Comel33 Privacy Policy – Your Personal Data Protection in Malaysia

To provide every member with a secure, fair, and personalised experience, comel33 needs to collect certain categories of personal information. We only collect data that is strictly necessary for the stated purposes — nothing more.

Information you provide directly:

• Full name as stated in your official identification document
• Identity card number (MyKad) or passport number for identity verification purposes
• Date of birth to verify age eligibility (18 years and above)
• Active email address for account communications and important notifications
• Registered Malaysian mobile number
• Bank account or digital wallet details for processing deposits and withdrawals
• Supporting KYC documents such as a copy of your MyKad or utility bill as proof of address

Automatically collected information:

• IP address and device information used to access the platform
• Session log data including login time, logout time, and session duration
• In-platform gaming activity history and financial transaction records
• Your device's web browser and operating system information
• Cookie data and other tracking technologies as described in Section 4

The personal data we collect is used solely for legitimate and transparent purposes. Below is a summary table outlining the purposes of data use and their corresponding legal basis.

Comel33 will not use your data for any purpose other than those stated above without first obtaining your consent. Should there be any change in the purpose of use, you will be notified via email or an in-platform notification.

Comel33 does not sell, rent, or share your personal data with external parties for their own marketing purposes. However, in the normal course of operating the platform, there are limited situations where your data may need to be shared with certain parties:

• Payment Service Providers: Payment gateways that are registered and compliant with PCI-DSS standards for processing your deposits and withdrawals. Your financial data is processed through fully secured channels and is not stored directly by comel33.
• Game Providers: Third-party gaming platforms integrated with comel33 may receive session information required to run the games. This sharing is kept to a minimum and is subject to strict confidentiality agreements.
• Identity Verification Services: Certified third-party KYC providers help us verify member identities quickly and securely, in line with compliance requirements.
• Legal Authorities: comel33 will disclose your data to the relevant authorities when required by law, court order, or a legitimate criminal investigation.
• Analytics Services: Anonymised usage data (with no personally identifiable information) may be shared with analytics providers for platform improvement purposes.

All third parties that receive your data are bound by strict data processing agreements and are required to protect your data to the same or higher standards as comel33.

The comel33 website and app use cookies and similar tracking technologies to enhance your experience. Cookies are small text files stored on your device when you visit the comel33 platform.

We use the following types of cookies:

• Essential Cookies: Required for core platform functions such as login session management and security. These cookies cannot be disabled as they are essential to platform operations.
• Performance Cookies: Collects information on how you use the platform, such as most visited pages and response times. This data is used solely for technical improvements.
• Functional Cookies: Allows the platform to remember your preferences such as language, region, and display settings for a more personalised experience.
• Analytics Cookies: Helps us understand aggregate usage behaviour to make better platform development decisions. This data is always anonymised.

You can manage or disable cookies through your web browser settings at any time. Please note that disabling certain cookies may affect the functionality of the comel33 platform.

Comel33 continuously invests in robust security infrastructure to protect your personal data from unauthorised access, disclosure, alteration, or destruction. The technical and organisational security measures we employ include:

• Data-in-transit encryption using TLS 1.3 and 256-bit SSL protocols
• Data-at-rest encryption using AES-256 algorithm
• Two-factor authentication (2FA) is available and encouraged for all member accounts
• Role-based access control (RBAC) for comel33 internal staff
• 24/7 security monitoring by a dedicated cybersecurity team
• Periodic penetration testing and security audits by independent parties
• Tested and documented incident response procedures
• Mandatory security awareness training for all comel33 staff

While no system can be guaranteed 100% secure, comel33 takes every reasonable step to minimise risk. Should any security breach occur that affects your data, we will notify you within 72 hours as required by applicable law.

Comel33 retains your personal data only for as long as necessary to fulfil the purposes stated in this policy or as required by applicable Malaysian law. The following are our data retention guidelines:

• Active Account Data: Retained for the duration of your membership and until account closure.
• Financial Transaction Records: Retained for seven (7) years from the transaction date in accordance with Malaysia's financial and tax legal requirements.
• KYC Documents: Retained for five (5) years after account closure for anti-money laundering (AML) compliance purposes.
• Support Communication Logs: Retained for two (2) years for reference and quality assurance purposes.
• Anonymised Analytics Data: May be retained indefinitely as it contains no personally identifiable information.

Once the designated retention period expires, your data will be securely deleted or anonymised using industry-recognised methods, ensuring it cannot be recovered.

The comel33 platform may contain links or integrations to third-party services such as game providers and payment gateways. comel33 is not responsible for the privacy practices or content of those third-party sites or services.

We encourage you to read the privacy policy of each third-party service you use through the comel33 platform. Each service provider has its own data handling policies and practices, which may differ from those of comel33.

When you click a link to a third-party site or service, you will leave the comel33 platform environment and enter an area no longer under our control. Please exercise caution and review the relevant third party's privacy policy before providing any personal information.

The comel33 platform is strictly for individuals aged 18 and above. We do not intentionally collect or process personal data from anyone under the age of 18 under any circumstances.

If we discover that personal data of a child has been collected without valid consent, we will take the following steps immediately:

• Immediately freezing the associated account
• Deleting all personal data related to the child from our systems
• Reporting relevant cases to the appropriate authorities when required
• Conducting internal reviews to identify and address weaknesses in the age verification process

Parents or guardians who suspect their child has registered for or used the comel33 platform without their knowledge should contact our support team immediately. We will handle such cases with the highest priority and full confidentiality.

Comel33 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological developments. Any material changes will be communicated to you via:

• Email notification to your registered address at least 14 days before changes take effect
• Prominent notice on the comel33 platform homepage
• Push notifications via the comel33 mobile app

The effective date of the latest comel33 Privacy Policy is always displayed at the top of this page. Continued use of the comel33 platform after the effective date of any changes constitutes your acceptance of the updated policy.

We recommend reviewing this page regularly and keeping a copy of this policy for your personal reference. If you do not agree with any changes, you may close your account and stop using the platform.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, the comel33 privacy team is here to help.