Privacy Policy — telur33

1Introduction

This Privacy Policy ("Policy") is published by telur33 ("the Company", "we", "us", "our"), the operator of the online gaming platform accessible at telur33.cam ("the Platform"). This Policy describes the manner in which telur33 collects, processes, stores, uses, and protects the personal data of users ("Player", "User", "you") who access, register on, or otherwise interact with the Platform.

telur33 is committed to maintaining the privacy and security of your personal data. We process personal data in accordance with applicable data protection principles — including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, and integrity and confidentiality.

By accessing the Platform or creating an Account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform.

This Policy should be read in conjunction with our Terms & Conditions, which form an integral part of the agreement between you and telur33. In the event of any inconsistency between this Policy and the Terms & Conditions on a privacy matter, this Privacy Policy shall prevail.

2Definitions

For the purposes of this Privacy Policy, the following definitions shall apply:

• "Personal Data" means any information that relates to an identified or identifiable natural person. This includes, but is not limited to, name, email address, phone number, identification document details, payment information, and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure, or destruction, whether automated or manual.
• "Data Controller" means telur33, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" means any third party that processes personal data on behalf of telur33 under a data processing agreement.
• "Consent" means freely given, specific, informed, and unambiguous agreement by the data subject to the processing of their personal data.
• "KYC Data" means identity documents and supporting materials collected during the Know Your Customer verification process.
• "Cookies" means small data files stored on your device by your browser when you access the Platform, used to enhance functionality and analyse usage patterns.
• "Sensitive Data" means a subset of personal data that warrants heightened protection, including financial information, government-issued identification details, and responsible gambling self-assessment records.

3Data We Collect

telur33 collects the following categories of personal data from Players and visitors to the Platform:

• Full legal name as shown on government-issued identification
• Date of birth (used for mandatory age verification — players must be 21 or older)
• Residential address
• Email address
• Mobile telephone number
• Malaysian Identity Card (MyKad) number or Passport number (collected during KYC)

• Deposit transaction records, amounts, and timestamps
• Withdrawal requests and processing records
• Payment method identifiers (e.g., masked Maybank account number, Touch 'n Go eWallet account reference, CIMB Clicks identifier)
• Account balance history
• Bonus and promotion claim records

• Betting history including markets, stakes, and outcomes
• Casino game session records
• Live dealer session logs
• Game preferences and activity patterns

• IP address and geolocation data derived from IP
• Device type, operating system, and browser version
• Session duration and Platform navigation data
• Cookies and similar tracking technology data (see Section 9)

• Customer support chat transcripts and email correspondence
• Feedback and survey responses
• Responsible gambling self-assessment and limit-setting preferences

4How We Collect Your Data

telur33 collects personal data through the following channels:

• Direct submission: Data you provide during Account registration, KYC verification, deposit or withdrawal requests, and customer support interactions.
• Automated technologies: Cookies, session logs, and analytics tools that record your interactions with the Platform (see Section 9).
• Payment processing partners: Transaction data received from Malaysian payment providers including Maybank, CIMB, Public Bank, Hong Leong Connect, Touch 'n Go eWallet, GrabPay, Boost, DuitNow, and FPX as part of deposit and withdrawal processing.
• Identity verification services: Data received from third-party KYC verification service providers engaged to validate the authenticity of identity documents submitted by Players.
• Fraud prevention services: Data from fraud detection and anti-money-laundering screening services used to protect Platform integrity.

5Purpose of Data Processing

telur33 processes your personal data for the following specific and legitimate purposes:

6Legal Basis for Processing

telur33 relies on one or more of the following legal bases when processing your personal data:

• Contract performance: Processing is necessary for the performance of the Agreement between you and telur33, including Account management, payment processing, and service delivery.
• Legal obligation: Processing is required to comply with applicable legal and regulatory obligations, including KYC identity verification, anti-money-laundering procedures, and responsible gambling requirements.
• Legitimate interests: Processing serves telur33's legitimate business interests, including fraud prevention, platform security, and improving the quality of services, provided such interests are not overridden by your privacy rights.
• Consent: Where required by applicable law — particularly for direct marketing communications — telur33 will seek and rely on your freely given consent. You may withdraw marketing consent at any time by contacting our support team or updating your Account notification preferences.

7Data Sharing & Third-Party Disclosure

telur33 does not sell or rent your personal data to unaffiliated third parties. We may share your personal data with the following categories of recipients, only to the extent necessary for the purposes described in this Policy:

• Payment service providers: Malaysian banks and e-wallet operators (Maybank, CIMB, Public Bank, Hong Leong, DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay) to facilitate deposit and withdrawal transactions.
• Identity verification providers: Third-party KYC and document verification services engaged to validate player identity and age during the verification process.
• Fraud & AML screening services: Specialist providers that screen transactions and player profiles against sanctions lists, fraud indicators, and money-laundering risk signals.
• Game content providers: Platform software and game providers who may receive limited technical data necessary to deliver game services (e.g., player session identifiers for live dealer connectivity).
• IT and hosting infrastructure providers: Cloud infrastructure, server hosting, and cybersecurity service providers who process data on telur33's behalf under binding data processing agreements.
• Legal and regulatory authorities: Law enforcement agencies, regulatory bodies, or courts where disclosure is required by law, court order, or to protect the legal rights of telur33 or other parties.

8Payment Data & Financial Information

Given the financial nature of the telur33 Platform, we necessarily collect and process financial transaction data in connection with deposits and withdrawals. All financial data is treated with heightened security controls.

telur33 supports the full range of mainstream Malaysian payment methods, including Maybank2u, CIMB Clicks, Public Bank online banking, Hong Leong Connect, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, and FPX. When you initiate a transaction through any of these methods, the relevant payment provider processes the transaction under their own terms and privacy policies. telur33 receives transaction confirmation data and records associated with your Account.

telur33 does not store full bank account numbers, credit card numbers, or complete payment credentials. Where partial payment identifiers are retained (e.g., masked account references), they are used solely for transaction matching and fraud prevention purposes.

9Cookies & Tracking Technologies

The telur33 Platform uses cookies and similar tracking technologies to enhance functionality, maintain your session, and analyse Platform usage. The following categories of cookies are used:

Most web browsers permit you to control cookie settings through their privacy or settings menus. Disabling strictly necessary cookies may impair your ability to log in to your Account or use certain Platform features. Analytical cookies may be declined without affecting core functionality.

10Data Retention

telur33 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply as general guidance:

• Active Account data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in accordance with anti-money-laundering record-keeping requirements.
• KYC documentation: Retained for a minimum of five (5) years from the date of verification or Account closure, whichever is later.
• Transaction records: Financial transaction data retained for a minimum of seven (7) years to support audit, dispute resolution, and regulatory compliance.
• Customer support communications: Retained for three (3) years from the date of the last communication, unless the matter relates to an ongoing dispute or legal proceeding.
• Marketing data: Retained until you withdraw consent or request deletion, subject to applicable retention minima.
• Analytical data: Anonymised or aggregated usage data may be retained indefinitely for platform improvement purposes, as it is no longer attributable to individual players.

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

11Your Data Rights

As a data subject, you hold the following rights in relation to your personal data held by telur33. Requests may be submitted via email to [email protected] or through the live chat function in your Account dashboard.

12Children's Privacy & Age Restrictions

The telur33 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, solicit, or process personal data from persons under the age of 21. Age verification is a mandatory component of the Account registration and KYC process.

If telur33 becomes aware that personal data has been collected from a person under the age of 21, the Account will be immediately suspended, all data will be reviewed, and appropriate action will be taken — including permanent Account closure and data deletion where permissible. Any winnings accrued by an underage player will be forfeited.

13Security Measures

telur33 implements comprehensive technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between player devices and Platform servers
• Encryption of sensitive data at rest, including KYC documents and financial records
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis
• Two-factor authentication (2FA) support for player Accounts
• Regular security audits, penetration testing, and vulnerability assessments
• Automated monitoring for suspicious login activity, account takeover attempts, and anomalous transaction patterns
• Incident response procedures for data breach detection, containment, and notification

While telur33 employs robust security practices, no system is entirely impenetrable. You are also responsible for maintaining the security of your Account credentials. telur33 strongly recommends enabling 2FA and using a unique, strong password for your Account. Do not share your login details with any third party.

14Policy Updates & Amendments

telur33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or operational changes. The "Last Reviewed" date at the top of this page will be updated with each revision.

Where changes are material — for example, a new category of data collection, a new third-party data sharing arrangement, or a change to the legal basis for processing — telur33 will notify registered players via email at least seven (7) days prior to the revised Policy taking effect. For minor or clarificatory amendments, the updated Policy will be published on this page with no separate notification.

Your continued use of the telur33 Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you should contact our support team to request Account closure. Funds in your Account will be returned following applicable security checks.

15Contact Us

For all privacy-related enquiries, data rights requests, or concerns regarding telur33's handling of your personal data, please contact our Privacy and Data Protection team using the details below. Please write in English to ensure your query is handled accurately and promptly.

When submitting a data rights request, please include your full name, Account username, and a description of your request. For verification purposes, we may ask you to confirm your identity before processing certain requests. This is to protect your personal data from being disclosed to or modified by unauthorised parties.