telur33 Privacy Policy

1.Who We Are

This Privacy Policy applies to the telur33 online gambling platform, accessible at telur33.one (the "Platform"). For the purposes of this Policy, "telur33", "we", "us", and "our" refer to the operator of the Platform. "You" and "your" refer to any individual who accesses, registers on, or uses the Platform.

telur33 acts as the data controller in respect of the personal data it collects directly from users of the Platform. Where telur33 engages third-party processors to carry out specific data processing activities on its behalf, those processors act as data processors under telur33's instructions and are bound by contractual data protection obligations consistent with this Policy.

2.Personal Data We Collect

telur33 collects the following categories of personal data from users of the Platform:

• Identity Data: Full legal name, date of birth, nationality, and copies of government-issued identity documents (e.g., Malaysian national identity card, passport) where required for Know Your Customer (KYC) verification.
• Contact Data: Malaysian mobile telephone number, email address, and residential address.
• Financial Data: Payment method details (eWallet identifiers, bank account numbers, or cryptocurrency wallet addresses) used for deposits and withdrawals. Full payment card numbers are not stored by telur33; card transactions, if applicable, are handled directly by PCI-DSS compliant payment processors.
• Account Data: Username, encrypted password hash, account preferences, session history, and communication preferences.
• Transaction Data: Records of all deposits, withdrawals, bets, wagers, game sessions, and bonus claims associated with your account.
• Technical Data: IP address, browser type and version, device identifiers, operating system, time zone, and referring URL.
• Usage Data: Information about how you navigate and interact with the Platform, including pages visited, games played, session duration, and click-through data.
• Communications Data: Records of your communications with telur33 customer support, including live chat transcripts and email correspondence.

3.How We Collect Your Data

telur33 collects personal data through the following channels:

• Direct Submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or updating your account profile.
• Automated Collection: Technical and usage data collected automatically when you access or use the Platform, including through cookies, web beacons, and server logs.
• Third-Party Sources: Data received from payment processors, identity verification service providers, fraud detection agencies, and, where applicable, publicly available sources such as sanctions lists and politically exposed persons (PEP) databases.

4.How We Use Your Personal Data

telur33 uses the personal data it collects for the following purposes:

• To create, verify, and maintain your player account.
• To process deposits, withdrawals, and other financial transactions associated with your account.
• To verify your identity and age in compliance with KYC and anti-money laundering (AML) obligations.
• To provide access to the Platform's gambling products, including live casino, sportsbook, slots, and lottery.
• To personalise your experience on the Platform, including by displaying relevant promotions and game recommendations.
• To detect and prevent fraud, cheating, collusion, money laundering, and other prohibited conduct.
• To communicate with you regarding your account, transactions, promotions, and Platform updates.
• To comply with applicable legal and regulatory obligations, including reporting obligations to relevant gaming authorities.
• To enforce our Terms & Conditions and respond to disputes or complaints.
• To conduct internal analytics and improve the performance, security, and user experience of the Platform.
• To provide responsible gaming support, including monitoring account activity for indicators of problem gambling and facilitating self-exclusion requests.

5.Legal Basis for Processing

telur33 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and telur33, including account registration, transaction processing, and providing access to the Platform's services.
• Legal Obligation: Processing required to comply with applicable anti-money laundering legislation, gaming regulations, tax reporting obligations, and court orders.
• Legitimate Interests: Processing carried out in pursuit of telur33's legitimate business interests, including fraud prevention, security monitoring, analytics, and Platform improvement, where those interests are not overridden by your data protection rights.
• Consent: Where telur33 relies on your consent as the legal basis for processing (for example, for non-essential marketing communications), you may withdraw that consent at any time by contacting customer support or updating your account communication preferences.

6.Data Sharing and Disclosure

telur33 does not sell or rent your personal data to third parties for their own marketing purposes. telur33 may share your personal data with the following categories of recipients in the following circumstances:

• Payment Processors: To facilitate deposits and withdrawals, including eWallet providers (Touch n Go, Boost, GrabPay), Malaysian banks (Maybank, CIMB, Public Bank), and cryptocurrency processing services.
• Identity Verification Providers: To perform KYC checks and age verification in compliance with regulatory requirements.
• Game and Platform Providers: Game studios and software providers whose products are hosted on the Platform may receive anonymised or pseudonymised game session data for legitimate operational purposes.
• Fraud Prevention Agencies: To detect and prevent fraudulent activity, money laundering, and other financial crime.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or the lawful request of a competent authority with jurisdiction over the Platform or its operations.
• Professional Advisers: Including lawyers, auditors, and accountants, subject to professional confidentiality obligations.

7.Cookies and Tracking Technologies

telur33 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. telur33 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These cannot be disabled without affecting the Platform's core functionality (e.g., session management, login state, security tokens).
• Performance Cookies: Collect anonymised data about how players use the Platform to help telur33 improve its services and identify technical issues.
• Functional Cookies: Remember your preferences (e.g., language, last-played games, display settings) to personalise your experience.
• Analytics Cookies: Used to aggregate usage statistics and understand traffic patterns across the Platform.

You may control non-essential cookies through your browser settings. Disabling all cookies may impair your ability to use certain features of the Platform. telur33 does not use cookies to track your activity across third-party websites that are not affiliated with the Platform.

8.Data Retention

telur33 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following:

• Account and transaction data is retained for a minimum of five (5) years following account closure to comply with AML record-keeping obligations.
• KYC documentation is retained for five (5) years from the date of the last transaction or account closure, whichever is later.
• Customer support communications are retained for two (2) years following resolution of the relevant query or dispute.
• Technical and usage data collected via cookies and logs is retained for up to thirteen (13) months.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with telur33's data destruction procedures.

9.International Data Transfers

The telur33 Platform is operated with support from service providers whose infrastructure may be located in jurisdictions outside Malaysia. Where personal data is transferred to a jurisdiction that does not provide an equivalent level of data protection, telur33 ensures that appropriate safeguards are in place — such as standard contractual clauses approved by a recognised data protection authority or binding corporate rules — prior to any such transfer.

10.Your Data Rights

Subject to applicable law, you have the following rights in respect of the personal data telur33 holds about you:

• Right of Access: You may request a copy of the personal data telur33 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 purposes for which it was collected, subject to telur33's legal and regulatory retention obligations.
• Right to Restrict Processing: You may request that telur33 restrict the processing of your data in certain circumstances.
• Right to Data Portability: You may request a copy of the personal data you provided to telur33 in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, contact telur33 customer support via live chat or email at [email protected]. telur33 will respond to all verified data rights requests within thirty (30) days.

11.Children's Privacy

The telur33 Platform is strictly for persons aged 21 years or older. telur33 does not knowingly collect personal data from persons under 21 years of age. If telur33 becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete that data and close the associated account. If you believe that a person under 21 has registered an account on the Platform, please contact customer support immediately.

12.Security Measures

telur33 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction, including:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform's servers.
• Encryption of sensitive data fields at rest within telur33's database infrastructure.
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Regular penetration testing and vulnerability assessments of the Platform's infrastructure.
• Incident response procedures for identifying, containing, and notifying affected parties in the event of a data breach.

While telur33 takes reasonable steps to protect your data, no security system is entirely impenetrable. You are encouraged to use a strong, unique password for your telur33 account and to enable two-factor authentication where available.

13.Third-Party Links

The telur33 Platform may contain references to third-party services (for example, payment provider interfaces). telur33 is not responsible for the privacy practices of third-party services accessed via the Platform. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of the Platform.

14.Changes to This Privacy Policy

telur33 reserves the right to update this Privacy Policy at any time. Material changes — those that affect your rights or the way telur33 uses your personal data in a significant way — will be communicated to registered players via email or an in-platform notification prior to the changes taking effect. The "Last updated" date at the top of this Policy will reflect the date of the most recent revision. Continued use of the Platform following notification of changes constitutes your acceptance of the revised 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 telur33 using the following channels:

• Live Chat: Available 24/7 within the Platform. Recommended for urgent queries.
• Email: [email protected] — responses within 2 business hours during normal operating periods.

For formal data rights requests, please state "Data Rights Request" in the subject line of your email and include your registered mobile number and a description of the right you wish to exercise. telur33 may request verification of your identity before processing the request.