22club Privacy Policy – Malaysian Player Data Protection

22club ("we", "Platform") are committed to protecting the privacy of all individuals who interact with our platform at 22club.click. This Privacy Policy sets out in detail how we collect, process, store and protect your personal information as a player or visitor to our website.

This policy applies to all individuals who register an account at 22club, use any of our services (Sports Betting, Live Casino, slots, table games), visit our website or contact our customer support team. It does not apply to third-party websites that may be linked from our platform.

By using the 22club, you agree to the collection and use of your information as described in this Privacy Policy. If you disagree with any part of this policy, please discontinue use of our platform and contact us for further assistance.

22club collects various types of information depending on how you interact with our platform. The following are the categories of data we collect:

A. Information You Provide Directly:

• Identity Information: Full name as shown on official identification documents, date of birth, gender and identification document number (for KYC verification).
• Contact Information: An active email address, a registered Malaysian mobile number, and your residential address.
• Account Information: The username you choose, your password (stored in encrypted form and unreadable by anyone), and your communication preferences.
• Financial Information: Details of payment methods used, such as Touch 'n Go eWallet, GrabPay, DuitNow, Boost, ShopeePay, or FPX accounts (Maybank2u, CIMB Clicks). Full card numbers are not stored by 22club.
• Verification Documents: Copies of identity documents, proof of address, or other documents requested during the KYC process.

B. Automatically Collected Information:

• Technical Data: IP address, browser type, operating system, screen resolution and device information.
• Usage Data: Pages visited, session duration, clicks, in-platform searches, and navigation choices.
• Betting Data: Betting history, types of games played (football, badminton, slots, live casino and others), amounts wagered and game outcomes.
• Location Data: General location information based on IP address for compliance and security purposes.

22club only uses your personal data for legitimate, stated purposes. We do not process your data beyond what is necessary for the following:

• Account Management: Create and manage your account, process registration, verify your identity (KYC), and confirm your age.
• Betting & Gaming Services: Processing sports betting (football, badminton, cricket, and others), Live Casino games, slots, and all platform services.
• Financial Processing: Processing deposits (Touch 'n Go, GrabPay, DuitNow, and others) and withdrawals in Malaysian Ringgit (RM), as well as detecting and preventing fraud and money laundering.
• Customer Support: Handling enquiries, resolving complaints and providing technical assistance to 22club players.
• Legal Compliance: Meeting legal obligations, including anti-money laundering (AML) and know your customer (KYC) requirements.
• Platform Security: Detect, investigate, and prevent fraudulent activity, multi-account usage, bonus abuse, and other security threats.
• Platform Improvement: Analysing aggregated usage data (without identifying individuals) to improve the features, design and performance of the 22club platform.
• Marketing Communications: Sending information about promotions, bonuses and new offers — only where you have given consent, which you may withdraw at any time.
• Responsible Gambling: Monitoring betting patterns to identify signs of problem gambling and providing appropriate support to players who need assistance.

The processing of your personal data by 22club is based on one or more of the following lawful grounds:

• Performance of Contract: Processing necessary to fulfil the service agreement between you and 22club — specifically, to provide the betting and gaming platform you registered for.
• Legal Obligation Compliance: Processing required to comply with applicable laws, including KYC, AML, and gambling regulatory requirements.
• Legitimate Interest: Processing for our legitimate interests, such as fraud prevention, platform security and service quality improvement — provided these interests do not override your fundamental privacy rights.
• Consent: For marketing communications and the use of non-essential cookies, we rely on your explicit consent, which may be withdrawn at any time.

22club does not sell player personal data to any party. However, we may share your data with a limited set of third-party categories in the following circumstances:

• Service Providers: Companies that provide technical services to us, such as payment processors (Touch 'n Go, GrabPay, and others), KYC solution providers, server hosting services, and analytics platforms. All such providers are bound by strict data protection agreements.
• Regulatory Authority: Government authorities, law enforcement or regulators where required by law or a valid court order.
• Game Providers: Live Casino and slots game providers may receive the minimum technical data required to deliver games to you. They do not receive your financial information or full identity details.
• Business Transfer: In the event of a merger, acquisition, or asset transfer, player data may be transferred to the new entity involved — in such cases, you will be notified in advance.

22club implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, loss, destruction, or disclosure:

• Encryption in Transit: All data transmitted between your device and our servers is encrypted using 256-bit TLS/SSL.
• Encryption at Rest: Sensitive data stored in our databases, including passwords (stored in hashed form) and financial information, is encrypted using industry-standard encryption algorithms.
• Access Controls: Access to player data is restricted to staff who require it to perform their duties, on a strict need-to-know basis.
• 24/7 Monitoring: Our systems are continuously monitored to detect suspicious activity and unauthorised access attempts.
• Security Audit: Regular security audits are conducted by independent parties to assess and strengthen our security defences.
• Incident Response: We have established incident response procedures in place. Should a data breach occur that affects players, you will be notified in accordance with applicable legal requirements.

22club retaining your personal data for as long as your account remains active or as long as necessary for the stated purposes. Specific retention periods are as follows:

• Active Account Data: Retained for as long as your account remains active and for a reasonable period after it becomes inactive.
• Financial Transaction Records: Retained for a minimum of 7 years for anti-money laundering compliance and accounting requirements.
• KYC Records: Retained for a minimum of 5 years after account closure or the end of the business relationship.
• Support Communication Logs: Retained for 3 years for complaint resolution and service quality audit purposes.
• Marketing Data (with consent): Retained until you withdraw consent or request deletion.

Once the relevant retention period has ended, your data will be securely deleted or anonymised in accordance with our data deletion procedures.

Website 22club uses cookies and similar tracking technologies to enhance the user experience and gather information about how the website is used. We use several types of cookies:

• Essential Cookies: Required for core platform functions such as login authentication, session security and language preferences. These cookies cannot be disabled without affecting platform functionality.
• Performance/Analytics Cookies: Helps us understand how players use the platform — popular pages, technical issues, and navigation paths. This data is collected in aggregate and does not identify individuals.
• Functional Cookies: Remembering your preferences such as language, last-used betting limits and display settings to deliver a more personalised experience.
• Marketing Cookies: Used to display relevant promotions. These cookies are only activated with your consent and can be disabled via your cookie settings.

You can manage or delete cookies at any time through your web browser settings. Please note that disabling essential cookies may affect the functionality of the platform.

As an online platform, your personal data may be transferred to, stored in or processed in countries other than Malaysia. In all cases of international data transfer, 22club ensuring adequate safeguards are in place through:

• Use of approved Standard Contractual Clauses to safeguard data transfers to countries without an adequate data protection determination.
• Transfers only to countries deemed to provide an adequate level of data protection.
• Strict data processing agreements with all third-party service providers who have access to player data.

Further information about the safeguards applied to international data transfers is available by contacting us at support@22club.click.

As a player 22club, you have certain rights regarding your personal data. We respect these rights and make it straightforward to exercise them:

• Right of Access: You have the right to obtain a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure ("Right to be Forgotten"): Under certain circumstances, you have the right to request the deletion of your personal data.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your data under certain circumstances.
• Data Portability Right: You have the right to receive your personal data in a machine-readable format and transfer it to another party.
• Right to Object: You have the right to object to the processing of your data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to Withdraw Consent: You may withdraw your consent for consent-based processing at any time.

Platform 22club is intended solely for individuals who are aged 21 years and above. We do not knowingly collect personal data from children or individuals below the applicable age of majority.

If we find that personal data belonging to individuals below the minimum age requirement has been collected without our knowledge, we will take immediate steps to delete that data and close the associated account. If you believe your child or an underage individual has registered on our platform, please contact us immediately at support@22club.click.

22club employs a range of technical and procedural measures to prevent underage individuals from registering, including age verification during sign-up and a rigorous KYC process before any first withdrawal is processed.

22club reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or services. Where material changes are made, we will notify you by email or in-platform notification at least 14 days before the changes take effect.

Continued use of the platform 22club after notice of changes has been given will be considered acceptance of the amended Privacy Policy. The "Last Updated" date at the top of this page will always reflect the most current version.

If you have any questions or concerns, or wish to exercise your data rights, please contact our Data Privacy Officer:

• Email: support@22club.click
• Website: 22club.click
• Response Time: 1–2 business days (general support) or 14 business days (formal data rights requests)