Privacy Policy

1. Introduction

comel33 ("we", "us", "our", "the Platform") operates the online casino and sportsbook accessible at comel33.win. In the course of providing gaming, betting, and related services to players across Malaysia — including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and beyond — comel33 collects and processes personal data about its registered users and website visitors.

This Privacy Policy sets out in clear terms what personal data comel33 collects, the purposes for which it is processed, the parties with whom it may be shared, the period for which it is retained, and the rights available to individuals in respect of their personal data.

By creating an account with comel33 or otherwise accessing the platform, you acknowledge that you have read and understood this Privacy Policy. This policy forms part of the comel33 Terms & Conditions and should be read alongside them.

2. Data We Collect

comel33 collects personal data in several ways: directly from you at registration and during use of the platform, automatically through your use of the site, and from third parties in connection with verification and payment processing. The categories of personal data comel33 may collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on your identity document
• Date of birth (for age verification purposes — 21+ requirement)
• Malaysian MyKad number, passport number, or other national identity document number
• Residential address, including postcode and state
• Email address and Malaysian mobile phone number
• Username and encrypted password credentials

2.2 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment channels used (FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank)
• Account wallet balance history
• Bonus credit allocations and wagering activity records

2.3 Gaming & Behavioural Data

• Game session logs, including games played, wager amounts, and session durations
• Sportsbook betting history, including markets selected, odds accepted, and outcomes
• Platform usage patterns and feature interaction data

2.4 Technical & Device Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system, and browser version
• Cookie identifiers and session tokens
• Referral URL and navigation paths within the comel33 platform

2.5 Communications Data

• Records of communications between you and the comel33 support team, including live chat transcripts and email correspondence
• Complaint and dispute records

3. How We Use Your Data

comel33 processes personal data for the following purposes:

• Account administration: To create, maintain, and manage your comel33 player account, including processing login requests, updating account details, and managing session security.
• Identity verification (KYC): To verify that you meet the 21+ age requirement and to comply with Know Your Customer obligations under applicable gaming authority standards before enabling withdrawal access.
• Transaction processing: To process deposits and withdrawals via Malaysian payment channels, reconcile wallet balances, and apply bonus credits in accordance with promotion terms.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other security incidents. This includes monitoring for unusual login patterns and transaction anomalies.
• Legal and regulatory compliance: To meet obligations imposed by applicable gaming authority requirements, anti-money laundering regulations, and data protection laws.
• Customer support: To respond to your queries, complaints, and support requests, and to maintain records of communications for quality and compliance purposes.
• Responsible gaming: To monitor gaming behaviour for indicators of problem gambling and to administer deposit limits, cooling-off periods, and self-exclusion requests in accordance with our Responsible Gaming policy.
• Platform improvement: To analyse aggregated usage data to improve the comel33 platform, identify technical issues, and optimise the player experience.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — where you have opted in to receive such communications or where we have a legitimate interest in doing so. You may opt out at any time through your account notification settings.

4. Legal Basis for Processing

comel33 processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between comel33 and you as a registered player — including account creation, transaction processing, and game service delivery.
• Legal obligation: Processing required to comply with applicable laws and gaming authority regulations, including KYC verification and anti-money laundering record-keeping.
• Legitimate interests: Processing undertaken for comel33's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing of data for marketing communications, where your prior consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

5. Data Sharing & Disclosure

comel33 does not sell your personal data to third parties. Personal data may be shared with the following categories of recipient in the circumstances described:

• Payment service providers: Malaysian payment processors including FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, and banking institutions require transaction data to process deposits and withdrawals.
• Identity verification providers: Third-party KYC and document verification services process identity document data on comel33's behalf to fulfil age and identity verification obligations.
• Game providers: Licensed game studios and platform providers may receive session data to the extent necessary for game operation and fault resolution.
• Fraud and security providers: Specialist fraud detection services process behavioural and technical data to identify and prevent fraudulent activity on the platform.
• Regulatory and law enforcement authorities: comel33 will disclose personal data to competent authorities where required by applicable law, court order, or regulatory direction, without prior notice to you where disclosure obligations prohibit it.
• Professional advisers: Legal, audit, and compliance advisers may access personal data on a need-to-know basis under strict confidentiality obligations.

All third-party data processors engaged by comel33 are subject to data processing agreements that require them to process personal data only as instructed and to maintain appropriate security measures.

6. Cookies & Tracking Technologies

The comel33 platform uses cookies and similar tracking technologies to operate correctly and to improve the player experience. The categories of cookies used include:

• Strictly necessary cookies: Required for the platform to function — including session authentication, login state maintenance, and security tokens. These cannot be disabled without impairing platform functionality.
• Functional cookies: Store your preferences such as language settings, display preferences, and game lobby filters so that they persist between sessions.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate and use the platform to help comel33 identify usability issues and optimise page performance.
• Marketing cookies: Used where you have opted in to receive personalised promotional content, to track which promotions have been shown and whether they have been engaged with.

You may manage cookie preferences through your browser settings. Disabling certain cookie categories may affect the functionality of the comel33 platform.

7. Data Retention

comel33 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account registration and identity data: retained for the duration of your account plus a minimum of five (5) years following account closure, to meet regulatory record-keeping obligations.
• Transaction and financial records: retained for a minimum of seven (7) years following the relevant transaction, in accordance with anti-money laundering record-keeping requirements.
• Customer support communications: retained for a minimum of three (3) years from the date of the last communication.
• Gaming session logs: retained for a minimum of three (3) years for compliance and dispute resolution purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

8. Data Security

comel33 implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data it processes. These measures include:

• TLS encryption for all data transmitted between your device and comel33 servers
• Encrypted storage of passwords — plain-text password storage is not used
• Role-based access controls limiting internal access to personal data to personnel with a demonstrated operational need
• Regular security assessments and penetration testing of the comel33 platform
• Two-factor authentication options for player accounts to reduce the risk of unauthorised access
• Incident response procedures covering detection, containment, investigation, and notification in the event of a personal data breach

9. Your Rights

Subject to applicable data protection law, you have the following rights in respect of your personal data held by comel33:

• Right of access: You may request a copy of the personal data comel33 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, subject to comel33's legal retention obligations which may prevent full erasure during the applicable retention period.
• Right to restriction: You may request that comel33 restrict processing of your personal data in certain circumstances, for example while the accuracy of data is being contested.
• Right to data portability: You may request that personal data you have provided to comel33 be supplied in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing of your personal data where comel33 relies on legitimate interests as the legal basis, or where data is processed 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.

To exercise any of these rights, contact the comel33 support team via live chat or by email at [email protected]. Requests will be responded to within thirty (30) days of receipt. Identity verification may be required before requests are processed.

10. Children's Privacy

The comel33 platform is strictly for individuals aged 21 and above. comel33 does not knowingly collect, use, or retain personal data from individuals under the age of 21. If comel33 becomes aware that personal data has been collected from a person under 21, that data will be deleted promptly and the associated account closed.

If you believe that a person under 21 has registered an account with comel33, please notify the support team immediately at [email protected].

11. Third-Party Services

The comel33 platform integrates with third-party services including game providers, payment processors, and analytics tools. These third parties operate their own privacy policies governing their handling of personal data. comel33 is not responsible for the privacy practices of third-party service providers, but requires all processors operating on comel33's behalf to adhere to contractual data protection obligations consistent with this Privacy Policy.

comel33.win does not contain links to third-party websites. Should you navigate to any external site independently, comel33's Privacy Policy does not extend to those sites.

12. International Data Transfers

Personal data collected by comel33 may be stored and processed on servers located outside of Malaysia, including in jurisdictions where data protection laws differ from those in Malaysia. Where personal data is transferred internationally, comel33 takes steps to ensure that such transfers are made only to recipients in countries providing an adequate level of data protection, or subject to appropriate safeguards such as standard contractual clauses or equivalent binding commitments.

13. Changes to This Privacy Policy

comel33 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered account holders via email or by prominent notice on the comel33 platform not less than seven (7) days before the revised policy takes effect, except where immediate amendment is required by law.

The "Last updated" date at the top of this policy indicates when the most recent revision was made. Your continued use of the comel33 platform after the effective date of any revised policy constitutes acceptance of the updated terms.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to comel33's handling of your personal data, please contact the data protection team through the following channels:

Email: [email protected]

Live chat: Available 24/7 through your comel33 account dashboard.

The comel33 privacy team will acknowledge your query within 48 hours and aims to provide a substantive response within thirty (30) calendar days. Queries may be submitted in English or Bahasa Malaysia.