Privacy Policy – pantas33

This Privacy Policy ("Policy") describes how pantas33 ("we", "us", "our"), the operator of the platform accessible at pantas33.club, collects, processes, stores, and protects personal data provided by or generated through users ("you", "Member") of the pantas33 Platform. This Policy forms part of and should be read alongside the pantas33 Terms & Conditions. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

pantas33 takes its data protection obligations seriously and operates in accordance with internationally recognised data protection principles, including purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

1. Data Controller

pantas33 is the data controller in respect of personal data collected through the pantas33 Platform. As data controller, pantas33 determines the purposes and means by which your personal data is processed. All data protection queries, subject access requests, and complaints should be directed to the pantas33 data protection contact identified in Section 14 of this Policy.

2. Personal Data We Collect

pantas33 collects the following categories of personal data from Members and prospective Members:

• Identity Data: Full legal name, date of birth, nationality, and copies of government-issued identity documents (e.g., MyKad, passport) provided during the Know Your Customer (KYC) verification process.
• Contact Data: Email address, mobile phone number, and residential address.
• Account Data: Username, account number, account registration date, account status, and login history.
• Financial Data: Payment method details (e.g., Touch 'n Go eWallet account identifier, FPX bank association, Boost or GrabPay account reference), transaction history, deposit and withdrawal records, and balance information. pantas33 does not store full payment instrument credentials such as bank account numbers or card numbers directly.
• Gaming Data: Game session records, wagering history, bonus utilisation, win/loss records, and responsible gaming tool settings (e.g., deposit limits, session time limits, self-exclusion status).
• Technical Data: IP address, device identifier, browser type and version, operating system, referring URL, and session timestamps.
• Communications Data: Records of live chat interactions, email correspondence, and support tickets submitted to the pantas33 support team.
• Verification Data: Source-of-funds documentation and any additional documentation submitted in response to an anti-money laundering (AML) or enhanced due diligence request.

3. How We Collect Personal Data

pantas33 collects personal data through the following channels:

• Direct provision: Data you submit when registering an account, completing KYC, making a deposit or withdrawal request, contacting support, or participating in a promotion.
• Automated technologies: Technical data collected automatically when you access and interact with the Platform, including through the use of cookies and similar tracking technologies (see Section 10).
• Third-party payment providers: Transaction confirmation data received from payment providers such as Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect when you initiate a deposit or withdrawal.
• Identity verification services: Data returned by third-party KYC and age verification service providers used by pantas33 to validate the identity and age of Members.
• Fraud prevention services: Risk scoring data provided by third-party fraud detection providers used to protect the integrity of the Platform and its Members.

4. Purposes of Processing

pantas33 processes your personal data for the following purposes:

• Registering and managing your pantas33 account, including verifying your identity and age in compliance with responsible gaming requirements.
• Processing deposits and withdrawals and maintaining accurate financial records of all transactions.
• Delivering and improving the gaming services, including personalising the game lobby based on your play history.
• Administering bonuses, promotions, and loyalty programmes and verifying eligibility for promotional offers.
• Complying with anti-money laundering, counter-terrorism financing, and responsible gaming obligations, including monitoring for unusual transaction patterns and enforcing self-exclusion restrictions.
• Providing customer support and responding to queries, complaints, and disputes.
• Communicating service updates, security notices, and, where you have provided your consent, promotional communications.
• Detecting, investigating, and preventing fraud, cheating, collusion, and other prohibited conduct on the Platform.
• Maintaining the security and integrity of the Platform infrastructure.
• Fulfilling any legal or regulatory obligation to which pantas33 is subject.

5. Legal Basis for Processing

pantas33 relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing required to perform the contract between you and pantas33, including account management, transaction processing, and game delivery.
• Legal obligation: Processing required to comply with applicable anti-money laundering, responsible gaming, and data retention laws and regulations.
• Legitimate interests: Processing carried out in pursuit of pantas33's legitimate interests, including fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including the sending of marketing communications. You may withdraw your consent at any time by contacting support.

6. Data Sharing and Disclosure

pantas33 does not sell your personal data to third parties. We may share your personal data in the following circumstances:

• Service providers: Third-party vendors engaged to provide services on behalf of pantas33, including payment processors, identity verification providers, fraud detection services, cloud infrastructure providers, and customer support platform operators. All service providers are bound by contractual data protection obligations.
• Game providers: Licensed game studios whose content is accessible through the pantas33 Platform may receive session-level technical data necessary for game delivery. Game providers do not receive your full identity or financial data.
• Regulatory and law enforcement authorities: Where pantas33 is required by applicable law, court order, or regulatory direction to disclose personal data, we will comply. Where permitted, we will notify you of such disclosure.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of pantas33's business assets, your personal data may be transferred to the acquiring entity, subject to the protections described in this Policy.

7. International Data Transfers

pantas33 may transfer your personal data to service providers and infrastructure partners located outside Malaysia. Where such transfers occur, pantas33 ensures that appropriate safeguards are in place, including contractual data protection clauses equivalent to internationally recognised standards. By using the pantas33 Platform, you consent to such transfers subject to the protections described in this Policy.

8. Data Retention

pantas33 retains personal data for as long as your account remains active and for a period thereafter as required to fulfil our legal and regulatory obligations. Specifically:

• Account and KYC data is retained for a minimum of five years following account closure, in accordance with AML record-keeping requirements.
• Transaction records are retained for a minimum of seven years.
• Support communications are retained for two years from the date of the last interaction.
• Technical logs are retained for up to 12 months and are used exclusively for security and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data destruction procedures.

9. Security Measures

pantas33 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include 256-bit SSL/TLS encryption for all data in transit, encrypted storage for sensitive data at rest, access controls restricting data access to authorised personnel on a need-to-know basis, regular security assessments and penetration testing of the Platform infrastructure, and staff training on data protection and information security obligations.

No data transmission or storage system can be guaranteed to be 100% secure. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, pantas33 will notify you in accordance with applicable breach notification obligations.

10. Cookies and Tracking Technologies

pantas33 uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies used include:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management and security. These cannot be disabled.
• Functional cookies: Used to remember your preferences and personalise your experience, such as game lobby sorting preferences.
• Analytics cookies: Used to understand how Members interact with the Platform in aggregate, enabling us to improve performance and usability. Analytics data is processed in anonymised or pseudonymised form.

You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

11. Your Data Protection Rights

Subject to applicable law, you have the following rights in respect of your personal data held by pantas33:

• Right of access: The right to request a copy of the personal data pantas33 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to restriction: The right to request that pantas33 restricts the processing of your personal data in certain circumstances.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format where processing is based on consent or contractual necessity.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact pantas33 as described in Section 14. pantas33 will respond to all verifiable requests within 30 days. We may require identity verification before processing a request.

12. Children's Privacy

The pantas33 Platform is strictly for adults aged 21 and above. pantas33 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an underage individual, we will delete that data promptly and close any associated account. If you believe that an underage person has registered on the Platform, please notify us immediately via the support contact in Section 14.

13. Changes to This Policy

pantas33 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. The revised Policy will be published on this page with an updated "Last Updated" date. Where changes are material, we will provide notice via the Platform or by email to your registered address. Continued use of the Platform following publication of a revised Policy constitutes acceptance of the updated terms.

14. Contact and Complaints

For all data protection queries, subject access requests, or complaints, please contact the pantas33 data protection team via:

• Live Chat: Available 24/7 on-site at pantas33.club
• Email: [email protected] (plain text — not a clickable link)

pantas33 will acknowledge all formal data protection complaints within 5 business days and aims to resolve complaints within 30 days. If you are not satisfied with our response, you may escalate your complaint to the relevant data protection supervisory authority in your jurisdiction.