telor33 Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") is issued by telor33 ("telor33", "we", "us", "our") and applies to all personal data collected from individuals ("Members", "Users", "you") who access or use the telor33 website at telor33.co and all associated services, games, and features (the "Platform").

telor33 is committed to protecting the privacy and security of your personal information. This Policy explains what data we collect, the legal basis on which we process it, how we use and share it, how long we retain it, and the rights available to you in respect of your personal data. Please read this Policy carefully. By registering a telor33 account or using the Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read alongside the telor33 Terms & Conditions available at telor33.co/terms-conditions.

2. Data Controller Information

For the purposes of applicable data protection legislation, telor33 is the data controller in respect of personal data collected through the Platform. The data controller is responsible for determining the purposes and means of processing your personal data.

For all data protection queries, requests to exercise your rights, or to contact our data protection function, please write to: [email protected] (plain text — not a clickable link) with the subject line "Data Protection Enquiry".

3. Personal Data We Collect

telor33 collects the following categories of personal data from Members and Platform visitors:

3.1 Identity Data

• Full legal name as it appears on government-issued identification.
• Date of birth (for mandatory age verification — all Members must be 21 or older).
• Nationality and country of residence.
• Government-issued identification document numbers (e.g., Malaysian MyKad number, passport number).

3.2 Contact Data

• Email address registered on your telor33 account.
• Mobile phone number.
• Residential address (required for KYC and regulatory compliance).

3.3 Financial Data

• Payment method details (e.g., bank account numbers, Touch 'n Go eWallet identifiers, Boost account references) — stored in tokenised form.
• Transaction history including deposits, withdrawals, and bonuses on the telor33 platform.
• Source of funds documentation where requested for AML compliance.

3.4 Technical & Usage Data

• IP address and approximate geolocation derived therefrom.
• Device type, operating system, and browser information.
• Login timestamps, session duration, and session activity logs.
• Game history, wagering activity, and platform interaction patterns on telor33.

3.5 Communications Data

• Records of communications between you and the telor33 support team, including live chat transcripts and email correspondence.
• Responses to surveys or feedback requests, where submitted voluntarily.

4. How We Collect Your Data

telor33 collects personal data through the following means:

• Direct collection: Data you provide when registering a telor33 account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically through cookies, server logs, and analytics tools when you browse or use the telor33 Platform.
• Third-party sources: Identity verification and fraud screening data from KYC/AML service providers; payment processing data from payment gateway partners; public databases where accessed for fraud prevention or regulatory compliance purposes.

5. Purposes & Legal Basis for Processing

telor33 processes your personal data for the following purposes, each supported by a lawful basis under applicable data protection law:

• Account registration and management — necessary for the performance of the contract between you and telor33.
• Age and identity verification (KYC) — necessary for compliance with legal obligations applicable to telor33 as a licensed gaming operator, including mandatory anti-underage-gambling measures (21+ requirement).
• Payment processing and fraud prevention — necessary for the performance of the contract and for telor33's legitimate interests in preventing financial fraud.
• Anti-money laundering (AML) compliance — necessary for compliance with legal obligations applicable to telor33 under international AML regulations.
• Platform operation and improvement — telor33's legitimate interests in maintaining, improving, and securing the Platform.
• Responsible gaming monitoring — telor33's legitimate interests and legal obligations in identifying and assisting players displaying indicators of problem gambling.
• Marketing communications — where you have provided explicit consent, or where permitted under applicable law based on the existing Member relationship.
• Legal and regulatory compliance — compliance with applicable law and regulatory requirements, including responses to lawful requests from authorities.

6. Sharing of Personal Data

telor33 does not sell or rent your personal data to any third party. We may share your personal data with the following categories of recipients where necessary:

• KYC/AML service providers — for identity verification and anti-money laundering screening.
• Payment processors and e-wallet operators — including Touch 'n Go eWallet, Boost, and Malaysian banking partners, to process your financial transactions on telor33.
• Game content providers — licensed game studios and live casino providers who process session data to deliver game functionality.
• Fraud prevention and cybersecurity providers — for the detection and prevention of fraud, account takeover, and platform abuse.
• Regulatory and law enforcement authorities — where telor33 is required by applicable law, court order, or regulatory direction to disclose your personal data.
• Professional advisers — lawyers, auditors, and insurers where necessary for legitimate legal or business purposes under strict confidentiality obligations.

All third-party service providers engaged by telor33 are subject to data processing agreements requiring them to handle your personal data securely and only for the specified purpose.

7. International Data Transfers

Some of telor33's service providers and technology infrastructure may be located outside Malaysia. Where personal data is transferred internationally, telor33 ensures that appropriate safeguards are in place, including contractual protections equivalent to those required under applicable data protection law. Transfers to KYC, payment, and game platform providers are conducted under standard contractual clauses or equivalent protections.

8. Data Retention

telor33 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods driven by legal and regulatory obligations:

• Account and identity data: Retained for a minimum of five (5) years following account closure, as required by applicable AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Retained for three (3) years from the date of the last interaction.
• Technical and usage logs: Retained for up to twelve (12) months, except where specific retention is required for fraud investigations or legal proceedings.

Upon expiry of the applicable retention period, telor33 will securely delete or anonymise personal data in accordance with its data disposal procedures.

9. Cookies & Tracking Technologies

The telor33 Platform uses cookies and similar tracking technologies to operate and improve the Platform experience. Cookies used by telor33 include:

• Strictly necessary cookies: Required for the Platform to function, including session authentication and security cookies. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and login state on trusted devices.
• Analytics cookies: Used by telor33 to understand how Members use the Platform and to identify areas for improvement. Analytics data is aggregated and anonymised where possible.
• Marketing cookies: Used only where you have given consent, to deliver relevant promotional content relating to telor33 services.

You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the telor33 Platform.

10. Security Measures

telor33 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the telor33 Platform.
• AES-256 encryption for sensitive personal data stored in telor33 databases.
• Role-based access controls limiting internal access to personal data to staff with a demonstrated operational need.
• Multi-factor authentication required for all telor33 staff with administrative access to Member data systems.
• Regular penetration testing and vulnerability assessments of telor33 infrastructure.
• Audit logging of all access to and modifications of Member personal data.

No system is completely immune from security threats. In the event of a personal data breach affecting your telor33 account, we will notify you promptly in accordance with our legal notification obligations.

11. Your Data Subject Rights

Subject to applicable data protection law and telor33's legal and regulatory obligations, you have the following rights in respect of your personal data held by telor33:

• Right of access: You may request a copy of the personal data telor33 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 where telor33 no longer has a lawful basis for retaining it, subject to legal and regulatory retention obligations.
• Right to restriction: You may request that telor33 restrict the processing of your personal data in certain circumstances.
• Right to data portability: You may request a machine-readable copy of personal data you have provided to telor33, where technically feasible.
• Right to object: You may object to processing of your personal data based on telor33's legitimate interests, including 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 prior processing.

To exercise any of the above rights, please contact telor33 at [email protected] with the subject line "Data Rights Request". We will respond within thirty (30) days. Identity verification may be required before processing your request.

12. Children & Minors

The telor33 Platform is strictly restricted to individuals aged 21 years and above. telor33 does not knowingly collect personal data from individuals under 21. If telor33 becomes aware that personal data has been collected from a person under 21, that account will be closed immediately and the associated data deleted, subject to any mandatory regulatory retention requirements. Parents or guardians who believe a minor may have accessed telor33 should contact our support team immediately.

13. Third-Party Services

The telor33 Platform integrates with third-party game content providers, payment processors, and technology partners to deliver Platform services. These third parties operate their own privacy policies governing data they collect or process in the course of providing services to telor33. telor33 is not responsible for the privacy practices of third-party providers beyond the contractual data protection obligations imposed on them by telor33 as data processor agreements.

14. Marketing Communications

telor33 may send you promotional communications relating to telor33 offers, bonuses, and platform updates where you have consented to receive such communications or where permitted by applicable law based on the existing Member relationship. You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any telor33 marketing email.
• Updating your communication preferences in your telor33 account settings.
• Contacting telor33 support at [email protected].

Opting out of marketing communications does not affect telor33's ability to send you transactional communications relating to your account, such as withdrawal confirmations, security alerts, or KYC requests.

15. Changes to This Policy

telor33 reserves the right to update or amend this Privacy Policy at any time. Material changes will be notified to Members via email to the registered account address and/or by prominent notice on the telor33 Platform, with a minimum of seven (7) days' notice before the change takes effect. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Continued use of the telor33 Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

16. Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by telor33, please contact us:

• Email: [email protected] — subject line: "Privacy Policy Enquiry" or "Data Rights Request".
• Live Chat: Available 24/7 within your telor33 account dashboard.

If you are not satisfied with telor33's response to a data protection query, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.