Privacy Policy come33 — Your Data Protection & Information Security

1. Introduction

Welcome to the come33 Privacy Policy page. This document explains in detail how come33 ("we", "our platform") collects, processes, stores, and protects your personal data ("Player", "you") when you use the come33.pro website and all related services.

Come33 understands that your trust is our most valuable asset. We are therefore committed to handling all personal data with the highest standards of confidentiality and security. This Privacy Policy is prepared in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA) and international best practices in data protection.

By registering or using the come33 platform, you agree to the collection and use of your personal information as described in this Privacy Policy. If you do not agree, please stop using our platform and contact us to request deletion of your data.

2. Information We Collect

Come33 collects various types of information to enable us to provide a secure, seamless, and high-quality service. The following are the main categories of information we collect:

A. Information You Provide Directly

• Full name as shown on a valid identity document.
• Date of birth for age verification purposes (21 years and above).
• Email address and mobile number for communication and verification.
• Current residential address.
• Identity card number (MyKad) or passport number for the KYC process.
• Bank account or digital wallet details used for deposits and withdrawals.
• Copies of identification documents and proof of address for identity verification.

B. Information Collected Automatically

• IP address of the device used to access the platform.
• Web browser type and device operating system.
• Login session data including date, time, and session duration.
• Game history, deposits, withdrawals, and activity within the platform.
• Cookie data and similar tracking technologies.
• General geolocation information based on IP address.

C. Information from Third Parties

• Identity verification from trusted third-party KYC service providers.
• AML (Anti-Money Laundering) screening information from recognised databases.
• Data required from payment processors to process your transactions.

3. How We Use Your Data

Come33 uses collected personal data solely for legitimate and specific purposes. Below is a summary table of data usage purposes and their corresponding legal bases:

If you do not wish to receive marketing communications from come33, you may withdraw your consent at any time by contacting our support team or using the unsubscribe function found in any marketing email we send.

4. Sharing Information with Third Parties

Come33 does not sell, rent, or trade players' personal data to any third party for commercial or marketing purposes. However, in certain limited situations, we may need to share your information with the following parties:

• Payment Processors: Payment service providers that help process your deposits and withdrawals, such as FPX, Touch 'n Go, and local banks. They only receive the information necessary to complete the transaction.
• KYC Providers: Third-party identity verification companies that assist us in verifying player identification documents to meet legal requirements.
• Game Service Providers: Game software providers (game providers) who require minimum session information to deliver game content to you.
• Legal Authority: Government agencies, courts, or law enforcement bodies where required by law or a valid court order.
• Professional Advisors: Lawyers, accountants, or auditors subject to strict confidentiality obligations.

All third parties we work with are required to comply with data protection standards equivalent to or higher than those we uphold. Every data-sharing arrangement is governed by a legally binding confidentiality agreement.

5. Data Security

Come33 implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Our key security measures include:

• 256-bit SSL Encryption for all data transmitted between your browser and our servers.
• Data encryption at rest (encryption at rest) for all sensitive data stored in our database.
• Two-factor authentication (2FA) available on all player accounts as an additional layer of security.
• 24/7 security monitoring by a dedicated cybersecurity team.
• Role-based access control ensuring that only authorised personnel can access specific data.
• Penetration testing conducted periodically by independent security experts.
• Data backup performed automatically and stored in a secure, separate location.

While we take all reasonable steps to protect your data, no security system is entirely impenetrable. If you suspect your account has been accessed without authorisation, please contact the come33 support team immediately.

6. Use of Cookies

Come33 uses cookies and similar tracking technologies to enhance the user experience on our platform. Cookies are small text files stored on your device when you visit our website.

We use the following types of cookies:

• Essential Cookies: Required for core platform operations such as login verification and session management. These cookies cannot be disabled as they are essential to your account security.
• User Preference Cookies: Saving your language preference, display theme, and other settings you have selected for a consistent experience.
• Analytics Cookies: Helping us understand how players use our platform so we can make meaningful improvements. Data collected is not personally identifiable.
• Security Cookies: Used to detect and prevent suspicious activity and protect player accounts from security threats.

You can control or disable cookies through your web browser settings. Please note that disabling certain cookies may affect the functionality and user experience of the come33 platform.

7. Your Rights as a Data Subject

As a come33 player and data subject under Malaysia's PDPA, you hold the following rights regarding your personal data. We respect and facilitate the exercise of each of these rights:

To exercise any of the rights above, please contact our data protection team via email at [email protected] or via the platform's Live Chat. We are committed to processing every request within 30 business days from the date the request is received.

8. Data Retention & Deletion Period

Come33 retains players' personal data only for as long as it is needed for the purpose it was collected, or as required by law. The following are the data retention guidelines we observe:

• Active account data: Retained for the duration of account activity and up to 7 years after account closure to meet financial record-keeping and AML compliance requirements.
• Financial transaction records: Retained for a minimum of 7 years in accordance with Malaysian legal requirements for financial records.
• KYC Documents: Retained for the duration of account activity and 5 years after account closure, or in line with requirements from the relevant authorities.
• Customer support communication logs: Retained for 3 years for dispute resolution and service improvement purposes.
• Analytics and system log data: Non-personally identifiable data is retained for 2 years; detailed system logs are retained for 12 months.
• Marketing data: Retained until you withdraw consent or close your account, whichever comes first.

Upon expiry of the defined retention period, personal data will be securely deleted or anonymised in accordance with our integrated data disposal procedures. Anonymised data that cannot be linked to any specific individual may be retained for statistical and research purposes.

9. Cross-Border Data Transfers

In the course of our operations, your personal data may be processed or stored on servers located outside Malaysia. This occurs primarily when we use cloud computing services or work with international service providers.

Come33 ensures that any cross-border data transfers are carried out with adequate safeguards, including:

• Transfers only to countries with a level of data protection equivalent to or higher than Malaysia.
• Use of internationally recognised standard data transfer agreements.
• A data protection impact assessment (DPIA) is conducted before any significant new data transfer.
• All data recipients outside Malaysia are required to comply with data protection standards equivalent to Malaysia's PDPA.

10. Children's Privacy

The come33 platform is an adult service strictly available to individuals aged 21 and above. We do not knowingly collect or process any personal data from individuals under the age of 21.

Should we discover that personal data of a minor or underage individual has been collected without proper verification, we will immediately take the following steps:

• Suspending the relevant account while an investigation is conducted.
• Deleting all personal data of the individual concerned from our systems.
• Returning any funds in the account to the original payment method.
• Reporting the incident to the relevant authorities where required.

If you become aware that a minor has registered for or used the come33 platform, please contact us immediately via email [email protected] so that we may take appropriate action.

11. Changes to This Privacy Policy

Come33 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or improvements in how we protect your data.

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

• Updating the "Last Updated" date shown at the top of this page.
• Displaying a clear notice on the platform's home page for at least 14 days before the changes take effect.
• Sending notifications via registered email for changes deemed significant in how we process your personal data.

Continued use of the come33 platform after the effective date of any policy changes is considered your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed of how we protect your privacy.

12. Contact Our Data Protection Officer

If you have any questions, concerns, or complaints regarding how come33 handles your personal data, or to exercise any of the rights outlined in this Privacy Policy, please contact our Data Protection Officer (DPO):

• Data Protection Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 directly through the come33 platform.
• Official Telegram: Contact us via come33's official Telegram channel.

We are committed to responding to all privacy-related enquiries within 5 business days. For more complex complaints requiring detailed investigation, we will keep you informed of the expected timeline and provide regular updates on the progress of the investigation.

If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP) or the relevant data protection authority in your country.