comel33 Privacy Policy

1.Introduction

comel33 ("the Platform," "we," "us," "our") is committed to protecting the privacy and personal data of all users of the comel33 online casino, sportsbook, and gaming platform. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in connection with your use of comel33.

This Policy applies to all individuals who access or use the comel33 website, mobile platform, or any associated services — including registered members, prospective members, and casual visitors. By accessing comel33 or registering an account, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

This Privacy Policy should be read alongside the comel33 Terms & Conditions, which govern your overall use of the platform.

2.Data Controller

For the purposes of applicable data protection legislation, comel33 acts as the data controller in respect of personal data collected through and in connection with the comel33 platform. As data controller, comel33 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is lawful, fair, and transparent.

All queries, requests, or complaints relating to the handling of your personal data should be directed to the comel33 Data Protection contact detailed in Section 15 of this Policy.

3.Information We Collect

comel33 collects personal information through several channels in the ordinary course of operating a licensed online gaming platform. The categories of information we collect include:

3.1 Registration & Account Information

• Full legal name as it appears on your government-issued identity document;
• Date of birth (to verify compliance with the 21+ age requirement);
• Residential address, including postcode and state within Malaysia;
• Email address and mobile phone number registered to your account;
• Username and encrypted account password;
• Identity verification documents (e.g., MyKad, passport) uploaded during the KYC process.

3.2 Financial & Transaction Information

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment methods used;
• Payment method identifiers — such as e-wallet account references for Touch n Go eWallet or Boost, or bank account details for Maybank, CIMB, Public Bank, and RHB transfers;
• USDT wallet addresses where cryptocurrency transactions are used;
• Wallet balance history and bonus credit records.

3.3 Usage & Technical Data

• IP address and geolocation data at the time of login and game play;
• Device type, operating system, browser type, and version;
• Game session records, including games played, bet amounts, outcomes, and session duration;
• Betting history across the comel33 sportsbook, including Malaysia Super League, EPL, and other markets;
• Pages visited on the comel33 website, navigation patterns, and click-stream data;
• Customer support interaction records, including live chat transcripts and email correspondence.

3.4 Responsible Gaming Data

• Self-exclusion requests and their duration;
• Deposit limit, loss limit, and session time limit settings configured by the member;
• Responsible gaming assessments completed voluntarily or as required under platform policy.

4.How We Use Your Data

comel33 processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your comel33 account, including processing login requests and verifying your identity;
• Age verification: To verify that all comel33 members are aged 21 or above in compliance with our licensing obligations and responsible gaming policy;
• Payment processing: To process deposits and withdrawals via Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank, RHB, and USDT, and to maintain accurate financial records;
• Platform operation: To deliver the games, sportsbook markets, live casino services, and other features that constitute the comel33 platform;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal or prohibited conduct;
• Regulatory compliance: To fulfil our obligations under international gaming licensing requirements, anti-money laundering (AML) legislation, and applicable data protection law;
• Customer support: To respond to your queries, complaints, and requests via live chat and email;
• Responsible gaming: To monitor gaming patterns, enforce self-exclusion and limit settings, and identify members who may be at risk of problem gambling;
• Marketing communications: To send promotional offers, bonus notifications, and platform updates to members who have opted in to such communications. Members may opt out at any time;
• Platform improvement: To analyse usage patterns and technical performance data to improve the comel33 platform and user experience.

5.Legal Basis for Processing

comel33 processes personal data under the following legal bases, as applicable under relevant data protection legislation:

• Contract performance: Processing necessary to provide the comel33 service you have registered for, including account management, payment processing, and game delivery;
• Legal obligation: Processing required for comel33 to comply with licensing conditions, AML legislation, age verification requirements, and other applicable legal obligations;
• Legitimate interests: Processing for fraud detection, platform security, responsible gaming monitoring, and analytics, where such interests are not overridden by your data protection rights;
• Consent: Marketing communications and optional personalisation features, which you may withdraw at any time without affecting the provision of core platform services.

6.Sharing Your Information

comel33 does not sell your personal data to third parties. We may share your information with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment service providers: Touch n Go eWallet, Boost, and banking partners (Maybank, CIMB, Public Bank, RHB) for the purpose of processing financial transactions;
• Identity verification providers: Third-party KYC and age verification services used to validate documents submitted during account registration;
• Game software providers: Game studios and platform providers (e.g., Pragmatic Play, PG Soft, Evolution Gaming) may receive session data necessary to deliver their games within the comel33 platform;
• Regulatory and law enforcement authorities: Where required by law, court order, or our licensing authority, comel33 may disclose personal data to relevant authorities, including in connection with AML reporting obligations;
• Professional advisers: Legal, accounting, and audit firms engaged to support comel33's operations, under binding confidentiality obligations.

7.Cookies & Tracking Technologies

The comel33 website uses cookies and similar tracking technologies to deliver and improve the platform experience. The categories of cookies used include:

• Essential cookies: Required for the platform to function, including session management, login authentication, and security features. These cannot be disabled without affecting core platform functionality;
• Analytics cookies: Used to collect aggregated, anonymised data about how members navigate the comel33 platform, enabling us to identify performance issues and improve the user experience;
• Preference cookies: Store your language preference, layout settings, and other customisation options;
• Marketing cookies: Used where you have consented to receive personalised promotional content based on your activity on the comel33 platform.

You may manage your cookie preferences through your browser settings. Note that disabling essential cookies will impair your ability to log in to and use the comel33 platform.

8.Data Retention

comel33 retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Account and registration data: retained for the duration of your active account plus a minimum of 5 years following account closure, in accordance with AML and gaming licensing requirements;
• Financial transaction records: retained for a minimum of 7 years following the date of the transaction, as required by applicable financial record-keeping obligations;
• Marketing communication consent records: retained until you withdraw consent, plus a reasonable administrative period thereafter;
• Customer support records: retained for 3 years following resolution of the relevant query or complaint.

9.Data Security

comel33 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the comel33 platform;
• Encrypted storage of account passwords — passwords are never stored in plain text;
• Two-factor authentication (2FA) via SMS OTP for all login events on unrecognised devices;
• Regular independent security audits and penetration testing of the comel33 platform infrastructure;
• Strict access controls limiting internal access to personal data on a need-to-know basis.

While comel33 takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. Members are encouraged to use strong, unique passwords for their comel33 account and to contact support immediately if they suspect unauthorised access.

10.Your Rights

Subject to applicable data protection legislation, you have the following rights in respect of your personal data held by comel33:

• Right of access: You may request a copy of the personal data comel33 holds about you;
• Right to rectification: You may request that inaccurate or incomplete personal data be corrected;
• Right to erasure: You may request deletion of your personal data, subject to comel33's legal retention obligations;
• Right to restrict processing: You may request that comel33 limit the processing of your data in certain circumstances;
• Right to object: You may object to processing based on legitimate interests, including direct marketing;
• Right to data portability: You may request that data you have provided to comel33 be transferred to you or to another controller in a structured, machine-readable format.

To exercise any of these rights, contact the comel33 Data Protection team using the details in Section 15. comel33 will respond to valid requests within 30 days. Note that certain rights may be limited where processing is required for compliance with legal obligations.

11.Children's Privacy

The comel33 platform is strictly intended for persons aged 21 and above. comel33 does not knowingly collect personal data from individuals under 21 years of age. If comel33 becomes aware that personal data has been collected from an underage individual, the relevant account will be immediately suspended, the data will be deleted, and any deposits will be handled in accordance with applicable law and licensing requirements. Parents or guardians who believe their child has registered a comel33 account should contact support immediately.

12.International Data Transfers

In delivering the comel33 platform, your personal data may be processed by service providers located outside of Malaysia — including game software providers, payment processors, and cloud infrastructure partners. Where such transfers occur, comel33 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that provided under applicable Malaysian data protection requirements and our international gaming licensing obligations.

13.Third-Party Links

The comel33 platform does not contain links to third-party external websites. All navigation on comel33 remains within the comel33 domain. This Privacy Policy applies exclusively to data processed by comel33 in connection with the comel33 platform and does not cover the privacy practices of any third party.

14.Changes to This Policy

comel33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. The "Last Updated" date at the top of this Policy will indicate when the most recent revision was made. Where changes are material, comel33 will make reasonable efforts to notify registered members by email or via an in-platform notification. Continued use of the comel33 platform following notification of a revised Privacy Policy constitutes acceptance of the updated Policy.

15.Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or wish to raise a data protection concern, please contact the comel33 Data Protection team: