Privacy Policy 33l — How We Protect Your Personal Data

This Privacy Policy explains how 33l ("we," "platform," or "33l") collects, processes, stores, and protects the personal information you provide when using our services. This document applies to all users who access the 33l platform via web browser or mobile app.

By registering or using the 33l platform, you confirm that you have read and understood this Privacy Policy. If you do not agree, please refrain from using our services.

1Introduction

At 33l, we firmly uphold the principle that user privacy is a right to be protected, not merely a regulatory obligation. We built a transparent and accountable data management system from the very first day our platform launched.

This policy is written in plain, easy-to-understand language — we avoid excessive legal jargon so every member can truly understand how their data is handled. If anything is unclear, the 33l support team is always ready to help explain.

This Privacy Policy applies in conjunction with Terms & Conditions and Responsible Gaming Guide 33l. These three documents together form the complete framework governing the relationship between members and our platform.

2Data We Collect

33l collects various types of information necessary to provide a secure, personalized, and regulation-compliant service. Below are the categories of data we collect:

3How We Use Your Data

The data we collect is used responsibly for the following purposes:

• Account Operations: Creating and managing your account, processing deposit and withdrawal transactions, and sending necessary confirmations.
• Identity Verification (KYC): Ensuring every member is a real individual who meets the age and identity requirements in accordance with regulations.
• Platform Security: Detecting and preventing suspicious activity, fraud, money laundering, and other security violations.
• Service Improvement: Analyzing usage patterns in aggregate (not individually) to improve features, performance, and the overall gaming experience.
• Communications: Sending account information, promotional notifications (if you have enabled consent), and relevant platform updates.
• Customer Support: Responding to inquiries, complaints, or assistance requests you submit to the 33l support team.
• Regulatory Compliance: Fulfilling reporting obligations to the relevant authorities in accordance with applicable laws and regulations.

4Legal Basis for Data Processing

Every processing of personal data carried out by 33l is based on one of the following legal grounds:

• Contract Performance: Processing is necessary to perform the services you have requested, including account operations and financial transactions.
• Legal Compliance: Some data must be processed to meet applicable legal obligations, such as KYC procedures and anti-money laundering reporting.
• Legitimate Interests: We process data for platform security, fraud prevention, and service improvement purposes, provided this does not infringe on your privacy rights.
• Consent: For optional activities such as sending marketing materials or the use of non-essential cookies, we request your explicit consent, which may be withdrawn at any time.

5Sharing Data with Third Parties

33l does not sell your personal data. However, under certain limited and transparent circumstances, we may need to share information with trusted third parties:

• Payment Providers: The payment gateways we use require the necessary information to securely process your financial transactions.
• Technology Service Providers: Cloud infrastructure and security partners that help us operate the platform to the highest security standards.
• Game Providers: Third-party game studios receive only the minimum session data required to run games within the 33l platform.
• Competent Authorities: We will disclose data when required by law, court order, or official request from a government authority.

6Data Security

Protecting your personal data is a responsibility we take very seriously. 33l's security infrastructure is designed in multiple layers to ensure maximum protection:

• TLS 1.3 encryption with 256-bit keys for all data transmissions.
• Encryption at rest for sensitive information.
• Intrusion detection systems (IDS/IPS) actively monitoring abnormal traffic around the clock.
• Two-factor authentication (2FA) is available and strongly recommended for all accounts.
• Regular security audits conducted by our internal team and independent third parties.
• Standardized incident response procedures to handle data breaches as swiftly as possible.

That said, no security system is 100% perfect. In the event of a security breach that significantly impacts your personal data, 33l is committed to notifying you as soon as possible in accordance with applicable reporting obligations.

7Data Storage & Retention

Personal data is retained only as long as necessary to fulfill the purpose for which it was collected or to meet applicable legal obligations. Below are the general retention periods we apply:

• Active Account Data: Retained for the duration of the active account plus 5 years after account closure, for audit and legal compliance purposes.
• Transaction History: Retained for a minimum of 7 years in accordance with applicable financial and tax regulatory requirements in Indonesia.
• KYC Data: Retained in accordance with applicable regulatory requirements, generally 5 years after the business relationship ends.
• Technical Logs: Automatically deleted after 90 days, unless a security investigation is ongoing.
• Cookie Data: In accordance with the set cookie expiry period, generally ranging from the active session up to a maximum of 12 months.

Once the retention period ends, data is permanently deleted using secure, unrecoverable deletion methods.

8Cookies & Tracking Technologies

The 33l platform uses cookies and similar technologies to enhance user experience, maintain session security, and understand how members use our services. We use several types of cookies:

• Essential Cookies: Required for core platform functions such as login, session management, and security. These cookies cannot be disabled.
• Functional Cookies: Storing your preferences such as language, display settings, and favorite game selections for a more personalized experience.
• Analytics Cookies: Helps us understand platform usage patterns in an aggregated, anonymous manner to improve our services. Can be disabled.
• Marketing Cookies: Used to display relevant promotions. Only active if you have given explicit consent.

9Member Rights Over Personal Data

As a 33l member, you have the following rights over your personal data:

10Privacy Policy Updates

This Privacy Policy may be updated from time to time to reflect changes in our practices, applicable regulatory changes, or the addition of new services. The date of the last update is always displayed at the top of this page.

For significant and material changes, 33l will provide at least 7 days' notice via registered email and/or in-platform notifications. Minor changes such as language corrections or clarifications that do not alter the substance may be made without specific notice.

Continued use of the 33l platform after an updated Privacy Policy takes effect constitutes acceptance of the latest version. We encourage you to review this page periodically.

11Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, feel free to reach out to our team:

• Privacy Email: [email protected] (not clickable — please copy manually)
• Live Chat: Available 24/7 on the 33l platform after login
• Response Time: Maximum 2 business days for general inquiries, 14 business days for data rights requests

We are committed to handling every privacy inquiry with seriousness and professionalism. The trust you place in 33l is something we never take lightly.