Club22 Privacy Policy – Malaysia Member Personal Data Protection

1 Introduction and Scope of This Policy

This Privacy Policy applies to all users of the Club22 platform, including website visitors, registered members, and all individuals who interact with any of the services we offer. This policy covers all data collected through:

• The official club22 website at club22.pro
• Club22 mobile app for Android and iOS
• Customer support channels including live chat and email
• Any other digital platforms operated by club22

As a data controller, club22 is fully responsible for processing your personal data in accordance with applicable laws in Malaysia. If you have any privacy-related enquiries, our data protection team is available to assist at any time.

2 Types of Personal Data We Collect

Club22 only collects data that is genuinely necessary to provide you with quality service. The following are the categories of data we collect:

3 How We Use Your Data

Every piece of data we collect has a clear and legitimate purpose. club22 uses your information for the following purposes:

• Account Management: Creating and maintaining your member account, including identity verification and KYC processes required by regulations.
• Transaction Processing: Processing deposits, withdrawals and other financial activities in your account securely and accurately.
• Service Delivery: Ensuring you can access all games and features on the club22 platform without interruption.
• Customer Support: Helping you resolve any issues or enquiries you encounter while using our platform.
• Security and Fraud Prevention: Detecting and preventing fraudulent activity, money laundering and security breaches on the platform.
• Legal Compliance: Meeting the legal and regulatory obligations imposed on online gaming platforms.
• Platform Improvements: Analyzing usage patterns to improve the performance, usability and overall experience of the club22 platform.
• Marketing Communications: Sending promotional information, bonuses and exclusive offers — only if you have given consent to receive them.

Club22 will not use your data for any purposes other than those listed above without first obtaining your consent.

4 Data Sharing with Third Parties

Club22 does not sell, rent, or disclose your personal data to third parties for marketing purposes. However, in certain limited situations, we may share your data with the following parties:

• Payment Service Providers: Payment processors and banks that help us carry out financial transactions securely. They receive only the data necessary for the transaction itself.
• Game Providers: Gaming companies that provide game content within the club22 platform. Data sharing is limited to session information required for game functionality.
• KYC Verification Services: Identity verification service providers that help us authenticate member documents during the KYC process.
• Regulatory Authority: Government agencies or regulatory bodies entitled to request certain information under their legal authority.
• Analytics Services: Third-party analytics providers that help us understand platform usage patterns — data is shared in aggregated form with no personally identifiable information.

5 Data Security Measures

Protecting your personal data from unauthorized access, leaks or misuse is club22's highest priority. We employ multiple layers of security technology and procedures for this purpose:

While we take every reasonable step to protect your data, no system is entirely free from security risks. We therefore encourage you to take your own precautions — such as using a strong password, not sharing your login credentials, and logging out after each session.

6 Cookies and Tracking Technology

Club22 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

You can manage or delete cookies at any time through your web browser settings. Please note that deleting essential cookies may affect certain features of the Club22 platform.

7 Your Rights Regarding Personal Data

As a data subject under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data held by club22:

To exercise any of the above rights, please contact our data protection team. We will process your request within 30 business days. For more complex cases, we may extend this period by up to 60 days, with prior notice to you.

8 Data Retention Period

Club22 retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or to comply with applicable legal requirements. Our general data retention guidelines are as follows:

• Active Account Data: For as long as your account is active and for 5 years after account closure for legal compliance purposes.
• Financial Transaction Records: Minimum 7 years in accordance with Malaysia's taxation and anti-money laundering legal requirements.
• KYC and Identity Verification Data: 5 years after the business relationship ends, or longer if required by law.
• Support Communication Logs: 2 years from the date of last interaction.
• Analytics and Cookie Data: 90 days to 1 year depending on cookie type.

9 Changes to This Privacy Policy

Club22 reserves the right to update this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or service improvements. When we make significant changes, we will:

• Displaying a clear notice on the club22 homepage at least 14 days before changes take effect.
• Sending notifications to the email address registered to your account.
• Updating the "Last Updated" date at the top of this document.
• Maintaining an archive of previous versions of the Privacy Policy for your reference.

Continued use of the club22 platform after the effective date of any changes is considered your acceptance of the updated policy. If you do not agree with the changes, you have the right to close your account and stop using our platform.

10 Contact Our Data Protection Team

If you have any questions, concerns, or wish to exercise your privacy rights, Club22's data protection team is ready to assist. We are committed to responding to every enquiry thoroughly and within a reasonable timeframe.

Our response time is within 3 business days for general enquiries and 14 business days for formal requests related to your personal data rights.