Privacy Policy

This Privacy Policy ("Policy") is issued by mytown33 ("we", "us", "our", "the Operator", "the Platform") and governs the collection, processing, storage, and disclosure of personal data belonging to users ("you", "User", "Player") of the website located at https://mytown33.cam and all associated services.

mytown33 is committed to handling your personal information responsibly, transparently, and in accordance with internationally recognised data protection principles. We collect only what we need, use it only for stated purposes, and do not sell your personal data to third-party advertisers or data brokers under any circumstances.

This Policy forms part of our broader legal framework, alongside our Terms and Conditions. By registering an account or using the Platform, you acknowledge that you have read this Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you should not use the Platform.

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial information, and online identifiers.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means mytown33, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" means any third party engaged by mytown33 to process personal data on our behalf, such as payment processors and identity verification providers.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data for a stated purpose.
• "KYC" means Know Your Customer — the mandatory identity verification procedure applied to all accounts prior to withdrawal processing.
• "Sensitive Data" means personal data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, or financial account details beyond those strictly necessary for payment processing.

mytown33 collects the following categories of personal data from users of the Platform:

mytown33 collects personal data through the following channels:

4.1 Direct Collection

Data you provide to us directly includes information submitted during account registration, KYC verification uploads, deposit and withdrawal requests, support communications (live chat and email), and any feedback or survey responses you choose to submit.

4.2 Automated Collection

When you access and use the Platform, we automatically collect technical data including your IP address, device identifiers, browser type and version, operating system, session duration, pages visited, and gameplay activity. This data is collected via server logs, session tracking technology, and first-party cookies.

4.3 Third-Party Collection

In connection with payment processing and identity verification, our authorised third-party service providers — including payment gateways (FPX, DuitNow, e-wallet operators) and KYC verification providers — may share data with us as part of transaction confirmation and identity authentication workflows. This data sharing is governed by our agreements with those providers and is limited to what is strictly necessary for the stated purpose.

mytown33 processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and administering your player account, including processing login authentication and managing account settings and responsible gambling controls.
• Identity Verification (KYC): Verifying your identity, age (confirming 21+ requirement), and residential address in compliance with our international licensing obligations and anti-money laundering (AML) policies.
• Payment Processing: Processing deposits and withdrawals via all supported Malaysian payment methods (DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, Touch 'n Go eWallet, Boost, GrabPay, BTC/USDT).
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, chargeback abuse, and other prohibited conduct.
• Service Delivery: Providing access to all games, sports betting markets (including Liga Super Malaysia, EPL, UFC), live dealer tables, and associated platform features.
• Customer Support: Responding to support queries, resolving disputes, and processing account-related requests via live chat and email.
• Legal and Regulatory Compliance: Meeting our obligations under our international gaming licence, including transaction reporting and record retention requirements.
• Responsible Gambling Monitoring: Monitoring gameplay patterns to identify indicators of problem gambling behaviour and applying responsible gambling interventions where applicable.
• Service Improvement: Analysing aggregated, anonymised usage data to improve Platform features, game selection, and user experience.
• Marketing Communications: Sending promotional offers, bonus notifications, and Platform updates to users who have opted in to receive such communications. You may opt out at any time by contacting our support team.

mytown33 processes personal data under the following legal bases, consistent with internationally recognised data protection frameworks:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under the Terms and Conditions — including account creation, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with our international gaming licence obligations, KYC/AML requirements, and lawful requests from regulatory authorities.
• Legitimate Interests: Processing necessary for the legitimate interests of the Operator, including fraud detection, security monitoring, Platform improvement, and responsible gambling programme management, where such interests are not overridden by your data protection rights.
• Consent: Processing based on your explicit consent, specifically in relation to optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

mytown33 shares personal data only in the following limited and controlled circumstances:

7.1 Authorised Third-Party Service Providers

We engage carefully selected third-party service providers who process data on our behalf as Data Processors, strictly under written data processing agreements that bind them to the same data protection standards we apply. These include payment gateway operators (FPX, DuitNow providers, e-wallet platforms), KYC identity verification services, and cloud hosting infrastructure providers. These parties are not permitted to use your data for their own purposes.

7.2 Regulatory and Legal Disclosure

We may be required to disclose personal data to our licensing authority, law enforcement agencies, or other competent regulatory bodies where we are under a legal obligation to do so, or where disclosure is necessary to prevent, detect, or investigate suspected criminal activity including fraud and money laundering.

7.3 Business Succession

In the event of a merger, acquisition, or transfer of all or part of the Operator's business assets, your personal data may be transferred to the succeeding entity as part of that transaction. We will notify affected users prior to any such transfer and ensure the receiving entity is bound by equivalent data protection obligations.

7.4 No Sale of Data

mytown33 does not sell, trade, or otherwise transfer your personal data to third parties for commercial or marketing purposes. This commitment is unconditional.

mytown33 uses cookies and similar tracking technologies to deliver and improve the Platform experience. A cookie is a small text file stored on your device by the Platform for session management, authentication, and preference retention purposes.

8.1 Types of Cookies Used

8.2 Managing Cookies

You may configure your browser settings to refuse or delete cookies. Please note that disabling strictly necessary cookies will impair Platform functionality and may prevent login and payment processing from functioning correctly. We do not use third-party advertising cookies or retargeting pixels.

mytown33 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or licensing obligations. The following retention periods apply:

• Active Account Data: Retained for the duration of your account relationship with mytown33, plus a period of 5 years following account closure, to comply with AML record-keeping requirements under our international gaming licence.
• KYC Verification Documents: Retained for a minimum of 5 years from the date of last verification, in compliance with anti-money laundering obligations. Original identity documents are stored in encrypted form with restricted access.
• Transaction Records: All deposit and withdrawal records, including payment method identifiers, are retained for 5 years from the date of the transaction.
• Support Communication Logs: Live chat transcripts and email correspondence are retained for 2 years from the date of communication, or longer where the communication is relevant to an unresolved dispute.
• Technical / Log Data: Server log data and device fingerprint records are retained for up to 24 months for security and fraud investigation purposes.
• Marketing Preferences: Records of marketing opt-in and opt-out decisions are retained indefinitely to evidence consent status.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to an identified individual.

mytown33 implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption in Transit: All data transmitted between your device and the mytown33 Platform is encrypted using TLS 1.3 (256-bit SSL) — the same standard used by major Malaysian financial institutions.
• Encryption at Rest: All stored personal data, including KYC documents and financial records, is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within mytown33's systems is restricted on a strict need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and undergo data protection training.
• Two-Factor Authentication: Player accounts support two-factor authentication (2FA) for additional login security. We strongly recommend enabling this feature.
• Intrusion Detection: Our infrastructure is monitored 24/7 by automated intrusion detection systems. Security incidents are assessed and responded to according to documented incident response procedures.
• Third-Party Security Audits: Our Platform undergoes periodic third-party security assessments to identify and remediate vulnerabilities.

Subject to applicable law and the terms of our licensing obligations, you hold the following rights in respect of your personal data held by mytown33. To exercise any of these rights, please contact our Data Protection team via the email address listed in Section 15.

We will respond to all verified data rights requests within 30 calendar days. In complex cases, this may be extended to 60 days, with notification provided. We may require proof of identity before processing a rights request.

mytown33 is strictly an adult online gaming platform. Access is permitted only to individuals who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21.

Age verification is enforced through mandatory KYC identity document submission before any withdrawal is processed. Where we have reason to believe that an account has been registered by or is being operated by an individual under 21, we will immediately suspend the account, conduct an investigation, and close the account if underage use is confirmed. Any balance held will be returned to the lawful source of funds.

If you are a parent or guardian and believe your child has created an account on mytown33, please contact our support team without delay. We will cooperate fully to close the account and return any funds to the appropriate party.

As mytown33 operates under international licensing and engages third-party service providers across multiple jurisdictions, your personal data may be transferred to and processed in countries outside Malaysia. These may include jurisdictions where our cloud infrastructure, KYC verification providers, or payment processing partners are based.

Where personal data is transferred internationally, mytown33 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that which applies under our licensing framework. These safeguards include:

• Contractual data processing agreements with receiving parties, incorporating standard data protection clauses.
• Technical security controls (encryption in transit and at rest) applied regardless of the jurisdiction in which data is processed.
• Restriction of international transfers to third parties who can demonstrate compliance with recognised data protection standards.

By using the mytown33 Platform, you acknowledge and consent to the international transfer of your personal data as described in this Policy.

mytown33 reserves the right to amend this Privacy Policy at any time. Where amendments are material — such as changes to the categories of data collected, purposes of processing, or your rights — we will notify active account holders via email or in-platform notification prior to the changes taking effect.

The "Last Updated" date displayed at the top of this page indicates the most recent revision. We recommend reviewing this Policy periodically to stay informed of how we protect your personal data.

Your continued use of the Platform following notification of any amendment constitutes acceptance of the updated Policy. If you do not agree with any amendment, you may request account closure by contacting our support team.

For all queries, concerns, or requests relating to this Privacy Policy — including the exercise of your data rights — please contact the mytown33 Data Protection team through the channels below. We aim to respond to all privacy-related enquiries within 5 business days.

When contacting us regarding a data rights request, please include your registered account username, the nature of your request, and a description of the personal data concerned. We may require proof of identity before processing your request.