closure of the relevant ticket.
• After Account Closure: Upon account closure, Club 33 will delete or anonymise your personal data within a reasonable timeframe, except for data that must be retained for legal compliance purposes such as financial transaction records.

Once the relevant retention period has expired, your personal data will be securely deleted from our systems using recognised data erasure methods to ensure it cannot be recovered.

08 Your Rights Over Personal Data

As a Club 33 member, you have the following rights regarding the personal data we hold about you. These are your genuine rights, and Club 33 is committed to respecting and facilitating every related request:

To exercise any of the rights above, please contact the Club 33 support team by email at support@club33.click or via live chat within the platform. We will process your request within a reasonable timeframe and will not charge a fee for most privacy rights requests.

09 Cookies & Tracking Technologies

The Club 33 platform uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions properly. The following are the types of cookies we use:

• Essential Cookies: These cookies are essential for the basic operation of the Club 33 platform — including maintaining your login session, enabling the betting cart to function, and protecting against CSRF attacks. They cannot be disabled as they are critical to the platform's core functionality.
• Performance Cookies: These cookies collect information about how you use Club 33 — the most frequently visited pages, time spent in each section, and any error messages you encounter. This data helps us improve platform performance.
• Functional Cookies: These cookies allow the platform to remember your preferences — such as your preferred language, display settings and game choices — to deliver a more personalised experience.
• Security Cookies: Used by Club 33's security monitoring systems to detect suspicious login attempts and protect your account from unauthorised access.

You can manage cookies through your web browser settings. However, disabling essential cookies may affect the functionality of the Club 33 platform and your gaming experience. Visiting Club 33 without disabling cookies in your browser settings is considered your consent to the use of cookies as described above.

10 Children's Privacy

Club 33 is an online entertainment platform that intended for users aged 18 and above only. We do not knowingly collect or process personal data from any individual under the age of 18.

Should we discover that we have inadvertently collected personal data from someone under the age of 18, we will take immediate steps to delete that data and close the relevant account. Accounts registered by minors are in violation of Club 33's Terms & Conditions, and all associated balances or winnings will be voided.

If you find that a minor has registered or is using the Club 33 platform, please contact us immediately at support@club33.click so that we can take the appropriate action.

11 Amendments to the Privacy Policy

Club 33 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or new platform features. Whenever the Privacy Policy is updated, the "Updated" date at the top of this page will be revised to reflect the date of the latest amendment.

When we make significant changes to this Privacy Policy, we will notify members through:

• A clear in-platform notification the next time you log in
• Email to the address registered with your account
• The updated date at the top of this page

We encourage you to review this Privacy Policy periodically. Your continued use of the Club 33 platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

12 Contact Us About Privacy

If you have any questions, concerns, or wish to exercise your privacy rights regarding personal data held by Club 33, please do not hesitate to contact us:

• Privacy Email: support@club33.click — include "Privacy Enquiry" in the subject line of your email
• Live Chat: Available directly on the Club 33 platform — responses within minutes
• Response Time: We are committed to responding to all privacy-related enquiries within 14 working days
• Language: We handle enquiries in both Bahasa Melayu and English

We take every privacy-related enquiry seriously and are committed to providing clear, accurate and meaningful responses to each one received. Your privacy as a Club 33 member is a responsibility we uphold with the utmost trust.