Privacy Policy — clybet

1. Who We Are

clybet ("we", "us", "our") is the operator of the online gambling platform accessible at clybet.app and its associated subdomains, mobile interfaces, and related digital services (collectively, the "Platform"). clybet acts as the data controller in respect of personal data collected from players ("you", "your") who register for and use the Platform.

This Privacy Policy applies to all personal data processed by clybet in connection with player registration, account management, gameplay, deposits and withdrawals, customer support interactions, and marketing communications. This policy should be read alongside our Terms & Conditions and Responsible Gaming Policy.

2. Personal Data We Collect

2.1 Registration and Identity Data

When you create a clybet account, we collect: your full legal name, date of birth, residential address, email address, mobile phone number, and the username you select. Where identity verification (KYC) is required, we additionally collect copies of government-issued identification documents such as a Malaysian MyKad or passport, and proof of address documents.

2.2 Financial Data

clybet collects information necessary to process deposits and withdrawals, including: the payment method used (e.g., Touch n Go eWallet, Boost, Maybank online banking, CIMB Clicks, GrabPay, USDT wallet address), transaction amounts, and transaction reference numbers. clybet does not store full card numbers or banking credentials — payment transactions are handled via certified third-party payment processors.

2.3 Gameplay and Transaction Data

We record all betting and gaming activity on the Platform, including: game sessions played, bets placed and outcomes, bonus eligibility and utilisation, and account balance movements. This data is necessary for the operation of the Platform, dispute resolution, and regulatory compliance.

2.4 Technical and Usage Data

clybet automatically collects technical data when you access the Platform, including: IP address, device type and operating system, browser type and version, session timestamps, pages visited, and referring URLs. This data is collected via cookies, web beacons, and server logs.

2.5 Customer Support Data

When you contact clybet support via live chat or email, we retain records of your communications, including the content of messages, timestamps, and the outcome of any support interaction. These records are used for quality assurance, training, and dispute resolution purposes.

2.6 Responsible Gaming Data

Where you voluntarily use clybet's responsible gaming tools — such as setting deposit limits, requesting self-exclusion, or activating session timers — we record these elections and apply them to your account. This data is handled with heightened sensitivity and is not used for marketing profiling.

3. How We Use Your Personal Data

clybet processes personal data for the following purposes:

• Account management: To create, verify, maintain, and administer your clybet account, including authentication at clybet login and account security monitoring.
• Service delivery: To enable gameplay, process deposits and withdrawals, manage bonuses, and deliver all features of the clybet Platform.
• Identity verification and compliance: To fulfill KYC obligations, prevent underage gambling (enforcing the 21+ age requirement), conduct anti-money laundering checks, and comply with applicable regulatory requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, bonus abuse, and other prohibited activities on the clybet Platform.
• Customer support: To respond to your enquiries, resolve disputes, and provide assistance with your clybet account.
• Responsible gaming: To monitor gambling patterns for signs of problem gambling behaviour, to apply self-exclusion and limit settings, and to facilitate referrals to support resources where appropriate.
• Personalisation and improvement: To analyse Platform usage patterns, improve our services, personalise your gaming experience, and develop new features.
• Marketing communications: To send promotional offers, newsletters, and updates — subject to your communication preferences and applicable opt-out rights (see Section 12).

4. Legal Basis for Processing

clybet processes personal data under the following legal bases:

• Contractual necessity: Processing required to fulfil our contract with you — including account operation, payment processing, and service delivery — is necessary for the performance of the Terms & Conditions you entered into with clybet.
• Legal obligation: Certain processing — including KYC verification, AML monitoring, and responsible gaming record-keeping — is required for compliance with applicable legal and regulatory obligations.
• Legitimate interests: Processing for fraud prevention, security monitoring, Platform improvement, and anonymised analytics is conducted pursuant to clybet's legitimate interests, balanced against your privacy rights.
• Consent: Where we rely on your consent — principally for direct marketing communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

5.1 Service Providers

clybet shares personal data with carefully selected third-party service providers who process data on our behalf for specific purposes, including: payment processing partners, identity verification providers, customer support platform operators, and cloud infrastructure providers. All service providers are bound by data processing agreements and are prohibited from using personal data for their own independent purposes.

5.2 Game Providers

Certain game providers whose titles are available on the clybet Platform may receive limited technical data (such as player session identifiers) for the purpose of delivering their games. These providers do not receive your full identity or financial information.

5.3 Regulatory and Legal Authorities

clybet will disclose personal data to regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, regulatory instruction, or valid legal process. clybet will not disclose personal data beyond what is strictly required to satisfy any such obligation.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of clybet's business, personal data held by clybet may be transferred to a successor entity, subject to that entity assuming equivalent data protection obligations. Affected players will be notified of any such transfer.

5.5 No Sale of Personal Data

clybet does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes.

6. Cookies and Tracking Technologies

clybet uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used include:

• Strictly necessary cookies: Required for the Platform to function, including session management and security authentication. These cannot be disabled.
• Performance cookies: Collect anonymised data about how players interact with the Platform to help us improve usability and performance.
• Functional cookies: Remember your preferences, such as language settings and layout choices, to personalise your experience on the clybet Platform.
• Analytics cookies: Used by clybet to understand aggregate usage patterns, page performance, and player journeys. Data collected is anonymised or pseudonymised.

You may control non-essential cookies via your browser settings. Note that disabling certain cookies may impair the functionality of the clybet Platform.

7. Data Retention

clybet retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following general retention principles:

• Active account data: Retained for the duration of your clybet account and for a period of not less than five (5) years following account closure, to meet regulatory, anti-money laundering, and dispute resolution obligations.
• Transaction records: Financial and gaming transaction records are retained for a minimum of seven (7) years from the date of the transaction, in accordance with applicable financial record-keeping requirements.
• Self-exclusion records: Where a player has self-excluded from clybet, that record is retained permanently to prevent re-registration during the exclusion period.
• Support communications: Retained for a minimum of three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications, after which data is suppressed or deleted within 30 days.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised.

8. Data Security

clybet implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the clybet Platform
• Encryption of sensitive data at rest within clybet's data storage systems
• Multi-factor authentication controls for administrative access to systems containing personal data
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular penetration testing and security audits by independent third-party security specialists
• Incident response procedures for detecting, containing, and reporting data security incidents

In the event of a personal data breach that poses a risk to your rights, clybet will notify affected players without undue delay and in accordance with applicable regulatory notification requirements.

9. International Data Transfers

As an internationally operating platform, clybet may transfer your personal data to countries outside of Malaysia for processing and storage — including by third-party service providers operating in other jurisdictions. Where such transfers occur, clybet ensures that appropriate safeguards are in place, such as standard contractual clauses or equivalent data transfer mechanisms, to ensure that your personal data receives a level of protection consistent with applicable data protection standards.

10. Your Privacy Rights

Subject to applicable law, you have the following rights in respect of your personal data held by clybet:

• Right of access: You may request a copy of the personal data clybet holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data held by clybet.
• Right to erasure: You may request deletion of your personal data in certain circumstances, subject to clybet's legal retention obligations.
• Right to restrict processing: You may request that clybet limit its use of your personal data in certain defined circumstances.
• Right to data portability: Where processing is based on consent or contractual necessity, you may request that your personal data be provided to you in a structured, machine-readable format.
• Right to object: You may object to processing of your personal data conducted on the basis of legitimate interests, including profiling for direct marketing purposes.
• Right to withdraw consent: Where clybet processes data on the basis of your consent, you may withdraw that consent at any time without affecting prior lawful processing.

To exercise any of these rights, please contact clybet at [email protected]. Requests will be acknowledged within five (5) business days and fulfilled within thirty (30) days, subject to identity verification requirements.

11. Children's Privacy and Age Restriction

The clybet Platform is strictly for individuals who are 21 years of age or older. clybet does not knowingly collect personal data from individuals under the age of 21. The Platform employs age verification procedures during registration to enforce this restriction. If clybet becomes aware that an account has been registered by an individual under 21, the account will be immediately closed, all funds will be forfeited, and personal data will be retained only to the extent required to record the age violation and prevent future registration.

If you believe a minor has registered for a clybet account, please contact us immediately at [email protected].

12. Marketing Communications

With your consent, clybet may send you promotional emails, SMS messages, and Platform notifications about bonuses, new games, sportsbook promotions, and other clybet offers relevant to Malaysian players. You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email from clybet
• Updating your communication preferences in your clybet account settings
• Contacting clybet support at [email protected] and requesting removal from marketing lists

Please note that opting out of marketing communications does not affect the delivery of transactional communications related to your clybet account, such as deposit confirmations, withdrawal notifications, and security alerts.

Players who have self-excluded from clybet will be automatically removed from all marketing lists for the duration of the self-exclusion period and will not receive any promotional communications from clybet during that time.

13. Changes to This Privacy Policy

clybet reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, Platform features, or applicable law. Material changes will be communicated to registered players via email and/or a prominent notice displayed upon clybet login. The effective date of the current version of this Policy is stated at the top of this page. Your continued use of the clybet Platform following notification of any material changes constitutes your acknowledgement of the updated Policy.

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or clybet's data practices, please contact our Data Protection team:

• Email: [email protected] (subject line: "Privacy Enquiry")
• Live Chat: Available on the clybet Platform 24/7

clybet will acknowledge all privacy-related correspondence within five (5) business days and aims to resolve all requests within thirty (30) days.