Privacy Policy — super33

1 Introduction

This Privacy Policy (hereinafter referred to as "Policy" or "Privacy Policy") is published by super33 (hereinafter referred to as "super33", "we", "us", or "the Company"), the operator of the online gaming and sports betting platform accessible at https://super33.lat and all associated interfaces and services.

Super33 is committed to protecting the privacy and personal data of all individuals who visit, register with, or interact with our Platform — including players across Malaysia (Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and other regions), as well as casual visitors who do not register an account.

This Policy explains:

• what personal data we collect from you and how we collect it;
• the purposes for which we process your personal data;
• the legal bases on which we rely to process your data;
• how we protect, store, and (where applicable) share your data;
• how long we retain your data; and
• the rights you hold in relation to your personal data and how to exercise them.

By accessing the super33 Platform, registering an account, or submitting any personal information to us, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you should cease using the Platform immediately and may request account closure by contacting our support team.

2 Definitions

In this Privacy Policy, the following terms carry the meanings set out below:

"Personal Data"

Any information that identifies or can reasonably be used to identify a living natural person, directly or indirectly. This includes name, email address, phone number, payment account details, device identifiers, and IP addresses.

"Processing"

Any operation performed on personal data, including collection, recording, organisation, storage, retrieval, use, disclosure, transmission, alignment, restriction, erasure, or destruction.

"Data Controller"

The entity that determines the purposes and means of processing personal data. For data processed through the super33 Platform, super33 is the Data Controller.

"Data Processor"

A third-party entity that processes personal data on behalf of the Data Controller under contractual instructions. Examples include payment processors, KYC verification providers, and cloud hosting services.

"KYC" (Know Your Customer)

The identity verification process mandatory for all players prior to their first withdrawal, requiring submission of a government-issued identification document and, where required, proof of payment method ownership.

"Platform"

The super33 website at https://super33.lat, including all gaming features, account management systems, promotional interfaces, and customer support channels.

3 Data Controller

Super33 acts as the Data Controller in respect of all personal data collected through the Platform. As Data Controller, we are responsible for determining why and how your personal data is processed, and for ensuring that our processing activities are lawful, fair, and transparent.

Super33 is licensed and regulated under an international gaming licence (Curaçao). Our data protection obligations derive from this licensing framework and from the internationally recognised principles we voluntarily adopt for our player base, including those in our Malaysian market.

For all data protection enquiries, requests to exercise your rights, or complaints regarding our data practices, you may contact us using the details set out in Section 15 of this Policy.

4 Data We Collect

Super33 collects personal data in several ways: information you provide directly, information generated automatically through your use of the Platform, and information received from third parties (such as payment processors and KYC verification services). The categories of data we collect are set out below.

5 How We Use Your Data

Super33 processes personal data only for specified, explicit, and legitimate purposes. The table below summarises the primary purposes for which we use your data:

Super33 does not use your personal data for automated decision-making that produces significant legal effects on you, except where such automation is integral to fraud detection systems operating under human oversight. If you believe an automated decision has adversely affected you, you have the right to request human review — see Section 11.

6 Legal Basis for Processing

Super33 relies on the following legal bases for processing personal data, as applicable to each processing activity:

• Contract performance: Processing necessary to fulfil the terms of the player agreement — including account management, payment processing, and gaming service delivery.
• Legal obligation: Processing required to comply with applicable law, including KYC/AML obligations, age verification requirements, and regulatory reporting.
• Legitimate interests: Processing for purposes of fraud prevention, platform security, responsible gambling monitoring, and analytics — where these interests do not override your fundamental privacy rights.
• Consent: Where we send marketing communications, personalised promotions, or process data for purposes not covered by the above bases, we rely on your freely given, informed consent, which you may withdraw at any time.

7 Data Sharing & Disclosure

Super33 does not sell, rent, or trade your personal data to any third party for commercial marketing purposes. We share personal data only in the following limited circumstances:

8 Data Retention

Super33 retains personal data for as long as necessary to fulfil the purposes set out in this Policy, unless a longer retention period is required by applicable law or regulation.

Indicative retention periods by data category:

• Account and registration data: Retained for the duration of the player relationship plus a minimum of 5 years following account closure, to comply with anti-money laundering record-keeping requirements.
• KYC and identity verification documents: Retained for a minimum of 5 years following the KYC verification date or account closure, whichever is later.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction.
• Gaming activity logs: Retained for a minimum of 3 years for dispute resolution and responsible gambling monitoring purposes.
• Customer support records: Retained for 3 years from the date of the most recent support interaction.
• Technical and usage data (cookies, logs): Session data deleted within 30 days; aggregated analytics data retained for up to 24 months.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised such that it can no longer be linked to an individual. Data subject to an ongoing legal hold or regulatory investigation will be retained until the matter is resolved.

9 Data Security

Super33 implements technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• Encryption in transit: All data transmitted between your device and the super33 Platform is protected by TLS (Transport Layer Security) with 256-bit encryption. You can verify this via the HTTPS padlock indicator in your browser.
• Encryption at rest: Sensitive personal data stored on our servers is encrypted using AES-256 standard encryption.
• Access controls: Personal data is accessible only to authorised super33 personnel and contractors on a strict need-to-know basis, enforced by role-based access controls.
• Two-factor authentication: All player accounts support two-factor authentication (2FA) as an additional layer of account security. We strongly encourage all players to enable 2FA.
• Regular security audits: Our infrastructure undergoes periodic independent security assessments and vulnerability testing.
• Password hashing: Account passwords are never stored in plaintext. We use industry-standard cryptographic hashing algorithms with salting.

10 Cookies & Tracking Technologies

Super33 uses cookies and similar tracking technologies to operate the Platform, personalise your experience, and analyse usage patterns. Cookies are small text files stored on your device by your web browser.

11 Your Rights

As a data subject, you hold the following rights in relation to your personal data held by super33. These rights are subject to applicable legal limitations and may be balanced against our obligations to other data subjects and our legal compliance requirements.

To exercise any of these rights, please submit a written request to our support team via live chat or at the email address provided in Section 15. We will respond to verified requests within 30 days. We may require identity verification before processing your request to protect against unauthorised access to account data.

12 International Data Transfers

Super33 operates internationally and your personal data may be transferred to and processed in countries outside of Malaysia, including the jurisdiction in which super33 is incorporated and the locations of our service providers' data centres.

Where personal data is transferred outside of Malaysia, we ensure that appropriate safeguards are in place, which may include:

• entering into standard contractual clauses or data processing agreements with recipient entities that impose equivalent data protection obligations;
• transferring data only to jurisdictions with recognised adequate data protection frameworks;
• applying binding corporate rules for intra-group transfers where applicable.

If you would like further information about the safeguards we apply to international transfers of your personal data, please contact us using the details in Section 15.

13 Minors & Age Policy

Super33 strictly prohibits access by individuals under 21 years of age. The Platform is intended exclusively for adults aged 21 and above. We do not knowingly collect, process, or retain personal data relating to individuals below the minimum age threshold.

Age verification is enforced through mandatory KYC procedures prior to the first withdrawal. Account registration requires confirmation that the applicant is aged 21 or older. Providing false age information constitutes a material breach of our Terms and Conditions and may constitute fraud under applicable law.

If super33 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to close the relevant account and delete the data, and to return any deposited funds in accordance with applicable procedures.

14 Policy Amendments

Super33 reserves the right to update, modify, or replace any part of this Privacy Policy at any time to reflect changes in our data practices, applicable law, or operational requirements. Any amendments will become effective upon publication on this page, accompanied by a revised "Last Updated" date.

Where changes to this Policy are material — that is, where they significantly affect the nature of processing or the rights available to you — we will endeavour to provide reasonable advance notice via registered email or via a prominent notification on the Platform. Non-material updates (such as clarifications or corrections) may be made without prior notice.

Your continued use of the Platform following the publication of any amended Privacy Policy constitutes your acknowledgement of, and agreement to, the updated terms. If you do not accept the amended Policy, you must discontinue use of the Platform and may request account closure in accordance with the procedure described in our Terms and Conditions.

15 Contact Us

For all privacy-related enquiries, requests to exercise your data rights, or complaints about how we have handled your personal data, please contact our support team through the channels below. All email addresses are displayed as plain text and are not clickable links.

If you are not satisfied with our response to a privacy complaint, you may have the right to escalate your complaint to a relevant supervisory authority in your jurisdiction. We encourage players to contact us first so we can attempt to resolve any concerns directly and promptly.

For information about our responsible gambling data tools and self-exclusion options, please visit our Responsible Gambling page. For the full terms governing your use of the Platform, please review our Terms & Conditions.