Privacy Policy — etiqa33

This Privacy Policy ("Policy") is issued by etiqa33 ("etiqa33", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at etiqa33.cam. This Policy describes how etiqa33 collects, processes, uses, discloses, and protects the personal data of its Members and website visitors ("you", "your", "Data Subject").

etiqa33 takes the privacy of its Members seriously. We are committed to processing personal data in a transparent, lawful, and responsible manner, consistent with applicable data protection principles. We do not sell personal data to third parties for commercial marketing purposes under any circumstances.

By registering an account with etiqa33, accessing the platform, or otherwise interacting with our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described herein. If you do not agree with this Policy, you should discontinue use of the platform and close your account.

The following defined terms are used throughout this Privacy Policy:

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, directly or indirectly — including name, identification number, location data, online identifier, or factors specific to the individual's identity.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transmission, and deletion.
• "Data Controller" means etiqa33, the entity that determines the purposes and means of processing Personal Data collected through the platform.
• "Data Processor" means a third party that processes Personal Data on behalf of etiqa33 under a contractual arrangement, such as payment processors or analytics service providers.
• "Cookies" means small text files placed on your device by a website to store information about your session, preferences, or browsing behaviour.
• "KYC Data" means identity verification documents and information submitted by Members to satisfy Know Your Customer obligations, including national identification, proof of address, and source of funds documentation.
• "Transaction Data" means records of deposits, withdrawals, bets, game outcomes, and bonus transactions processed through your etiqa33 Account.

etiqa33 collects Personal Data across several categories, depending on how you interact with the platform:

3.1 Registration & Identity Data

• Full legal name;
• Date of birth (for age verification — must be 21 or above);
• Email address;
• Mobile phone number;
• Username and encrypted password;
• Malaysian NRIC (MyKad) number or passport number (for KYC purposes).

3.2 KYC Verification Documents

• Scanned or photographed copies of government-issued identification (Malaysian IC, passport, or driving licence);
• Proof of address documentation (utility bill, bank statement, or equivalent);
• Source of funds documentation where required under anti-money laundering (AML) obligations.

3.3 Financial & Transaction Data

• Deposit and withdrawal records, including amounts (denominated in MYR), timestamps, and payment methods used (e.g., Touch 'n Go eWallet, DuitNow, CIMB, Maybank, Public Bank, FPX);
• Betting history, game session records, and bonus transaction logs;
• Partial payment instrument identifiers (e.g., masked e-wallet account references) — full payment credentials are not stored by etiqa33.

3.4 Technical & Usage Data

• IP address, device type, operating system, and browser version;
• Session timestamps, pages visited, and features accessed;
• Geolocation data at the city or region level (Kuala Lumpur, Penang, Johor Bahru, Shah Alam, Petaling Jaya, or equivalent) derived from IP address;
• Referring URL and exit page data.

3.5 Communications Data

• Records of live chat conversations, email correspondence, and support ticket submissions;
• Feedback, survey responses, and promotional opt-in records.

etiqa33 collects Personal Data through the following channels:

• Directly from you — when you register an account, submit KYC documents, make deposits or withdrawal requests, contact support, or participate in promotions;
• Automatically via the platform — through server logs, session tracking, cookies, and similar technologies when you access the website;
• From payment service providers — confirmation data from payment processors and e-wallet platforms (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX) following a deposit or withdrawal transaction;
• From identity verification partners — where third-party KYC or age verification services are used to validate documents submitted by Members.

etiqa33 processes your Personal Data for the following clearly defined purposes:

etiqa33 does not use your Personal Data for unsolicited third-party marketing, profiling for political purposes, or sale to data brokers.

etiqa33 relies on the following legal bases to process your Personal Data:

• Contractual necessity — processing required to perform the contract between etiqa33 and the Member, including account creation, payment processing, and service delivery;
• Legal obligation — processing required to comply with applicable laws, including KYC/AML obligations, age verification requirements, and regulatory reporting;
• Legitimate interests — processing carried out for fraud prevention, platform security, responsible gambling monitoring, and improvement of services, where such interests are not overridden by your fundamental rights;
• Consent — where you have provided explicit consent for specific processing activities, such as receiving promotional communications. You may withdraw consent at any time by contacting support or updating your account preferences.

etiqa33 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We may share your data with the following categories of recipients where necessary and proportionate to the purpose:

• Payment Service Providers — Malaysian e-wallet operators (Touch 'n Go eWallet, Boost, GrabPay), DuitNow, FPX, and bank partners (Maybank, CIMB, Public Bank, Hong Leong, RHB) to process financial transactions;
• Identity Verification Partners — third-party KYC service providers engaged to verify identity documents and perform age verification checks;
• Game Studio Partners — licensed game providers who may receive session and outcome data for game delivery, RTP compliance, and jackpot administration purposes;
• Technology and Infrastructure Providers — cloud hosting, content delivery, and security services that process data on etiqa33's behalf under data processing agreements;
• Regulatory Authorities and Law Enforcement — where required by applicable law, court order, or regulatory demand. etiqa33 will not disclose Member data to government authorities absent a legal obligation to do so;
• Professional Advisors — legal, audit, and compliance advisors engaged in connection with the operation of the platform, bound by professional confidentiality obligations.

All deposits and withdrawals on etiqa33 are processed in Malaysian Ringgit (MYR) through Supported Payment Methods including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, and RHB.

etiqa33 does not store full payment card numbers, e-wallet PINs, or online banking credentials. Payment processing is handled by PCI-DSS compliant payment service providers. etiqa33 retains only transaction reference identifiers and masked account/instrument identifiers for reconciliation, compliance, and customer support purposes.

Transaction records (including deposit amounts, withdrawal amounts, dates, and payment methods) are retained for a minimum of five (5) years from the date of the transaction in compliance with applicable anti-money laundering record-keeping obligations.

etiqa33 uses cookies and similar tracking technologies (including local storage and session tokens) to operate the platform, authenticate user sessions, maintain security, and understand how Members use the platform.

9.1 Types of Cookies Used

• Essential Cookies — required for the platform to function correctly, including session authentication, security tokens, and load balancing. These cannot be disabled without impairing your ability to use the platform;
• Analytics Cookies — used to collect anonymised data on page performance, feature usage, and navigation patterns to improve the platform experience;
• Preference Cookies — used to remember your language preferences, display settings, and other personalisation options between sessions.

9.2 Cookie Management

You can control non-essential cookies through your browser settings. Please note that disabling cookies may affect the functionality of certain platform features. Detailed cookie preferences can be managed via the cookie consent banner displayed upon first access to the platform.

etiqa33 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal obligations, or to resolve disputes and enforce agreements. The following retention periods apply as general guidelines:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be attributed to an identified individual.

etiqa33 implements a comprehensive set of technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• End-to-end TLS/SSL encryption for all data transmitted between your device and the etiqa33 platform;
• Encryption of sensitive data fields (passwords, partial payment identifiers) at rest using industry-standard cryptographic algorithms;
• Role-based access controls ensuring that only authorised personnel can access specific categories of Member data;
• Regular security assessments, penetration testing, and vulnerability management processes;
• Incident response procedures to detect, report, and remediate any personal data breach in a timely manner;
• Staff training on data protection obligations and secure data handling practices.

Notwithstanding the above measures, no data transmission over the internet or electronic storage system is completely secure. While etiqa33 takes reasonable steps to protect your data, we cannot guarantee absolute security against all threats.

As a Data Subject whose personal information is processed by etiqa33, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please contact our Data Protection team via the support channels listed in Section 15.

• Right of Access — You have the right to request confirmation of whether etiqa33 processes your Personal Data and to obtain a copy of that data in a structured, commonly used format;
• Right to Rectification — You may request correction of any inaccurate or incomplete Personal Data held about you;
• Right to Erasure — Subject to our legal retention obligations, you may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected;
• Right to Restrict Processing — You may request that we limit the processing of your data in specified circumstances, such as where you contest the accuracy of the data;
• Right to Data Portability — Where processing is based on consent or contractual necessity, you may request that we provide your Personal Data in a machine-readable format;
• Right to Object — You may object to processing carried out on the basis of legitimate interests, including processing for direct marketing purposes;
• Right to Withdraw Consent — Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

etiqa33 will respond to verified data rights requests within 30 calendar days of receipt. In complex or high-volume cases, this period may be extended by a further 60 days, with notification of the extension provided within the initial 30-day window.

etiqa33 is strictly an adult gaming platform. Registration and use of the platform is prohibited for individuals under the age of 21. We do not knowingly collect Personal Data from individuals under 21 years of age.

Where etiqa33 becomes aware that Personal Data has been submitted by or on behalf of an individual under 21, we will take immediate steps to delete that data, close the associated Account, and return any deposited funds where legally permissible. Age verification is conducted as part of the KYC process for all Members.

etiqa33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Where material changes are made, we will notify registered Members by email and/or by posting a prominent notice on the platform prior to the changes taking effect.

We encourage you to review this Policy periodically. The date at the top of this page indicates when this Policy was last revised. Continued use of the platform following the effective date of any amendment constitutes your acceptance of the updated Policy.

For any queries, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact etiqa33 through the following channels:

• Data Protection Enquiries (Email): [email protected] — please include "Privacy Request" in the subject line for faster routing.
• Live Chat: Available 24/7 through the platform's live chat interface. Our data protection support staff are available during business hours for privacy-specific matters.
• Headquarters: Kuala Lumpur, Malaysia.

etiqa33 is committed to addressing privacy concerns promptly and fairly. If you are not satisfied with our response to a data rights request, you retain the right to escalate the matter to the relevant data protection authority in your jurisdiction.