cly88 Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by cly88 in connection with the operation of the cly88 platform accessible at cly88.co, including the cly88 mobile applications for Android and iOS, customer support channels, and promotional communications. It applies to all registered account holders and visitors to the platform, regardless of location.

By registering a cly88 account or using the cly88 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 consent to this Policy, you should not register an account or use the cly88 platform.

This Policy should be read together with the cly88 Terms and Conditions, which are available at cly88.co/terms-conditions. Defined terms used but not defined in this Policy have the meanings given to them in the Terms and Conditions.

2. Data Controller Information

cly88 acts as the data controller in respect of personal data collected and processed through the cly88 platform. As data controller, cly88 is responsible for determining the purposes and means of processing your personal data. cly88 operates under an international gaming authority licensing framework, which imposes specific obligations on the collection, storage, and processing of player data.

For data protection enquiries, you may contact the cly88 data protection team via the support email address listed in the footer of this page. Please mark your correspondence clearly as a data protection enquiry to ensure it is routed to the appropriate team.

3. Personal Data We Collect

cly88 collects the following categories of personal data in connection with account registration, platform use, and regulatory compliance:

Identity Data:

• Full legal name as it appears on your government-issued identity document;
• Date of birth;
• Gender;
• Malaysian identity card number (MyKad) or passport number;
• Copies of identity documents submitted for KYC verification;
• Selfie photographs submitted as part of identity verification.

Contact Data:

• Email address;
• Malaysian mobile telephone number;
• Residential address (as provided for KYC verification).

Financial Data:

• Payment method details (e-wallet account identifiers, bank account numbers) used for deposits and withdrawals — note that full card numbers are not stored by cly88;
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment methods;
• Source of funds information where required by enhanced due diligence procedures.

Gaming Activity Data:

• Betting and gaming history across all cly88 products;
• Account balance history;
• Bonus and promotion participation records;
• Responsible gaming tool settings and self-exclusion records.

Technical Data:

• IP address and geolocation data derived from IP;
• Device identifiers, browser type, and operating system;
• Login timestamps and session duration data;
• Cookie and tracking technology data as described in Section 9.

4. How We Collect Your Data

cly88 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the cly88 platform, including IP addresses, device information, and session data collected via server logs and cookies;
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; geolocation data from IP intelligence services used for regulatory compliance;
• Publicly available sources: Information from public registers or databases used to verify identity or conduct due diligence where required by our licensing obligations.

5. Purposes and Legal Bases for Processing

cly88 processes your personal data for the following purposes and on the following legal bases:

• Contract performance: Processing necessary to operate your cly88 account, process deposits and withdrawals, provide gaming services, and handle support requests;
• Legal obligation: Processing required by our licensing framework, including KYC identity verification, anti-money laundering checks, age verification, and responsible gaming recordkeeping obligations;
• Legitimate interests: Fraud detection and prevention; platform security monitoring; improving platform functionality based on usage analytics; communicating service-related updates;
• Consent: Marketing communications and promotional offers, where you have opted in to receive such communications. You may withdraw consent at any time by updating your communication preferences in your account settings or by contacting support.

6. Sharing of Personal Data

cly88 does not sell personal data to third parties. We share personal data with third parties only in the following circumstances and to the extent strictly necessary:

• KYC and identity verification providers: Third-party identity verification services used to validate identity documents and confirm player identity as required by our licensing framework;
• Payment processors: Payment service providers, e-wallet operators (including Touch n Go eWallet, Boost, and GrabPay), and banking partners necessary to process deposit and withdrawal transactions;
• Fraud and AML service providers: Third-party services used to detect, prevent, and investigate fraud, money laundering, and other prohibited activity;
• Regulatory and law enforcement authorities: Disclosure required by applicable law, court order, or regulatory authority directive. cly88 will notify you of such disclosures where legally permitted to do so;
• Technology and infrastructure providers: Cloud hosting, analytics, and platform technology vendors operating under data processing agreements that bind them to equivalent data protection standards;
• Corporate transactions: In the event of a merger, acquisition, or sale of cly88 assets, personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third-party data processors engaged by cly88 are contractually required to handle personal data in accordance with applicable data protection standards and are prohibited from using your data for their own purposes.

7. International Data Transfers

cly88 operates internationally and may transfer personal data to servers and service providers located outside Malaysia. Where such transfers occur, cly88 implements appropriate safeguards to ensure that your personal data receives an equivalent level of protection to that afforded under applicable Malaysian data protection principles.

Safeguards for international transfers include: data processing agreements incorporating standard contractual clauses; transfers to jurisdictions with recognised adequate data protection standards; and technical and organisational security measures applied consistently regardless of data location.

8. Data Retention

cly88 retains personal data for the following periods:

• Active accounts: Personal data is retained for the duration of the account relationship and for a minimum of five (5) years following account closure, to meet AML, KYC, and licensing recordkeeping requirements;
• Transaction records: Financial transaction records are retained for a minimum of six (6) years following the relevant transaction, in accordance with financial recordkeeping obligations;
• Support communications: Customer support records are retained for up to three (3) years following the close of the relevant support interaction;
• Marketing data: Marketing consent records and communication preferences are retained until you withdraw consent or the account is closed, plus a further 12 months for compliance recordkeeping;
• Technical logs: Server logs and technical access records are retained for up to 12 months, unless a longer period is required for security investigation purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with cly88's data disposal procedures.

9. Cookies and Tracking Technologies

The cly88 platform uses cookies and similar tracking technologies to operate the platform, personalise your experience, and support analytics and security functions. The following categories of cookies may be used:

• Essential cookies: Required for the platform to function, including session management, authentication tokens, and security cookies. These cannot be disabled without impairing platform functionality;
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations;
• Analytics cookies: Used to collect aggregated data on platform usage patterns to help improve the cly88 platform. Data collected is anonymised or pseudonymised;
• Security cookies: Used for fraud detection, bot detection, and to protect the platform and its users from security threats.

You may manage cookie preferences through your browser settings. Disabling essential cookies will affect your ability to use the cly88 platform. cly88 does not use third-party advertising or behavioural targeting cookies.

10. Your Data Subject Rights

Subject to applicable law and the limitations imposed by our licensing and legal obligations, you have the following rights in relation to your personal data held by cly88:

• Right of access: You may request a copy of the personal data cly88 holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data;
• Right to erasure: You may 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 restrict processing: You may request that we restrict processing of your data in certain circumstances;
• Right to data portability: You may request a structured, machine-readable copy of personal data you have provided to cly88, where processing is based on consent or contract;
• Right to object: You may object to processing based on legitimate interests where your individual circumstances warrant it;
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact cly88 via the support email address in the footer of this page with the subject line "Data Subject Request". We will respond within 30 calendar days. Standard requests are handled free of charge. For manifestly unfounded or excessive requests, cly88 reserves the right to charge a reasonable administrative fee.

11. Children and Underage Users

The cly88 platform is strictly for users aged 21 and above. cly88 does not knowingly collect personal data from persons under the age of 21. Age verification is a mandatory condition of account registration and is enforced throughout the account lifecycle.

If cly88 becomes aware that personal data has been collected from a person under the age of 21, the account will be immediately suspended, all data will be deleted (except to the extent required for legal and regulatory purposes), and the matter will be escalated to the compliance team for investigation.

If you believe a person under 21 has registered a cly88 account, please notify us immediately at the support email address in the footer of this page.

12. Security Measures

cly88 implements appropriate technical and organisational measures to protect personal data against accidental loss, destruction, alteration, unauthorised disclosure, and unauthorised access. These measures include:

• SSL/TLS encryption for all data transmitted between your device and cly88 servers;
• Encryption of sensitive data at rest, including identity documents and payment details;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Incident response procedures for detecting, containing, and notifying affected parties in the event of a data breach;
• Staff data protection training and confidentiality obligations.

Notwithstanding these measures, no system is completely immune from security risks. cly88 cannot guarantee absolute security of data transmitted over the internet. You are responsible for maintaining the security of your cly88 login credentials and for notifying cly88 immediately if you suspect unauthorised access to your account.

13. Changes to This Policy

cly88 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or platform features. Material changes will be communicated to registered account holders via the email address on file at least seven (7) calendar days before the updated Policy takes effect. The date of the most recent revision is displayed at the top of this page.

Continued use of the cly88 platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you must cease using the platform and may request account closure.

14. Contact and Complaints

For data protection enquiries, data subject requests, or privacy-related complaints, please contact the cly88 data protection team via the support email address displayed in the footer of this page. Please include "Privacy Policy" or "Data Subject Request" in the subject line to ensure prompt routing to the appropriate team.

cly88 will acknowledge all privacy enquiries within five (5) business days and provide a substantive response within 30 calendar days. If you are dissatisfied with our response to a privacy complaint, you may escalate the matter to the relevant data protection authority in your jurisdiction or to the regulatory body overseeing our licensing framework.