Privacy Policy

This Privacy Policy (hereinafter "the Policy") describes how tompel69 (the "Company", "Platform", "we", "us", or "our"), operating at https://tompel69.cam, collects, uses, processes, stores, and discloses personal data relating to individuals (the "User", "Member", "Player", or "you") who access or use the tompel69 online casino and sports betting platform.

tompel69 takes data privacy seriously. We serve players across Malaysia — including those in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam — and we are committed to handling all personal data responsibly, transparently, and in compliance with applicable data protection principles.

This Policy should be read together with our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference. By registering an account or continuing to use the tompel69 platform, you acknowledge that you have read and understood this Policy.

For the purposes of this Policy, the following definitions apply:

• "Personal Data" — any information that identifies or can be used to identify a living natural person, directly or indirectly (e.g., name, identification number, email address, IP address, payment details).
• "Processing" — any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — tompel69, as the entity that determines the purposes and means of processing personal data.
• "Data Processor" — a third party that processes personal data on behalf of tompel69 under a formal data processing agreement.
• "Consent" — any freely given, specific, informed, and unambiguous indication of the data subject's agreement to the processing of their personal data.
• "KYC" — Know Your Customer; the identity and address verification process required under our compliance obligations.
• "Sensitive Data" — a subset of personal data requiring heightened protection, including government-issued identification numbers, financial account details, and biometric data.

tompel69 collects personal data in the following categories. Collection is limited to what is necessary for the stated purposes (data minimisation principle):

tompel69 collects personal data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit, requesting a withdrawal, or contacting our support team.
• Automated technical collection: Data collected automatically when you access the platform, including IP address, browser fingerprint, device identifiers, and navigation behaviour via cookies and similar technologies.
• Payment partners: Transaction confirmation data received from Malaysian payment providers including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and Hong Leong.
• Identity verification providers: Confirmation responses from third-party KYC and anti-fraud service providers we engage for compliance purposes.
• Publicly available sources: In cases where fraud prevention or compliance requires it, we may consult publicly available records such as sanctions lists or politically exposed persons (PEP) databases.

tompel69 processes personal data for the following defined purposes. We do not process personal data for any purpose incompatible with those listed below:

1. Account creation and management — to register, maintain, and operate your tompel69 member account.
2. Identity and age verification — to confirm that users meet the minimum age requirement of 21 years and to fulfil KYC obligations.
3. Payment processing — to facilitate deposits and withdrawals in MYR via your chosen Malaysian payment channel.
4. Regulatory compliance and AML — to comply with anti-money laundering (AML), counter-terrorism financing (CTF), and related regulatory obligations.
5. Fraud prevention and security — to detect, investigate, and prevent fraudulent transactions, account abuse, and platform security threats.
6. Customer support — to respond to your queries, complaints, and requests via live chat, email, or messaging platforms.
7. Responsible gambling monitoring — to identify patterns of play that may indicate problem gambling behaviour and to enforce self-exclusion or deposit limit requests.
8. Platform improvement — to analyse usage patterns and improve the functionality, design, and performance of the tompel69 platform.
9. Marketing communications — to send promotional offers, bonus notifications, and platform news to users who have opted in to receive such communications.

Each processing activity conducted by tompel69 is based on one of the following lawful grounds:

• Contract performance: Processing necessary to deliver the gaming and sports betting services you have registered to use, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable laws, including KYC, AML, and financial crime regulations.
• Legitimate interest: Processing carried out for fraud prevention, platform security, customer service quality improvement, and responsible gambling monitoring, where such interests do not override your fundamental rights.
• Consent: Processing for marketing communications and non-essential cookies, where we have obtained your explicit, informed, and freely given consent. You may withdraw consent at any time.

tompel69 does not sell, rent, or commercially trade your personal data. We may share your personal data only in the following limited circumstances and only with appropriate safeguards in place:

• Payment service providers: Malaysian payment partners (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong) receive the minimum data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party compliance service providers that assist with identity verification, document validation, and sanctions screening.
• Game content providers: Game studios that supply casino and sportsbook content to the platform may receive pseudonymised session data for game operation and dispute resolution purposes.
• Regulatory and law enforcement authorities: We will disclose personal data to government agencies, regulators, or law enforcement bodies where required to do so by applicable law, court order, or valid regulatory direction.
• Anti-fraud networks: Anonymised or aggregated fraud-related data may be shared with industry fraud prevention networks to protect the integrity of the online gaming ecosystem.
• Corporate transactions: In the event of a merger, acquisition, or asset sale, personal data may be transferred to the acquiring entity subject to equivalent privacy protections.

tompel69 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. Key retention periods are set out below:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be associated with an identifiable individual.

tompel69 uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain your session, and analyse how the platform is used. The following categories of cookies are deployed:

• Strictly necessary cookies: Required for the platform to function. These include session authentication tokens and security cookies. They cannot be disabled without affecting platform operation.
• Functional cookies: Enable personalisation features such as language preferences, session duration settings, and remembered account login state.
• Analytical cookies: Collect anonymised data about user behaviour — pages visited, time spent, and navigation flows — to help us improve the platform experience.
• Marketing cookies: Used to track whether you arrived at tompel69 via an affiliate link or promotional campaign. These are set only with your consent.

As a data subject, you hold the following rights with respect to the personal data tompel69 processes about you. To exercise any of the rights below, please contact our support team with your account details and a description of your request.

tompel69 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, and destruction. Our security framework includes:

• Encryption at rest: All personal data stored on our servers is encrypted using AES-256 symmetric encryption.
• Encryption in transit: All data transmitted between your Device and the tompel69 platform is protected by TLS 1.3 (Transport Layer Security).
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis with role-based access controls (RBAC) and multi-factor authentication for all staff.
• Penetration testing: Our platform undergoes regular third-party security audits and penetration testing to identify and remediate vulnerabilities.
• Incident response: We maintain a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify you and relevant authorities within applicable regulatory timeframes.

The tompel69 platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data belonging to any person under the age of 21. If we become aware that personal data has been collected from a person below the minimum age, we will take immediate steps to delete that data and close the associated account.

If you have reason to believe that a minor has registered an account on tompel69 using false information, please contact our support team immediately at [email protected] with relevant details.

In certain circumstances, the operation of the tompel69 platform may require the transfer of personal data to service providers located outside Malaysia. Where such transfers occur, tompel69 ensures that appropriate safeguards are in place, including:

• Contractual data processing agreements incorporating standard data protection clauses with all international processors
• Transfer to jurisdictions that maintain an equivalent or higher standard of data protection
• Encryption of data prior to any international transfer where technically feasible

International transfers are limited to what is strictly necessary and are always governed by a documented data processing agreement.

tompel69 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or operational requirements. Where changes are material, we will notify registered users via email or a prominent notice on the platform prior to the changes taking effect.

The "Effective Date" displayed at the top of this page indicates the date of the most recent revision. We recommend reviewing this Policy periodically to stay informed of how your personal data is being handled.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the tompel69 Data Privacy team using the details below. All privacy-related requests are handled with priority and acknowledged within 5 business days.