lb33 Privacy Policy

1 Introduction

lb33 ("we", "us", "our", or "lb33") is committed to protecting the privacy and personal data of all individuals who access and use the lb33 online gaming platform, available at lb33.club. This Privacy Policy sets out how lb33 collects, processes, stores, and shares personal data in connection with the provision of our services to players based primarily in Malaysia.

This Privacy Policy should be read in conjunction with lb33's Terms & Conditions and Responsible Gaming Policy, which together govern your use of lb33's platform. By registering an account or continuing to use lb33's services, you acknowledge that you have read and understood this Privacy Policy.

lb33 takes its obligations under applicable data protection legislation seriously. We regularly review our data handling practices to ensure they remain appropriate, proportionate, and aligned with current regulatory expectations.

2 Personal Data We Collect

lb33 collects personal data through multiple touchpoints during your registration and use of the platform. The categories of data we collect include:

lb33 does not collect sensitive personal data (such as racial or ethnic origin, political opinions, health data, or biometric data) except where explicitly required for responsible gaming or identity verification purposes and where you have provided explicit consent.

3 How lb33 Uses Your Personal Data

lb33 processes your personal data for the following purposes:

• Account creation and management: To create, maintain, and administer your lb33 player account, including verifying your identity and age (21+) upon registration.
• Service delivery: To process bets, manage your gaming activity, credit winnings, and provide access to all lb33 products including the sportsbook, live casino, slots, and esports betting sections.
• Payment processing: To process deposits and withdrawals via Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank, and other supported Malaysian payment channels.
• Identity and fraud verification (KYC/AML): To comply with applicable Know Your Customer and Anti-Money Laundering obligations, including verifying the source of funds where required.
• Customer support: To respond to your enquiries, resolve account issues, process complaints, and deliver support through lb33's 24/7 live chat.
• Responsible gaming: To monitor gaming patterns for indicators of problem gambling, administer deposit limits and self-exclusion requests, and discharge lb33's player protection obligations.
• Platform improvement: To analyse usage data in aggregate to improve lb33's platform performance, product offerings, and user experience.
• Marketing communications: To send you promotions, bonus offers, and product updates by email or in-platform notification, where you have opted in or where lb33 has a legitimate interest to do so. You may opt out at any time.
• Legal compliance: To comply with applicable legal, regulatory, and law enforcement obligations.

4 Legal Basis for Processing

lb33 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between lb33 and you as a registered player — including account administration, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, and responsible gaming compliance obligations.
• Legitimate interests: Processing for fraud detection, platform security, and aggregate analytics — where lb33's legitimate interests do not override your fundamental rights and freedoms.
• Consent: Processing for optional communications and non-essential data uses — where lb33 relies on your freely given, informed consent which you may withdraw at any time without detriment.

5 Data Sharing & Disclosure

lb33 does not sell your personal data. We may share your data with third parties only in the following circumstances:

• Payment service providers: Touch n Go eWallet, Boost, and banking partners receive the minimum data necessary to process your deposits and withdrawals.
• Game and technology providers: Third-party game providers who supply games on lb33's platform may receive limited technical data (such as a pseudonymous player identifier and session token) necessary for game operation. These providers are contractually bound to data protection standards.
• Identity verification services: lb33 may engage specialist KYC/AML service providers to verify player identity. All such providers are contractually obligated to handle data securely and solely for the stated purpose.
• Law enforcement and regulators: lb33 may disclose personal data to law enforcement agencies, regulators, or courts where legally required to do so, or where lb33 believes disclosure is necessary to protect lb33's rights or the safety of any person.
• Business transfer: In the event of a merger, acquisition, or transfer of lb33's business assets, player data may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy.

All third-party recipients of personal data are required to maintain appropriate technical and organisational measures to protect that data, and are prohibited from using it for any purpose beyond that for which it was disclosed.

6 Cookies & Tracking Technologies

lb33 uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies lb33 uses include:

• Strictly necessary cookies: Required for the platform to function — including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language, display settings, and previously used payment methods to improve your lb33 experience.
• Analytics cookies: Collect aggregate, anonymised data about how players interact with lb33's pages — used to identify technical issues and improve platform performance. No personally identifiable information is associated with these cookies.

lb33 does not use third-party advertising cookies or behavioural tracking technologies that share your data with external advertising networks. You may manage your cookie preferences through your browser settings, though disabling strictly necessary cookies may affect your ability to use lb33's platform.

7 Data Retention

lb33 retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. General retention periods applied by lb33 are:

• Active account data: Retained for the duration of your lb33 account and for a period of five (5) years following account closure, in compliance with AML record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• KYC/identity documents: Retained for five (5) years from the date of verification or account closure, whichever is later.
• Support communications: Retained for two (2) years from the date of the interaction.
• Technical/session data: Retained for thirteen (13) months for security and fraud analysis purposes.

Where lb33 no longer has a lawful basis for retaining personal data, it will be securely deleted or anonymised.

8 Data Security

lb33 implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and lb33's servers.
• Encrypted storage of sensitive data at rest, including financial and identity information.
• Role-based access controls restricting access to personal data to authorised lb33 personnel on a need-to-know basis.
• Regular security audits and penetration testing of lb33's platform infrastructure.
• Multi-factor authentication for internal systems accessing player data.
• Incident response procedures for detecting, reporting, and responding to personal data breaches.

Notwithstanding these measures, no data transmission over the internet can be guaranteed to be 100% secure. lb33 will notify affected players of any personal data breach where required by applicable law and will take immediate remedial action upon discovering a breach.

9 Your Data Rights

As an lb33 player, you have the following rights in relation to your personal data, subject to applicable legal limitations:

• Right of access: You may request confirmation of whether lb33 holds personal data about you and, if so, receive a copy of that data.
• Right to rectification: You may request correction of inaccurate or incomplete personal data held by lb33.
• Right to erasure: Subject to lb33's legal retention obligations, you may request deletion of personal data that lb33 no longer has a lawful basis to retain.
• Right to restriction of processing: You may request that lb33 restrict its processing of your personal data in certain circumstances.
• Right to data portability: You may request that lb33 provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You may object to lb33's processing of your personal data where that processing is based on 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 these rights, contact lb33's support team at [email protected] (use as plain text reference only). lb33 will respond to rights requests within 14 business days. We may need to verify your identity before fulfilling a request.

10 Children & Minors

lb33's services are strictly intended for persons aged 21 years and above. lb33 does not knowingly collect personal data from individuals under the age of 21. If lb33 becomes aware that personal data has been collected from a minor, the relevant account will be immediately suspended, the data deleted, and the matter may be referred to the appropriate authorities.

If you are a parent or guardian and believe your child has created an lb33 account, please contact lb33's support team immediately so that appropriate action can be taken.

11 Third-Party Links

lb33's platform may reference third-party services, game providers, or payment processors. Where links or integrations to third-party platforms exist, those third parties operate under their own privacy policies for which lb33 is not responsible. lb33 recommends that you review the privacy practices of any third-party service you interact with in connection with your lb33 account.

12 Updates to This Privacy Policy

lb33 reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered players via email or on-platform notification where reasonably practicable. The current version of this Privacy Policy is always accessible at lb33.club/privacy-policy and the effective date is displayed in the header of this document.

Continued use of lb33's platform following notification of a policy update constitutes acceptance of the revised Privacy Policy. If you disagree with any changes, you should close your lb33 account and cease using the platform.

13 Contact & Data Enquiries

For all privacy-related enquiries, data rights requests, or concerns about lb33's data handling practices, please contact lb33's support team using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week via the lb33 platform dashboard
• Response Commitment: lb33 targets a response to all written data enquiries within 14 business days