Twin33 Privacy Policy – Member Personal Data Protection

Twin33 only collects information that is genuinely necessary for platform operations, regulatory compliance, and delivering the best service to members. We do not collect excessive or irrelevant data. The types of information we collect can be divided into two main categories:

Information You Provide Directly

• Full name as it appears on your official identification document.
• National identification number (MyKad) or passport for KYC identity verification purposes.
• Date of birth for age verification purposes.
• Active email address and mobile phone number.
• Malaysian bank account details used for deposits and withdrawals.
• Current residential address.
• Supporting documents uploaded during the KYC process.

Information Collected Automatically

• Your device's IP address and geolocation information.
• Your device's web browser type and operating system.
• Game session data including date, time, game type, and total wagering amount.
• Deposit and withdrawal transaction history.
• Cookie data and website tracking technologies.
• Activity logs for account login and logout events.

Twin33 collects personal information through a variety of lawful and transparent channels. You are always informed about the type of data being collected and its purpose before or at the time of collection.

• Registration Form: Basic information collected when you complete new account registration on the twin33 platform.
• KYC Process: Identity documents and bank statements are collected during identity verification to enable withdrawal processing.
• Platform Usage: Gaming activity data, transactions, and interactions with the platform are collected automatically when you use twin33 services.
• Customer Support: Information you share during live chat sessions, email, or any communication with our support team.
• Cookies and Similar Technologies: Browsing data is collected through authorised first-party and third-party cookies when you browse the twin33 platform.

Every piece of information we collect has a clear and legitimate purpose. twin33 uses member personal data solely for the following purposes:

Twin33 does not sell, rent, or disclose member personal data to third parties for marketing purposes. However, in the course of platform operations, there are certain situations where sharing data with trusted parties is necessary:

Parties That May Receive Your Data

• Payment Providers: Payment gateways and banks that process your deposit and withdrawal transactions receive only the minimum necessary transaction information.
• KYC Providers: Third-party identity verification services integrated with the twin33 platform to process member verification documents.
• Game Service Providers: Game software providers that supply content within the twin33 platform receive session data necessary for game operations.
• Relevant Authorities: Law enforcement agencies, regulatory bodies, or courts when required under applicable Malaysian law.
• Audit and Compliance: Independent auditors and certification bodies conducting compliance reviews on the twin33 platform.

The personal data security of our members is twin33's top priority. We continuously invest in the latest security infrastructure to ensure your data is always protected against unauthorized access, modification, disclosure, or destruction.

Technical Measures

• Data encryption in transit using TLS 1.3 and 256-bit SSL protocols.
• Encryption of stored data using AES-256 for all sensitive information.
• Intrusion detection and prevention system (IDS/IPS) operating 24/7.
• Regular penetration testing conducted by independent security experts.
• Two-factor authentication (2FA) is available for all member accounts.
• Real-time activity log monitoring to detect suspicious activity.

Organizational Measures

• Access to members' personal data is restricted to staff who require it to perform their duties only (least privilege principle).
• All staff handling personal data are required to undergo regular data security training.
• Non-disclosure agreements (NDAs) signed by all twin33 staff and contractors.
• A comprehensive incident response procedure is in place and ready to be activated in the event of any data breach.

Twin33 retains member personal data only for as long as necessary to fulfil the stated collection purposes, or as required by applicable Malaysian law.

• Active account data: Retained for the duration your account is active plus 7 years after account closure, in line with Malaysian financial compliance requirements.
• Transaction records: Retained for a minimum of 7 years as required by applicable anti-money laundering legislation (AMLA).
• KYC Documents: Retained for 5 years after the business relationship ends.
• Support communication logs: Retained for 2 years for reference and service improvement purposes.
• Cookie and analytics data: Retained according to their respective policies — generally between 30 days and 2 years depending on cookie type.

Upon expiry of the stipulated retention period, your personal data will be securely deleted or anonymised using industry-standard deletion procedures.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have certain rights regarding your personal data held by twin33. The following is a summary of those rights and how to exercise them:

Twin33 uses cookies and similar tracking technologies to enhance the user experience, analyse platform usage, and deliver relevant content to you. The following are the types of cookies we use:

• Essential Cookies (Required): Required for core platform functions such as login session verification, account security, and language preferences. These cookies cannot be disabled as they are essential to platform operation.
• Performance & Analytics Cookies: Helps us understand how members interact with the platform so we can make continuous improvements. Data collected is anonymized.
• Functional Cookies: Stores your preferences such as display settings, preferred language, and interface customizations to deliver a more personalized experience.
• Marketing Cookies: Used to deliver relevant offers and promotions to you. These cookies are only activated with your consent.

The twin33 platform may contain links to third-party websites such as game providers or payment providers. twin33's Privacy Policy applies solely to the twin33 platform and does not cover the privacy practices of those third-party sites.

Twin33 is not responsible for the content, privacy policies, or practices of any third-party websites. We encourage you to read the privacy policy of every website you visit, especially before providing any personal information.

Twin33 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our data handling practices, legal requirements, or platform improvements. All changes take effect as soon as the latest version is published on this page.

When significant changes occur to how we process your personal data, twin33 will notify you via:

• Clear notices on the twin33 platform's home page.
• Email to your registered email address (for material changes).
• Push notifications via the twin33 mobile app (where applicable).

The "Last Updated" date at the top of this page indicates when this Privacy Policy was last reviewed. We encourage you to check this page periodically to stay informed about how we protect your privacy.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, do not hesitate to contact the twin33 privacy team. We are committed to providing accurate, transparent, and satisfactory responses to every privacy-related enquiry.