Privacy Policy Comel 33 — Malaysian Player Data Protection

This Privacy Policy is issued by Comel 33 ("we", "platform") and applies to all users of the website Comel 33, mobile app, and any related services we provide ("Services"). This Privacy Policy describes our practices regarding the collection, use, disclosure, and protection of your personal information.

At Comel 33, we understand how sensitive personal information is in today's digital age. As an online gaming platform serving players across Malaysia, we recognise the trust you place in us every time you make a deposit via Touch 'n Go eWallet, play slots, join a Live Casino session or place your favourite football bet. That trust is something we take very seriously.

This Policy is drawn up in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA) and international best practices in data protection. By using the services of Comel 33, you acknowledge that you have read and understood this Privacy Policy.

Comel 33 only collects information that is genuinely necessary to provide Malaysian players with a safe, fair and enjoyable experience. The following are the categories of information we collect:

Comel 33 does not collect any sensitive data unrelated to the provision of services, including health information, political views, or religious beliefs.

Comel 33 uses the information collected solely for legitimate and transparent purposes. Every use of your data has a solid legal basis under Malaysia's PDPA. The following are the primary purposes for which your data is used:

• Account Management: Registering and maintaining your account Comel 33 yours, including identity verification during the KYC process and password recovery.
• Transaction Processing: Processing deposits via your preferred payment methods such as Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow or FPX, as well as managing withdrawal of winnings to your bank account or e-wallet.
• Gaming Service Provision: Grants you access to all games on Comel 33 — from online slots and Live Casino to Malaysian Super League and EPL Sports Betting, all the way to progressive jackpots.
• Security & Fraud Prevention: Continuously monitors account activity to detect and prevent unauthorised access, identity fraud, and money laundering.
• Responsible Gaming: Uses gameplay history data to identify risky betting patterns and offer support tools such as deposit limits and self-exclusion to players who need them.
• Legal Compliance: Meet reporting and compliance obligations required under applicable Malaysian law.
• Service Communications: Sending important account notifications related to transactions and promotions Comel 33 and policy updates via email or SMS (with your consent).
• Platform Improvements: Analysing aggregated and anonymised usage patterns to improve the gaming experience at Comel 33.

Comel 33 will not use your data for any purpose not stated above without first obtaining your consent through a clear and transparent process.

Comel 33 strictly applies a need-to-know principle — meaning your information is only shared with parties that genuinely require access in order to perform their service functions. We do not sell your personal data to any third party for marketing purposes.

The following are limited circumstances in which Comel 33 may share your information:

• Payment Processors: Approved payment service providers — including the FPX gateway, Touch 'n Go eWallet operators, GrabPay and DuitNow — receive the transaction details required to process your deposits and withdrawals. They are governed by their own privacy policies and confidentiality agreements.
• Game Providers: Third-party game providers that supply slots, Live Casino and other products on the platform Comel 33 may receive the player ID and game data necessary to operate the relevant game.
• Technical Service Providers: Companies that provide cloud computing, data analytics and cybersecurity services to Comel 33 subject to strict data processing agreements.
• Legal Authorities: Comel 33 is required to disclose player information when ordered by a court or a competent Malaysian regulatory authority, in accordance with our legal obligations.
• Rights Protection: Where necessary to enforce our Terms & Conditions, prevent fraud, or protect the rights, property and safety Comel 33 and its users.

Comel 33 continuously invests in robust security infrastructure to protect our players' personal data from unauthorised access, loss, damage or accidental disclosure. Key security measures we have in place include:

• 256-bit SSL Encryption: All communications between your device and the Comel 33 is encrypted using the latest TLS protocols, ensuring no third party can intercept your data in transit.
• Encrypted Database: Sensitive data such as financial information and identification details are stored in encrypted form within databases protected against external access.
• Two-Factor Authentication (2FA): Comel 33 offers two-factor authentication as an option to add an extra layer of security to your account.
• 24/7 Security Monitoring: Our automated monitoring system operates around the clock to detect and respond to any cybersecurity threats promptly.
• Internal Access Controls: Only staff Comel 33 who are authorised and have a legitimate business need may access players' personal data. All access is logged and audited on a regular basis.
• Penetration Testing: Comel 33 conducts regular security audits by independent experts to identify and address any system vulnerabilities before they can be exploited.

Comel 33 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

You can manage or disable cookies through your web browser settings at any time. However, disabling essential cookies may affect the functionality of the platform Comel 33 entirely, including the ability to log in to your account.

Under Malaysia's PDPA and the commitment of Comel 33 regarding privacy, you have the following rights in relation to your personal data. All requests will be processed within 14 business days:

To exercise any of the above rights, please contact our privacy team Comel 33 via email at privacy@comel33.im or via the live chat function on our platform. Your identity will be verified before any request is processed to ensure the security of your account.

Comel 33 retain your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy, or as required under applicable Malaysian law. The following are the general retention periods we observe:

Once the retention period has ended and there is no continuing legal requirement, Comel 33 will securely delete or anonymise your data using industry-recognised methods.

Comel 33 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, current legal requirements, or service improvements. All amendments will be published on this page with a clearly indicated update date.

For significant amendments that materially affect your rights, Comel 33 will notify you through one of the following methods:

• Email to your registered address at least 14 days before the amendments take effect.
• In-platform notifications when you log in to your account Comel 33.
• A prominent notice banner on the main page of our website.

Continued use of the platform Comel 33 following the amendments taking effect will be considered acceptance of the updated Privacy Policy. If you do not agree with any amendments, you have the right to close your account before they take effect.

If you have any questions, concerns or complaints regarding the Privacy Policy Comel 33 or the way we handle your personal data, please do not hesitate to contact us. Our privacy team will respond within 3 business days.

If you believe that Comel 33 has failed to resolve your privacy complaint to your satisfaction, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia, who is responsible for enforcing the PDPA 2010.