Privacy Policy — cmbet

1Introduction

This Privacy Policy ("Policy") is issued by cmbet ("Company", "we", "us" or "our"), the operator of the online gaming and sports betting platform available at cmbet.cam (the "Platform"). It sets out how cmbet collects, uses, stores, discloses and otherwise processes personal data submitted by or gathered about individuals who visit or use the Platform ("Members", "Users" or "you").

This Policy forms part of the cmbet Terms & Conditions and should be read alongside them. By accessing the Platform, registering an Account or making use of any cmbet product or service, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2Definitions

For the purposes of this Policy, the following terms carry the meanings assigned below:

Term	Meaning
Personal Data	Any information that identifies or can reasonably be used to identify a living individual, directly or in combination with other data.
Processing	Any operation performed on personal data, including collection, storage, use, disclosure, alteration, combination and deletion.
Data Controller	cmbet, as the entity that determines the purposes and means of processing your personal data.
Data Processor	A third-party service provider that processes personal data on behalf of cmbet under a binding data-processing agreement.
Consent	A freely given, specific, informed and unambiguous indication of agreement by which you accept the processing of your personal data.
Cookie	A small text file placed on your device by a web server to store preference information and enable session continuity.
KYC Data	Identity verification documents and related information collected as part of the Know Your Customer process.

3Data We Collect

3.1 — Information You Provide Directly

When you register an Account, complete KYC verification, make a transaction or contact our support team, you provide us with personal data that may include:

• Full legal name, date of birth and gender;
• Malaysian Identity Card (MyKad) number, passport number or other government-issued identification;
• Residential address (including city — e.g. Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam);
• Email address, mobile phone number and preferred language;
• Financial information such as bank account details, e-wallet identifiers (Touch 'n Go eWallet, Boost, GrabPay) and transaction history in MYR;
• Profile preferences, communication opt-in status and correspondence with our support team.

3.2 — Information Collected Automatically

When you access the Platform, our systems automatically collect certain technical data, including:

• IP address and approximate geographic location;
• Device type, operating system, browser type and version;
• Session timestamps, pages visited and features used;
• Referring URLs and search terms that led you to the Platform;
• Cookies and similar tracking identifiers as described in Section 9.

3.3 — Verification Data

To comply with anti-money laundering (AML) and responsible gambling obligations, cmbet may collect copies of identity documents, selfie images for liveness verification, proof-of-address documents and, where applicable, source-of-funds declarations. This data is collected only to the extent required for regulatory compliance.

4Lawful Basis for Processing

cmbet processes your personal data on one or more of the following lawful grounds:

Legal Basis	Examples of Processing Activity
Contract Performance	Creating and managing your Account; processing deposits and withdrawals; providing gaming services.
Legal Obligation	KYC identity verification; AML transaction monitoring; age verification (21+); regulatory reporting.
Legitimate Interests	Fraud prevention; platform security; service improvement; analytics to optimise the user experience.
Consent	Marketing communications; optional analytics cookies; participation in surveys or promotions.

5How We Use Your Data

cmbet uses the personal data we collect for the following purposes:

• Account Administration — registering, maintaining and securing your cmbet Account;
• Identity & Age Verification — confirming that you are aged 21 or above and that the information you provide is accurate;
• Payment Processing — facilitating MYR deposits and withdrawals through supported payment channels including DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, Touch 'n Go eWallet, Boost and GrabPay;
• Regulatory Compliance — meeting AML, counter-terrorist financing (CTF) and licensing obligations;
• Customer Support — responding to enquiries, resolving disputes and delivering 24/7 live chat assistance in English (Malaysia Standard Time);
• Responsible Gambling — administering deposit limits, cooling-off periods and self-exclusion requests;
• Marketing Communications — sending you relevant promotional offers and cmbet updates, where you have opted in — you may withdraw consent at any time;
• Platform Improvement — analysing usage patterns to improve navigation, performance and game selection;
• Fraud & Security — detecting and preventing fraudulent activity, account takeover attempts and misuse of the Platform.

6Data Sharing & Disclosure

cmbet does not sell or rent personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to binding data-processing or confidentiality agreements:

• Payment Processors — banks, e-wallet providers and payment gateway operators necessary to execute your transactions;
• KYC & Identity Verification Partners — third-party verification services used to fulfil our age and identity check obligations;
• Technology & Hosting Providers — cloud infrastructure, platform software and security service providers who process data under strict contractual controls;
• Regulatory & Law Enforcement Authorities — government agencies, gaming regulators or law enforcement bodies when disclosure is required by law, court order or regulatory direction;
• Licensed Game Studios — to the minimum extent necessary to deliver gameplay functionality; game providers do not receive financial account data;
• Business Successors — in the event of a merger, acquisition or restructuring of the Company, subject to equivalent data protection obligations being imposed on the successor entity.

7Data Retention

cmbet retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, accounting and regulatory requirements. Typical retention periods are as follows:

Data Category	Retention Period
Account registration information	Duration of account plus 5 years after closure
KYC & identity documents	Minimum 5 years from last transaction or account closure
Transaction records (MYR deposits & withdrawals)	Minimum 5 years from transaction date
Support correspondence	3 years from last interaction
Marketing consent records	Until withdrawal of consent, plus 2 years
Session & technical logs	Up to 13 months

After the applicable retention period, personal data is securely deleted or irreversibly anonymised, unless retention is required by a continuing legal obligation.

8Security Measures

cmbet implements a range of technical and organisational measures to protect your personal data against accidental loss, unauthorised access, disclosure, alteration or destruction. These include, but are not limited to:

• 256-bit Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest within our database systems;
• Role-based access controls limiting internal staff access to data strictly necessary for their function;
• Multi-factor authentication requirements for privileged system access;
• Regular penetration testing, vulnerability assessments and security audits;
• Formal incident response procedures covering notification timelines in the event of a data breach.

9Cookies & Tracking Technologies

9.1 — Types of Cookies Used

Cookie Type	Purpose	Retention
Strictly Necessary	Enable core Platform functions: login sessions, account security and payment flow integrity.	Session
Performance / Analytics	Measure page load times, user navigation paths and feature engagement to improve the Platform.	Up to 13 months
Functional	Remember your language preference, display settings and region (e.g. Malaysia, MYR currency display).	Up to 12 months
Marketing / Targeting	Deliver relevant cmbet promotions based on interaction history, with your consent only.	Up to 12 months

9.2 — Managing Cookies

Strictly necessary cookies cannot be disabled as they are essential to the operation of the Platform. For all other cookie categories, you may adjust your preferences through your browser settings. Please note that disabling certain cookies may impair the functionality or personalisation of your cmbet experience.

10International Data Transfers

cmbet operates under international gaming regulatory frameworks, which means some of your personal data may be processed on servers located outside Malaysia. Where such transfers occur, cmbet ensures that appropriate safeguards are in place — including contractual data-protection clauses, adequacy determinations or equivalent protective mechanisms — to provide a level of protection consistent with applicable privacy standards.

Payment data transmitted through Malaysian financial infrastructure, including DuitNow and FPX transactions, is handled in accordance with applicable Malaysian financial institution data-handling requirements.

11Your Rights

Subject to applicable law and regulatory constraints, you have the following rights regarding your personal data held by cmbet:

To exercise any of the above rights, please contact our Data Protection contact via live chat or email as detailed in Section 15. We will acknowledge your request within 5 business days and provide a substantive response within 30 days. Identity verification may be required before we can process a data request.

12Protection of Minors

cmbet is a platform intended solely for adults aged 21 and above. We do not knowingly collect, store or process personal data from individuals under the age of 21. As part of our KYC process, all Members are required to submit valid age verification documentation prior to being permitted to deposit funds or place wagers.

If cmbet becomes aware that personal data has been collected from an individual under the age of 21, that Account will be immediately suspended, the data will be deleted from our systems in accordance with our retention schedules and any funds held in the Account will be handled in accordance with applicable regulatory requirements.

13Responsible Gambling & Data

Personal data you provide when activating responsible gambling tools — including deposit limit settings, session reminder preferences and self-exclusion requests — is treated with the highest level of confidentiality. This data is processed solely for the purpose of administering and enforcing your safer-gambling choices.

Self-exclusion data is retained for the full duration of the exclusion period and for a minimum of five years thereafter, to prevent re-registration in breach of the exclusion commitment. This retention is a regulatory requirement and cannot be overridden by a deletion request during the active exclusion period.

For further information on the responsible gambling tools available at cmbet, please visit our dedicated Responsible Gambling page.

14Policy Amendments

cmbet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, applicable law or regulatory requirements. The revised Policy will be published on this page with an updated effective date. Where changes are substantive, we will notify active Members via an Account notification or a prominent in-platform notice.

Continued use of the Platform following the posting of an updated Policy constitutes acceptance of the revised terms. If you disagree with any amended provisions, you should cease using the Platform and close your Account.

15Contact Us

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by cmbet, please contact us using the following channels:

• Live Chat Support: Available 24/7 directly on the Platform — operated on Malaysia Standard Time (MYT, UTC+8)
• Email: [email protected] (plain text only — this address is not a clickable hyperlink)

For data subject access requests or formal data protection complaints, please clearly mark your communication "Data Privacy Request" to ensure it is directed to the appropriate team. We will acknowledge receipt within 3 business days and aim to provide a full response within 30 days.