kaki33 Privacy Policy

1 Introduction

kaki33 ("we", "us", "our") is committed to protecting the privacy and personal data of all individuals who use the kaki33 platform at kaki33.net and its associated mobile applications (collectively, "the Platform"). This Privacy Policy has been drafted in compliance with applicable data protection legislation, including the Personal Data Protection Act 2010 (Malaysia) ("PDPA") and the data protection requirements imposed by kaki33's international gaming authority licensing.

This policy applies to all personal data processed by kaki33 in connection with the operation of its online gaming platform, including data collected during account registration, KYC verification, payment processing, customer support interactions, and general platform use. It applies to all registered kaki33 players, prospective players who browse the platform, and any individual whose data is submitted to kaki33 in connection with these activities.

We encourage all kaki33 users — particularly those accessing the platform from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and other parts of Malaysia — to read this policy carefully to understand how their data is handled.

2 Data Controller

kaki33 acts as the data controller in respect of the personal data it collects and processes through the Platform. As data controller, kaki33 determines the purposes and means of processing personal data and bears responsibility for ensuring that such processing is carried out in compliance with applicable data protection law and the requirements of its international gaming authority licence.

For any data protection enquiries, please contact kaki33 via the details provided in Section 16 of this policy.

3 Categories of Personal Data We Collect

kaki33 collects the following categories of personal data from players and platform users:

4 How We Collect Your Personal Data

kaki33 collects personal data through the following means:

4.1 Direct Collection

Data you provide directly to kaki33 during account registration, KYC verification, payment processing, and support interactions. This includes all information entered into the kaki33 registration form, KYC upload portal, or cashier interface.

4.2 Automated Collection

Technical and usage data is collected automatically when you access and use the kaki33 platform, including through the use of cookies, web beacons, and server logs. This data is collected to maintain platform security, detect fraud, and improve the user experience. Please refer to Section 8 for further details on cookies.

4.3 Third-Party Sources

kaki33 may receive personal data from third-party sources in the following circumstances:

• Identity verification service providers used to assist with KYC processing;
• Payment processors confirming the status of transactions;
• Fraud prevention and AML screening services;
• Analytics and marketing attribution platforms.

In all cases, kaki33 ensures that third-party sources from whom data is received are themselves compliant with applicable data protection law.

5 How We Use Your Personal Data

kaki33 uses the personal data it collects for the following purposes:

• Account Management: Creating and maintaining your kaki33 account, verifying your identity and age, and managing your account settings and preferences;
• Payment Processing: Processing deposits, withdrawals, and refunds in Malaysian Ringgit (MYR) via your chosen payment method;
• KYC & Compliance: Fulfilling our obligations under international gaming authority licensing requirements, including age verification (21+), AML screening, and responsible gaming monitoring;
• Customer Support: Responding to your enquiries, resolving disputes, and providing technical assistance;
• Security & Fraud Prevention: Detecting, investigating, and preventing fraudulent activity, account takeover attempts, and prohibited conduct as defined in the kaki33 Terms & Conditions;
• Service Improvement: Analysing platform usage patterns to improve the functionality, performance, and content of the kaki33 platform;
• Responsible Gaming: Monitoring player activity to identify potential problem gambling indicators and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Marketing Communications: Sending promotional offers and platform updates to registered players who have not opted out of such communications. You may opt out at any time via your account settings or by contacting support.

6 Legal Basis for Processing

kaki33 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the kaki33 Terms & Conditions agreement with you, including account operation and payment processing;
• Legal Obligation: Processing required to comply with applicable law, including KYC, AML, and gaming licence requirements;
• Legitimate Interests: Processing carried out for kaki33's legitimate business interests, such as fraud prevention and platform security, where such interests are not overridden by your data protection rights;
• Consent: Processing based on your explicit consent, such as the sending of marketing communications. Where consent is the basis, you may withdraw it at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

kaki33 does not sell or rent your personal data to any third party. kaki33 may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• KYC & Identity Verification Providers: Third-party services engaged to assist with document verification and age confirmation;
• Payment Service Providers: Banks, e-wallet operators (including Touch 'n Go, Boost, and DuitNow), and payment gateways required to process your MYR transactions;
• Game Providers: Game content providers whose games are available on the kaki33 platform may receive the minimum data necessary to facilitate gameplay and verify results;
• Regulatory Authorities: Government regulators, gaming authorities, law enforcement agencies, and courts where kaki33 is required by law or licensing obligation to disclose data;
• Fraud & AML Services: Third-party services used to screen transactions and player activity for money laundering, fraud, and match-fixing indicators;
• IT Infrastructure Providers: Cloud hosting and technical infrastructure providers who process data on kaki33's behalf under strict data processing agreements.

8 Cookies & Tracking Technologies

kaki33 uses cookies, web beacons, and similar tracking technologies on its platform. These are used for the following purposes:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that maintain your logged-in state on the kaki33 platform. These cannot be disabled without affecting core platform functionality;
• Functional Cookies: Used to remember your preferences such as language settings and recently played games;
• Analytics Cookies: Used to collect aggregated, anonymised data about how players interact with the kaki33 platform, helping us identify areas for improvement;
• Security Cookies: Used to detect and prevent fraudulent access attempts, including bot activity and credential stuffing attacks.

You can manage non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Note that disabling cookies may affect the functionality of certain kaki33 platform features.

9 Data Retention

kaki33 retains personal data only for as long as is necessary for the purposes for which it was collected, and in any event for the minimum period required by applicable law and our gaming licence conditions. As a general guide:

• Account and KYC data is retained for a minimum of five years following account closure, as required by AML and gaming licensing regulations;
• Transaction records are retained for a minimum of seven years for financial compliance purposes;
• Support and communications data is retained for two years following the closure of the relevant enquiry;
• Marketing preference data is retained until you withdraw consent or for a maximum of three years from last interaction, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised.

10 Data Security

kaki33 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and kaki33's servers;
• Encryption of sensitive data fields (including identity document data and payment information) at rest;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of kaki33's systems;
• Multi-factor authentication requirements for internal staff accessing player data systems.

Notwithstanding these measures, no internet transmission or electronic storage system is 100% secure. If you believe your kaki33 account has been compromised, please contact kaki33 support immediately.

11 Your Data Rights

As a data subject, you have the following rights in relation to your personal data held by kaki33, subject to applicable legal limitations and retention obligations:

• Right of Access: You may request a copy of the personal data kaki33 holds about you;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention requirements;
• Right to Restrict Processing: You may request that kaki33 limit the processing of your data in certain circumstances;
• Right to Data Portability: You may request a machine-readable copy of data you have provided to kaki33 for transfer to another service provider;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal;
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including direct marketing.

To exercise any of these rights, submit a request to kaki33 support using the contact details in Section 16. kaki33 will respond within 30 days. Identity verification may be required before a request can be processed.

12 Children & Minors

13 International Data Transfers

kaki33's primary servers and data storage are located within jurisdictions covered by our international gaming authority licensing framework. In certain circumstances — for example, when engaging KYC verification providers or cloud infrastructure services — personal data may be transferred to or processed in countries outside Malaysia. kaki33 ensures that any such transfers are carried out with appropriate safeguards in place, including contractual protections equivalent to those required under the Malaysian PDPA.

14 Third-Party Platform Links

The kaki33 platform may contain references to third-party content providers (such as game developers and payment processors). These third parties operate under their own privacy policies, which are independent of this policy. kaki33 is not responsible for the privacy practices of any third-party platform or service. We recommend reviewing the privacy policies of any third-party services you interact with in connection with your kaki33 account.

15 Changes to This Privacy Policy

kaki33 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or platform operations. Material changes will be communicated to registered players via their registered email address at least 14 days before the change takes effect. The updated policy will be published on this page with a revised "Last Updated" date. Continued use of the kaki33 platform after the effective date of any update constitutes acceptance of the revised policy.

16 Contact & Data Requests

For all privacy-related enquiries, data subject rights requests, or concerns regarding how kaki33 handles your personal data, please contact:

• Email: [email protected] (plain text — not a clickable link)
• Subject line: "Privacy Request – [Your Registered Username]"
• Live Chat: Available 24/7 via the in-platform support widget

kaki33 aims to acknowledge all privacy-related requests within 5 business days and to provide a substantive response within 30 calendar days. Where a request is complex or involves multiple data points, this period may be extended by up to 60 days with prior notification to you.