Privacy Policy

1. Introduction

comel33 ("we", "us", "our") operates the online gaming and sports betting platform accessible at comel33.cam. In the course of providing our Services to players based in Malaysia and internationally, we collect and process certain personal information about you. We take our privacy obligations seriously and are committed to handling your data with care, transparency and respect.

This Privacy Policy ("Policy") describes the types of personal data we collect, the purposes for which we process it, the circumstances under which it may be shared with third parties, the measures we take to keep it secure, and the rights available to you as a data subject. This Policy applies to all personal data collected through the comel33 website, account registration process, payment transactions, customer support interactions, and any related digital touchpoints.

By creating a comel33 account or continuing to use the Platform following any update to this Policy, you acknowledge that you have read and understood its contents. If you do not agree to the practices described herein, you should not use the Platform and may request account closure as described in our Terms & Conditions.

2. Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including name, email address, date of birth, payment details, IP address and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" refers to comel33 as the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" refers to any third-party service provider that processes Personal Data on behalf of comel33 under a data processing agreement.
• "KYC" means Know Your Customer procedures, including age verification and identity checks required to activate full account functionality.
• "Platform" means the comel33 website, mobile-responsive interface and all related Services accessible at comel33.cam.
• "Player" / "you" means any individual who accesses, browses or holds a registered account on the comel33 Platform.
• "Sensitive Data" means a subset of Personal Data attracting heightened protection, such as government-issued identity document numbers and financial account details.

3. Data We Collect

comel33 collects the following categories of personal data across the stated collection points:

comel33 collects only the data that is reasonably necessary for the specified purposes set out in this Policy. We do not purchase Personal Data from third-party marketing lists or data brokers.

4. Legal Basis for Processing

comel33 processes your Personal Data on one or more of the following legal bases, as applicable to each processing activity:

• Contractual necessity: Processing required to create and maintain your account, process transactions, and deliver the Services you have requested.
• Legal obligation: Processing required to comply with anti-money laundering ("AML") obligations, age verification requirements, fraud prevention obligations, and other mandatory legal or licensing requirements under our international gaming licence.
• Legitimate interests: Processing undertaken in the legitimate interests of comel33 or a third party, including platform security, fraud detection, responsible gambling monitoring and service improvement, where such interests are not overridden by your rights.
• Consent: Where we rely on your consent as the legal basis for processing (for example, the use of non-essential cookies or marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. How We Use Your Data

comel33 uses the personal data it collects for the following purposes:

1. Account creation and management: Registering your account, verifying your identity and age (21+ requirement), maintaining your profile and enabling login access.
2. Transaction processing: Facilitating deposits via Malaysian payment channels (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and others) and processing withdrawal requests to your nominated account or e-wallet.
3. Service delivery: Making casino games, live dealer tables, sports betting markets and platform features available to you in accordance with your account tier and applicable terms.
4. Fraud prevention and security: Monitoring for suspicious activity, detecting unauthorised access, identifying collusion or abuse of promotional systems, and protecting the integrity of the Platform.
5. Legal and regulatory compliance: Meeting AML reporting obligations, responding to lawful authority requests, retaining records as required under our international licence and applicable law.
6. Responsible gambling: Monitoring usage patterns for indicators of problem gambling, enforcing player-set limits and self-exclusion instructions, and contacting players where welfare concerns arise.
7. Customer support: Responding to account queries, dispute resolution, and following up on feedback submitted through support channels.
8. Service improvement: Analysing aggregated usage data to understand player preferences, identify technical issues and develop new features.
9. Communications: Sending account-related notifications (transaction confirmations, security alerts, policy updates). Where you have provided explicit consent, we may also send promotional communications. You may opt out of marketing communications at any time via your account settings.

6. Sharing Your Data

comel33 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. We may share your data with the following categories of recipients only to the extent necessary:

• Payment processors and financial institutions: To facilitate deposit and withdrawal transactions via FPX, DuitNow, e-wallet providers and bank transfer channels. These processors operate under their own privacy policies and applicable financial regulations.
• KYC and identity verification providers: Third-party services engaged to perform age and identity verification, anti-fraud screening and AML checks. These providers are bound by data processing agreements with comel33.
• Cloud infrastructure and hosting providers: Providers supplying the servers, databases and content delivery infrastructure that power the Platform. All such providers are subject to appropriate contractual security requirements.
• Customer support tools: Platforms enabling live chat, email management and ticketing for the comel33 support team.
• Regulatory and law enforcement authorities: Where comel33 is legally obligated to disclose information under applicable law, a court order, or a lawful request from a competent authority, we will comply. We will notify you of any such disclosure to the extent permitted by law.
• Business successors: In the event of a merger, acquisition, restructuring or sale of comel33 assets, Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party processors engaged by comel33 are required to handle Personal Data in accordance with applicable data protection standards and in a manner consistent with this Policy.

7. Cookies & Tracking Technologies

comel33 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage patterns and support fraud prevention. The following categories of cookies are in use:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security tokens. These cannot be disabled without affecting core functionality.
• Functional cookies: Used to remember your preferences such as language settings and previously used payment methods.
• Analytical cookies: Used to measure traffic, identify popular game categories and support performance monitoring through aggregated, anonymised data. Where consent is required, it will be sought before deployment.
• Security and fraud-prevention cookies: Support the detection of bot activity, multi-account creation and other platform integrity risks.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the Platform, but may affect certain features and personalisation functions. Where applicable law requires your prior consent to set non-essential cookies, we will obtain that consent before doing so.

8. Data Retention

comel33 retains your Personal Data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting and reporting obligations. Our standard retention periods are as follows:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, consistent with standard AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for up to three (3) years from the date of the interaction, unless the matter involves an unresolved dispute or regulatory inquiry.
• Technical and usage logs: Retained for up to twelve (12) months for security and analytics purposes, after which they are deleted or anonymised.
• Self-exclusion data: Retained indefinitely to prevent re-registration by excluded players, in accordance with our responsible gambling commitments.
• Marketing preferences: Retained until you withdraw consent or close your account.

Upon expiry of the applicable retention period, Personal Data is securely deleted or permanently anonymised so that it can no longer be associated with an identifiable individual.

9. Data Security

comel33 implements a range of technical and organisational security measures to protect your Personal Data from unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include, but are not limited to:

• Transport Layer Security (TLS / 256-bit SSL encryption) for all data transmitted between your device and the Platform.
• Encryption of sensitive data fields at rest within our database infrastructure.
• Role-based access controls limiting staff access to Personal Data strictly to those with a verified operational need.
• Regular internal security reviews, penetration testing and vulnerability assessments.
• Two-factor authentication options for player accounts and mandatory 2FA for staff with access to production systems.
• Incident response procedures designed to identify, contain and notify affected parties of any data breach within applicable timeframes.

No transmission of data over the internet or storage system can be guaranteed to be completely secure. While we apply commercially reasonable precautions, comel33 cannot guarantee the absolute security of any data transmitted to or stored on the Platform. Players are encouraged to use strong, unique passwords and to activate two-factor authentication where available.

10. Your Rights

Subject to applicable law and the conditions governing our international operating licence, you have the following rights with respect to the Personal Data held about you by comel33:

• Right of Access: You may request a copy of the Personal Data we hold about you and information about how it is processed.
• Right to Rectification: You may request that inaccurate or incomplete Personal Data be corrected without undue delay.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal obligations (such as mandatory AML retention periods).
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, for example where you contest its accuracy pending verification.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you may request a copy of your data in a structured, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests. We will consider your objection and cease processing unless compelling legitimate grounds override your rights.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact comel33 support using the details in Section 15. We will respond to verified requests within thirty (30) calendar days. In cases of complexity or volume, this period may be extended by a further two months, with advance notice to you.

11. Minors and Age Restrictions

The comel33 Platform is strictly restricted to individuals aged 21 years and above. We do not knowingly collect, store or process Personal Data from persons below the age of 21. Age verification is a mandatory step in the account registration and KYC process.

If comel33 becomes aware that Personal Data has been collected from a person below the minimum age, the relevant account will be closed, any funds held will be returned via the original deposit method following verification, and all associated Personal Data will be deleted or anonymised in accordance with our data retention procedures.

If you believe that a person below the age of 21 has created an account on the Platform, please contact us immediately using the details in Section 15.

12. International Data Transfers

comel33 is an internationally operated platform. Your Personal Data may be transferred to, stored on, and processed by systems located in countries outside Malaysia. Such countries may not have data protection laws equivalent to those that apply in your home jurisdiction.

Where Personal Data is transferred internationally, comel33 takes steps to ensure that appropriate safeguards are in place, which may include standard contractual clauses, data processing agreements incorporating recognised international transfer mechanisms, or reliance on adequacy decisions issued by relevant data protection authorities.

By using the Platform, you acknowledge that your data may be transferred and processed internationally as described in this Policy.

13. Third-Party Links

The comel33 Platform may contain references or links to third-party sites or services, such as payment provider portals accessed during deposit or withdrawal flows. comel33 is not responsible for the privacy practices or content of those third-party platforms. We encourage you to review the privacy policies of any external service you access in connection with your use of comel33.

14. Amendments to This Policy

comel33 reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements or platform functionality. The revised Policy will be published at comel33.cam/privacy-policy with an updated effective date.

Where changes are material — for example, a new category of data collection or a new sharing arrangement — we will provide advance notice via your registered email address or a prominent notice on the Platform, allowing a reasonable period for review before the changes take effect. Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

It is your responsibility to check this page periodically. The date shown at the top of this Policy confirms when it was last updated.

15. Contact Us

If you have questions, concerns or requests relating to this Privacy Policy or the personal data held about you, please contact comel33 using the details below. We aim to acknowledge all privacy-related requests within five (5) business days and to provide a substantive response within thirty (30) calendar days.

Data enquiries email (plain text only — not a clickable link): [email protected]

You may also find useful information in our FAQ. Details of responsible gambling tools and support resources are available on our Responsible Gambling page. The contractual framework governing your use of the Platform is set out in the Terms & Conditions.