Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by Sayap33 ("we", "us", "our", "the Company", "the Platform") and governs the collection, use, storage, disclosure, and protection of personal data provided by or collected from individuals ("you", "User", "Player", "Member") who access or use the Sayap33 online casino and sports betting platform at sayap33.cam and all associated services.

Sayap33 recognises that the privacy and security of your personal information is of paramount importance, particularly given the sensitive nature of financial transactions and identity verification required for online gambling services. We are committed to handling all personal data responsibly, transparently, and in accordance with applicable data protection principles.

By registering an account with Sayap33, making a deposit, or otherwise using our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to the terms of this Policy, you must cease using the Sayap33 platform immediately.

2. Definitions

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

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, either directly or in combination with other available data, including but not limited to name, identification number, contact information, financial account details, and online identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, alteration, retrieval, consultation, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" means Sayap33, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" means a third party engaged by Sayap33 to process personal data on Sayap33's behalf, under binding contractual and confidentiality obligations.
• "Sensitive Personal Data" means a subset of personal data attracting heightened protection, including government-issued identity document numbers (e.g., Malaysian MyKad number), financial account details, and transaction history.
• "KYC Data" means Know Your Customer documentation submitted by Players for identity and address verification, including copies of government-issued identification and proof of residential address.
• "Cookies" means small text files placed on your device by the Sayap33 platform for the purpose of maintaining session state, analytics, personalisation, and security monitoring.
• "Services" means the online casino games, sports betting markets, VIP programme, customer support, and all other features and functions available through the Sayap33 platform.

3. Data We Collect

3.1 Data You Provide Directly

Sayap33 collects personal data that you voluntarily provide during the course of registering and using our Services, including:

• Registration Data: Full legal name, date of birth, gender, residential address (including city — e.g., Kuala Lumpur, Petaling Jaya, Johor Bahru, Shah Alam, Penang), email address, and mobile phone number;
• KYC Documentation: Malaysian National Identity Card (MyKad) number and scanned images (front and back), or equivalent government-issued passport; proof of residential address (utility bill or bank statement dated within 90 days);
• Payment Data: Bank account details, e-wallet account identifiers (Touch 'n Go eWallet, Boost, GrabPay, DuitNow/FPX account references), and cryptocurrency wallet addresses (BTC, USDT) where applicable. Sayap33 does not store full card numbers or CVV codes;
• Account Preferences: Responsible gambling settings including deposit limits, session time limits, and self-exclusion elections;
• Customer Support Communications: Transcripts of live chat conversations, emails, and support tickets submitted to our team.

3.2 Data Collected Automatically

When you access the Sayap33 platform, we automatically collect certain technical and behavioural data, including:

• Internet Protocol (IP) address and approximate geolocation (country, state, city);
• Device type, operating system, browser type and version;
• Session timestamps, page navigation paths, and feature interaction logs;
• Game play history, betting activity, wagering patterns, and transaction logs;
• Referral source data (how you arrived at the Sayap33 platform);
• Cookie identifiers and similar tracking technologies.

3.3 Data from Third Parties

In limited circumstances, Sayap33 may receive personal data about you from third-party sources, including:

• Identity verification and fraud screening service providers engaged to validate KYC documentation;
• Payment processors and Malaysian banking partners (Maybank, CIMB, Public Bank, RHB, Hong Leong) confirming transaction status and account ownership;
• Responsible gambling databases where a Player has registered a self-exclusion with a third-party programme.

4. How We Use Your Personal Data

Sayap33 uses the personal data we collect for the following purposes:

5. Legal Basis for Processing

Sayap33 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms and Conditions you accepted upon registration — including account management, payment processing, and delivery of gaming Services;
• Legal Obligation: Processing required to comply with applicable legal requirements, including KYC/AML obligations, tax reporting requirements, and responsible gambling regulations;
• Legitimate Interests: Processing necessary for Sayap33's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests do not override your fundamental privacy rights;
• Consent: Processing of your data for marketing communications and non-essential cookies, where you have provided explicit, informed consent that may be withdrawn at any time.

6. Data Sharing & Disclosure

6.1 Categories of Recipients

Sayap33 does not sell, rent, or trade your personal data to any third party for commercial purposes. We may disclose your personal data only to the following categories of recipients, and only to the extent necessary for each stated purpose:

• Payment Service Providers: Malaysian banking partners and e-wallet operators (including Touch 'n Go eWallet, Boost, GrabPay, DuitNow/FPX systems, Maybank, CIMB, Public Bank, RHB, Hong Leong) for the purpose of processing deposits and withdrawals;
• Identity Verification Services: Third-party KYC and AML screening providers engaged to validate player identity documents and screen against regulatory databases;
• Technology and Hosting Partners: Cloud infrastructure and data hosting providers who process data on Sayap33's behalf under binding data processing agreements;
• Game Software Providers: Licensed game studios and live casino operators whose products are integrated into the Sayap33 platform, where game play data must be transmitted for game delivery purposes;
• Analytics Providers: Web analytics platforms that process anonymised or pseudonymised session and behaviour data to assist Sayap33 in improving platform performance;
• Legal and Regulatory Authorities: Government bodies, law enforcement agencies, regulatory authorities, and courts where Sayap33 is legally required to disclose personal data by applicable law, court order, or regulatory direction.

6.2 Business Transfers

In the event of a merger, acquisition, asset sale, or restructuring of the Sayap33 business, personal data held by Sayap33 may be transferred to the acquiring or successor entity, subject to equivalent privacy protections remaining in place. Sayap33 will notify affected Players of any such transfer where legally required to do so.

7. International Data Transfers

Given the global nature of online gaming infrastructure and some of our third-party service providers, your personal data may be transferred to, stored in, or processed in jurisdictions outside of Malaysia. Where such transfers occur, Sayap33 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual data processing agreements with all third-party processors incorporating standard data protection clauses;
• Requiring all international processors to maintain security standards equivalent to those described in Section 10 of this Policy;
• Limiting international data transfers to countries or processors that provide an adequate level of data protection as assessed by Sayap33's compliance team.

For Malaysian residents, Sayap33 notes that the processing of personal data by Malaysian payment providers (Maybank, CIMB, Public Bank, DuitNow, FPX, Touch 'n Go eWallet, Boost) occurs within Malaysia and is subject to applicable Malaysian financial regulations.

8. Data Retention

Sayap33 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following retention periods apply as general guidance:

• Account and Registration Data: Retained for the duration of your active account plus a minimum of 5 years following account closure, in compliance with AML record-keeping obligations;
• KYC Documentation: Retained for a minimum of 5 years following the completion of the KYC process or account closure, whichever is later;
• Transaction Records: Retained for a minimum of 7 years in compliance with applicable financial record-keeping requirements;
• Customer Support Communications: Retained for 3 years following resolution of the relevant support interaction;
• Marketing Consent Records: Retained for the duration of the consent relationship plus 2 years following withdrawal of consent;
• Anonymised Analytics Data: Retained indefinitely in anonymised form for platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original personal data.

9. Cookies & Tracking Technologies

9.1 Types of Cookies Used

The Sayap33 platform uses the following categories of cookies and similar tracking technologies:

• Strictly Necessary Cookies: Essential for the operation of the platform, including session management, authentication, and security functions. These cannot be disabled without preventing use of the Services.
• Functional Cookies: Store your preferences such as language settings, responsible gambling tool configurations, and account display preferences to provide a personalised experience.
• Analytics Cookies: Collect anonymised data about how Players navigate and interact with the platform, used to improve performance and user experience. These require your consent.
• Marketing Cookies: Used to deliver relevant promotional content and track the effectiveness of our marketing campaigns. These require your explicit consent and may be disabled at any time.

9.2 Managing Your Cookie Preferences

You may manage your cookie preferences through your browser settings or through the Sayap33 cookie preference centre where available. Please note that disabling certain categories of cookies may affect the functionality and performance of the Sayap33 platform. Strictly necessary cookies cannot be disabled as they are required for the operation of the Services.

10. Data Security

Sayap33 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the Sayap33 platform is encrypted using industry-standard Secure Socket Layer protocol;
• Encryption at Rest: Sensitive personal data stored in our databases is encrypted at rest using AES-256 or equivalent encryption standards;
• Access Controls: Strict role-based access controls limit access to personal data to only those Sayap33 employees and contractors who require it to perform their job functions, subject to confidentiality obligations;
• Two-Factor Authentication (2FA): Available and encouraged for all Sayap33 Accounts to prevent unauthorised access;
• Real-Time Fraud Monitoring: Automated systems monitor account activity for signs of fraudulent behaviour, account takeover attempts, and unusual transaction patterns;
• Regular Security Audits: Sayap33's platform and data infrastructure are subject to periodic internal and external security reviews and penetration testing.

Despite these measures, no online platform can guarantee absolute security against all possible threats. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, Sayap33 will notify affected Players without undue delay in accordance with applicable notification requirements.

11. Your Data Protection Rights

Subject to applicable law and Sayap33's legal obligations, you have the following rights in relation to your personal data:

12. Minors & Age Policy

The Sayap33 platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. All account registrations are subject to age verification as part of our KYC process.

If Sayap33 discovers that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and permanently close the associated Account. If you have reason to believe that a minor has registered an account on the Sayap33 platform, please contact us immediately via live chat or at [email protected] so that we can investigate and take appropriate action.

13. Third-Party Links & Services

The Sayap33 platform may contain references to or integrations with third-party services, including licensed game providers, payment processors, and responsible gambling resources. This Privacy Policy applies solely to personal data processed by Sayap33 in connection with the Sayap33 platform and Services. Sayap33 is not responsible for the privacy practices of third-party services and recommends that you review the applicable privacy policy of any third-party service with which you interact.

In particular, when making payments via Malaysian e-wallet providers (Touch 'n Go eWallet, Boost, GrabPay) or banking channels (Maybank, CIMB, Public Bank, DuitNow, FPX), the data you provide directly to those providers is governed by their own respective privacy policies and not by this document.

14. Policy Amendments

Sayap33 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. Where material changes are made, Sayap33 will provide reasonable notice to registered Players via the email address associated with their Account or via a prominent notice on the Sayap33 platform.

The current version of this Privacy Policy is always available on this page and is identified by the "Last Updated" date at the top of the document. Continued use of the Sayap33 platform following the publication of an updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree to a material change in how your data is processed, you may request account closure in accordance with the Terms and Conditions.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Sayap33, please contact our Data Protection team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the Sayap33 website — our fastest response channel.
• Email: [email protected] — for privacy-related requests, please include "Privacy Request" in your subject line. We aim to acknowledge all requests within 48 hours and provide a substantive response within 30 calendar days.

For general enquiries about your Sayap33 Account, payments, bonuses, or responsible gambling tools, please visit our FAQ page or contact our 24/7 Malaysian customer support team via live chat.