super22 Privacy Policy

1. Data Controller

super22 ("we", "us", "our", "the Company") is the data controller responsible for the personal information collected through the super22 platform at super22.club (the "Platform"). As data controller, super22 determines the purposes and means of processing your personal data in connection with the products and services we provide, including online casino games, sports betting, and related account and payment services.

By registering an account or otherwise using the super22 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal data as described herein. If you do not agree with this Privacy Policy, you must discontinue use of the Platform immediately.

2. Personal Data We Collect

In the course of providing the super22 Platform and its services, we may collect the following categories of personal data:

Category	Examples
Identity Data	Full legal name, date of birth, nationality, government-issued ID number
Contact Data	Email address, phone number, residential address (including city, state, postcode)
Account Data	Username, encrypted password, account preferences, communication settings
Financial Data	Payment method details (bank account numbers, e-wallet identifiers), transaction history, deposit and withdrawal records
Gaming Data	Bet history, game preferences, session duration, win/loss records, bonus activity
Technical Data	IP address, browser type and version, device identifiers, operating system, time zone, cookie data
Usage Data	Pages visited, features used, clickstream data, search queries within the Platform
Communications Data	Support chat transcripts, email correspondence, feedback submissions
Verification Data	Copies of identity documents, proof of address, source-of-funds documentation submitted during KYC procedures

super22 does not knowingly collect sensitive personal data (such as data relating to racial or ethnic origin, religious beliefs, health status, or biometric data) unless required to do so by applicable law or our licensing obligations.

3. How We Collect Your Data

super22 collects personal data through the following means:

• Direct Interactions. When you register an account, make a deposit or withdrawal, contact customer support, complete KYC verification, or participate in promotions on the super22 Platform, you directly provide us with personal data.
• Automated Technologies. When you access the Platform, we automatically collect Technical Data and Usage Data via cookies, server logs, pixel tags, and similar tracking technologies. See Section 10 (Cookies) for further details.
• Third-Party Sources. We may receive personal data about you from third-party payment processors (such as FPX, Touch 'n Go eWallet, Boost, and Malaysian banking partners), identity verification service providers, fraud prevention agencies, and analytics providers, for the purposes described in this Policy.
• Publicly Available Sources. In limited circumstances, we may supplement our records with data from publicly available sources, including government databases, for the purpose of fulfilling our anti-money-laundering obligations.

4. How We Use Your Personal Data

super22 processes your personal data for the following purposes:

• Account Management. To create, maintain, and manage your super22 account, authenticate your identity, and enforce account security.
• Service Delivery. To provide access to games, process bets and transactions, credit winnings, and deliver bonuses and promotions.
• Payment Processing. To facilitate deposits and withdrawals via your chosen payment method (including DuitNow, Maybank, CIMB, Public Bank, Touch 'n Go eWallet, Boost, and others), and to comply with financial crime prevention obligations.
• Regulatory Compliance. To fulfil our obligations under our international gaming authority licence, including age verification, identity verification (KYC), anti-money-laundering (AML) checks, and responsible gaming requirements.
• Customer Support. To respond to your enquiries, resolve disputes, and provide technical assistance.
• Fraud Prevention & Security. To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other conduct that violates our Terms and Conditions.
• Platform Improvement. To analyse how members use the super22 Platform, identify technical issues, improve the user experience, and develop new features.
• Marketing Communications. Where you have provided consent or where permitted by applicable law, to send you promotional communications about super22 offers, bonuses, and events. You may opt out at any time by contacting support or updating your account notification preferences.
• Responsible Gaming. To monitor gaming activity for indicators of problem gambling and, where appropriate, to proactively apply player-protection measures in accordance with our licensing obligations.

5. Legal Basis for Processing

super22 relies on the following legal bases for processing your personal data:

• Contract Performance. Processing necessary to perform our contract with you (i.e., providing the super22 Platform and its services).
• Legal Obligation. Processing required to comply with applicable law, including our gaming licence obligations, AML regulations, and tax reporting requirements.
• Legitimate Interests. Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your fundamental rights.
• Consent. Processing based on your freely given, specific, and informed consent, principally for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. Data Sharing and Disclosure

super22 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors. Third-party payment service providers (including FPX facilitators, Touch 'n Go eWallet, Boost, and partner banks) to process financial transactions on your behalf.
• Identity Verification Providers. KYC and AML service providers who assist us in verifying your identity and complying with our licensing obligations.
• Game Providers. Certified game studios and live dealer operators whose content is integrated into the super22 Platform. These providers receive only the data necessary to deliver game content and record game outcomes.
• Regulatory Authorities. Gaming regulators, law enforcement agencies, and courts where disclosure is required by applicable law, regulation, legal process, or a valid order from a competent authority.
• Technology & Analytics Partners. Service providers who assist us in operating and improving the Platform, including hosting, security monitoring, and analytics services. All such providers are contractually bound to process your data only on our documented instructions.
• Group Companies. Affiliated entities within the super22 corporate group, where necessary for internal administration, compliance, or the delivery of our services.

7. Data Retention

super22 retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and our regulatory obligations. In general:

• Account and transaction data is retained for a minimum of five (5) years following account closure, in accordance with anti-money-laundering record-keeping requirements.
• KYC verification documents are retained for the period required by our gaming authority licence, which typically mirrors AML record-keeping obligations.
• Communications data (support transcripts, emails) is retained for up to three (3) years for dispute resolution and quality assurance purposes.
• Technical and usage data collected via cookies may be retained for shorter periods as set out in our cookie management settings.

When your personal data is no longer required for the purposes for which it was collected, and no legal obligation requires its retention, super22 will securely delete or anonymise it.

8. Security Measures

super22 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include 256-bit SSL/TLS encryption for all data transmitted to and from the Platform, encrypted storage of sensitive data at rest, access controls restricting personal data access to authorised personnel only, regular security assessments and penetration testing, and incident response procedures to address potential data breaches promptly. While we apply industry-standard safeguards, no data transmission or storage system can be guaranteed to be 100% secure. If you suspect that your account has been compromised, please contact super22 customer support immediately.

9. Your Rights

Subject to applicable law, you have the following rights in relation to the personal data super22 holds about you:

• Access. The right to request a copy of the personal data we hold about you.
• Rectification. The right to request that inaccurate or incomplete personal data be corrected.
• Erasure. The right to request deletion of your personal data where there is no compelling reason for its continued processing, subject to our legal retention obligations.
• Restriction. The right to request that we restrict processing of your personal data in certain circumstances.
• Portability. The right to receive personal data you have provided to us in a structured, commonly used, machine-readable format, where processing is based on consent or contract.
• Objection. The right to object to processing of your personal data based on our legitimate interests, including for direct marketing purposes.
• Withdraw Consent. The right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact super22 via live chat or by emailing [email protected]. We will respond to verified requests within 30 days. We may require you to verify your identity before processing a rights request.

10. Cookies and Tracking Technologies

super22 uses cookies and similar technologies to operate the Platform, remember your preferences, analyse traffic patterns, and deliver relevant promotions. The main categories of cookies we use are:

• Essential Cookies. Required for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and payment flows.
• Performance & Analytics Cookies. Collect anonymised data about how visitors interact with the Platform, allowing us to identify improvements.
• Functional Cookies. Remember your preferences (e.g., language, display settings) to personalise your experience.
• Marketing Cookies. Used, with your consent, to deliver relevant promotions and measure the effectiveness of marketing campaigns.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the core features of the super22 Platform.

11. Minors

The super22 Platform is strictly intended for persons aged 21 and above. We do not knowingly collect or process personal data from individuals under the age of 21. If we become aware that a person under 21 has provided personal data, we will take immediate steps to close the account and delete the data. If you believe a minor has accessed the Platform, please notify us immediately at [email protected].

12. International Data Transfers

super22 may process and store your personal data in countries other than Malaysia, including countries where our technology infrastructure, game providers, and service partners are based. When transferring personal data internationally, super22 ensures that appropriate safeguards are in place — such as standard contractual clauses approved by applicable data protection authorities — to protect your data to the same standard required under this Privacy Policy and applicable Malaysian data protection law.

13. Changes to This Privacy Policy

super22 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, our data practices, or our services. Material changes will be communicated to registered members by email or via a prominent notice on the Platform at least seven (7) days before the amended policy takes effect. Your continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Privacy Policy. We encourage you to review this page periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way super22 handles your personal data, please contact our privacy team via live chat (available 24/7 through the Platform) or by email at: [email protected]. We are committed to resolving all privacy queries promptly and transparently.