town33 Privacy Policy

This Privacy Policy ("Policy") applies to all personal data collected, processed, and stored by town33 ("the Company," "we," "us," or "our") in connection with the operation of the town33 online gaming platform accessible at town33.com. It applies to all registered Members, prospective Members, and visitors to the platform.

This Policy should be read in conjunction with the town33 Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and town33. In the event of any inconsistency between this Policy and the Terms & Conditions on matters specifically relating to data privacy, this Policy shall prevail.

town33 is committed to handling personal data responsibly, transparently, and in accordance with applicable data protection principles. We collect only what is necessary, retain it only for as long as required, and implement reasonable technical and organisational measures to protect it from unauthorised access, loss, or misuse.

town33 collects the following categories of personal data, depending on the nature of your interaction with the platform:

town33 does not collect sensitive personal data categories (such as racial or ethnic origin, political opinions, religious beliefs, biometric data for identification purposes, or health data) except where specifically required for responsible gaming self-exclusion processes, in which case such data is collected only with your explicit consent and is handled with heightened security measures.

town33 collects personal data through the following means:

• Direct submission: Information you provide when registering your account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the platform, including device identifiers, IP addresses, browser configuration, and session activity logs, via cookies and similar tracking technologies;
• Third-party sources: Identity and payment verification data from KYC service providers, payment processors (including Touch n Go, Boost, and FPX banking partners such as Maybank, CIMB, and Public Bank), and fraud prevention services, used to supplement and verify the information you have provided directly;
• Publicly available sources: In limited circumstances, publicly available information may be consulted for fraud screening or sanctions list checking purposes as required by applicable AML regulations.

town33 uses your personal data for the following purposes:

• Account management: Creating, verifying, maintaining, and securing your town33 account, including processing password reset requests and managing login sessions;
• Platform operation: Processing bets, recording game outcomes, crediting winnings to your MYR wallet, and operating all gaming products available on town33;
• Payment processing: Executing deposit and withdrawal transactions through your selected payment method and maintaining accurate transaction records;
• KYC and AML compliance: Verifying your identity, age (21+ requirement), and the source of funds in compliance with applicable anti-money laundering and counter-terrorism financing obligations;
• Responsible gaming: Monitoring usage patterns to identify potential problem gambling indicators and facilitating the operation of responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods;
• Security and fraud prevention: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, multi-accounting, and platform abuse;
• Customer support: Responding to support requests, managing disputes, and maintaining correspondence records;
• Platform improvement: Analysing aggregated usage data to improve platform performance, game catalogue selection, and user experience;
• Marketing communications: Sending promotional offers, new game notifications, and other marketing materials — only where you have provided consent or where a legitimate interest applies and an opt-out mechanism is provided.

town33 processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and town33, including account management, platform operation, and payment processing;
• Legal obligation: Processing required to comply with applicable laws, including AML/CFT regulations, age verification requirements, and data retention obligations imposed by gaming and financial regulators;
• Legitimate interests: Processing for fraud prevention, security monitoring, platform integrity, and responsible gaming oversight, where town33's legitimate interests are not overridden by your rights;
• Consent: Processing for marketing communications and any sensitive data processing related to responsible gaming tools, where your explicit consent has been obtained and may be withdrawn at any time.

town33 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Your personal data may be shared in the following circumstances only:

• Payment processors and e-wallet providers: Touch n Go, Boost, FPX partner banks (Maybank, CIMB, Public Bank), Visa, and Mastercard — shared to the extent necessary to process your transactions;
• KYC and identity verification providers: Third-party services engaged to assist in identity verification, age verification, and document authentication as part of our compliance obligations;
• Game content providers: Certified game studios supplying content to town33 receive aggregated, anonymised session data for RTP auditing and game integrity purposes; individual player identity data is not shared with game studios;
• Fraud prevention and security services: Specialist providers engaged to monitor for fraudulent activity, money laundering indicators, and platform abuse;
• Legal and regulatory disclosure: Competent regulatory authorities, law enforcement agencies, or courts, where disclosure is required by applicable law, regulatory mandate, or valid legal process;
• Group entities: Related corporate entities within the town33 group, where necessary for operational, compliance, or audit purposes, subject to equivalent data protection obligations.

All third-party service providers engaged by town33 are subject to contractual data processing obligations that require them to handle your data securely, use it only for the specified purpose, and comply with applicable data protection requirements.

town33 uses cookies and similar tracking technologies (such as web beacons and local storage objects) to operate the platform, maintain session security, and gather aggregate usage analytics. The following cookie categories are used:

• Strictly necessary cookies: Required for the platform to function, including login session management, security tokens, and load balancing. These cannot be disabled without impairing platform functionality;
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming configurations;
• Analytics cookies: Collect aggregated, anonymised data on how Members navigate and use the platform, used to improve user experience and platform performance. No individual user is identified in analytics reporting;
• Security cookies: Support fraud detection and authentication processes by tracking unusual session behaviour patterns.

town33 does not use third-party advertising or retargeting cookies. You may manage cookie preferences through your browser settings, though disabling strictly necessary cookies will affect your ability to log in and use the platform.

town33 retains personal data for as long as is necessary for the purposes for which it was collected, subject to any longer retention periods required by applicable legal, regulatory, or contractual obligations. As a general guide:

• Account and identity data: Retained for the duration of your account's active status, plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• Transaction and financial records: Retained for a minimum of seven (7) years from the date of the transaction to satisfy financial record-keeping obligations;
• KYC documents: Retained for the duration of the account plus five (5) years, or longer if required by regulatory direction;
• Support correspondence: Retained for three (3) years from the date of closure of the relevant support case;
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period to demonstrate that consent was validly obtained.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of your individual identity.

town33 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the town33 platform;
• Bcrypt hashing for all stored passwords — passwords are never stored in retrievable plain text;
• Role-based access controls limiting internal access to personal data to staff members with a defined operational need;
• Intrusion detection systems and real-time security monitoring of platform infrastructure;
• Regular security assessments and vulnerability testing by specialist third-party security professionals;
• Incident response procedures to contain, investigate, and notify affected parties in the event of a confirmed personal data breach.

While town33 takes all reasonable precautions, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for promptly notifying town33 if you suspect unauthorised access to your account.

Subject to applicable law, you have the following rights in relation to your personal data held by town33:

• Right of access: Request a copy of the personal data town33 holds about you, together with information about how it is used;
• Right of rectification: Request correction of inaccurate or incomplete personal data, including updating your registered contact details or address;
• Right of erasure: Request deletion of your personal data, subject to town33's legal obligation to retain certain records for the periods specified in Section 8;
• Right to restrict processing: Request that town33 limit the processing of your data in certain circumstances, such as while a rectification request is under review;
• Right to object: Object to processing of your data for direct marketing purposes or processing based on legitimate interests where you believe your rights override those interests;
• Right to withdraw consent: Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please submit a written request to [email protected] with sufficient information to identify your account. town33 will acknowledge your request within five (5) business days and respond substantively within thirty (30) days, or notify you if an extension is required. We may require identity verification before processing any data access or deletion request.

The town33 platform is strictly intended for adults aged 21 years and above. town33 does not knowingly collect personal data from individuals under the age of 21. If town33 becomes aware that personal data has been collected from a person under 21, all associated data will be deleted and the account closed immediately.

If you believe that a minor has registered an account on town33, please contact [email protected] immediately so that the matter can be investigated and resolved without delay.

town33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or our data processing practices. Updated versions will be published on this page with a revised "Last updated" date. For material changes, town33 will provide advance notice via email to your registered address or through a notice on the platform.

Your continued use of the town33 platform following publication of an updated Policy constitutes acceptance of the revised terms. We encourage you to review this Policy periodically.

For any questions, concerns, or formal requests relating to this Privacy Policy or town33's data processing practices, please contact us: