Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how gemebet ("we", "us", "our", "the Platform") collects, uses, stores, shares and protects personal data relating to users ("you", "the User", "the Player") of the gemebet website accessible at gemebet.cam and any associated mobile interfaces, applications or services.

gemebet is an online sports betting and live casino platform serving players across Malaysia, including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya and Shah Alam. As a platform that processes financial transactions and conducts identity verification, we handle personal data responsibly and in accordance with applicable international data protection standards.

By accessing the Platform, creating an Account, depositing funds or otherwise using our services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must immediately cease using the Platform.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall use of the gemebet platform.

2 Definitions

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

• "Personal Data" — any information that identifies or could reasonably be used to identify a natural person, directly or indirectly, including name, email address, payment details, device identifiers and IP addresses.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For all data collected via the gemebet Platform, the Data Controller is gemebet.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller, under documented instruction and subject to appropriate contractual safeguards.
• "KYC" — Know Your Customer verification procedures, including identity document submission and address verification, required for regulatory compliance and withdrawal processing.
• "Consent" — freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose.
• "Account" — a registered user account on the gemebet Platform.
• "Cookie" — a small data file stored on a user's device by a web browser at the request of a website, used to retain session state, preferences and analytics data.

3 Data Controller

gemebet acts as the Data Controller for all personal data collected through the Platform. As Data Controller, gemebet determines the purposes and lawful basis for processing your personal data and is responsible for ensuring that all processing is conducted in accordance with applicable data protection legislation and the terms of this Policy.

Where gemebet engages third-party service providers to process personal data on its behalf — for example, payment processors, KYC verification services and cloud infrastructure providers — those providers act as Data Processors under binding data processing agreements that restrict their use of your data to the specific services they provide to gemebet.

4 Data We Collect

gemebet collects personal data through several channels. The categories of personal data we collect and the circumstances in which they are collected are set out below.

4.1 Data Provided Directly by You

4.2 Data Collected Automatically

5 Purposes of Processing

gemebet processes your personal data for the following purposes:

• Account Management: Creating, maintaining and administering your gemebet Account, including authentication, account security and customer service.
• Identity Verification (KYC): Verifying your identity and age (minimum 21 years) in accordance with anti-money laundering obligations and responsible gambling requirements before processing any withdrawal.
• Payment Processing: Processing deposits and withdrawals via Malaysian payment methods including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong and supported cryptocurrencies.
• Contract Performance: Providing the betting and gaming services described in the Terms & Conditions, including settling bets, operating live casino games and awarding bonuses.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, money laundering, collusion and other prohibited conduct; monitoring for suspicious account behaviour.
• Responsible Gambling: Monitoring account activity to identify potential problem gambling patterns; enforcing responsible gambling tools including deposit limits and self-exclusion; complying with 21+ age requirements.
• Legal & Regulatory Compliance: Meeting obligations under applicable international gaming licensing conditions, anti-money laundering legislation and data protection requirements.
• Platform Improvement: Analysing usage patterns to improve platform performance, user experience and product development.
• Marketing Communications: Sending promotional offers, bonus notifications and platform updates — only where you have provided consent and only until that consent is withdrawn.

6 Legal Basis for Processing

gemebet processes your personal data on one or more of the following lawful bases as appropriate to the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and gemebet — including account operation, bet settlement and payment processing.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC/AML obligations under our gaming licence conditions.
• Legitimate Interests: Processing necessary for gemebet's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, responsible gambling monitoring and analytics.
• Consent: Processing based on your freely given, specific and informed consent — primarily for direct marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

gemebet does not sell your personal data. We may share personal data with the following categories of recipients, strictly for the purposes described:

7.1 Service Providers (Data Processors)

Third-party providers engaged by gemebet to deliver specific services on our behalf, including payment processing companies (operating DuitNow, FPX and e-wallet integrations), KYC and identity verification services, cloud infrastructure and hosting providers, fraud detection and security monitoring services, and customer support platform providers. All such providers are bound by data processing agreements restricting their use of your data.

7.2 Gaming Studios and Content Providers

Licensed international game studios may receive limited technical data (session identifiers, game result data) necessary to deliver and audit game outcomes. No identity data or financial data is shared with studios beyond what is strictly necessary.

7.3 Regulatory Authorities

gemebet may disclose personal data to licensing authorities, financial intelligence units or law enforcement agencies where required to do so by applicable law, court order or regulatory directive. We will notify you of any such disclosure where legally permitted to do so.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring or sale of substantially all of gemebet's assets, personal data may be transferred to the relevant successor entity. You will be notified of any such transfer in advance and given the opportunity to exercise your rights under this Policy.

8 International Data Transfers

As an internationally licensed platform, gemebet and certain of its service providers may store or process personal data on servers located outside Malaysia. Where personal data is transferred internationally, gemebet implements appropriate safeguards to ensure that the data receives an equivalent level of protection to that afforded in the originating jurisdiction, including:

• Standard contractual clauses or equivalent transfer mechanisms with third-party recipients.
• Transfer only to jurisdictions or service providers that maintain adequate data protection standards.
• Encryption of data in transit using TLS/SSL protocols.

For specific information about international transfers related to your personal data, you may contact gemebet's Data Protection team at the address provided in Section 15.

9 Data Retention

gemebet retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law and our gaming licence conditions. The following indicative retention periods apply:

Following the expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with gemebet's internal data disposal procedures.

10 Cookies & Tracking Technologies

gemebet uses cookies and similar tracking technologies to operate the Platform effectively, maintain session state, understand how users interact with our services and, where consent has been provided, for analytics and performance monitoring.

10.1 Cookie Categories

We use the following categories of cookies on the Platform:

• Essential Cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens and load-balancing cookies. They cannot be disabled without disrupting Platform functionality and do not require consent.
• Functional Cookies: Store your preferences such as language settings, preferred deposit method and responsible gambling tool configurations. They improve your experience but are not strictly necessary.
• Analytics Cookies: Collect aggregated, pseudonymous data about how users navigate the Platform, which pages are visited most frequently, and where technical errors occur. This data helps us improve Platform performance and user experience. These cookies require your consent and may be declined.

10.2 Managing Cookies

You can manage your cookie preferences at any time through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling essential cookies will impair your ability to use the Platform, including logging in to your Account.

11 Security Measures

gemebet implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, alteration, disclosure or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest within our database infrastructure.
• Hashing of account passwords using industry-standard cryptographic algorithms — passwords are never stored in plain text.
• Two-factor authentication (2FA) available to all Account holders.
• Real-time fraud detection and anomaly monitoring systems.
• Strict role-based access controls limiting staff access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing conducted by qualified third-party security professionals.
• Incident response procedures, including notification protocols for data security incidents.

12 Your Data Subject Rights

Subject to applicable data protection law and certain legal exceptions, you have the following rights in respect of your personal data held by gemebet:

• Right of Access You have the right to request a copy of all personal data gemebet holds about you, along with information about how it is processed. We will respond to verified access requests within 30 days.
• Right to Rectification You have the right to request correction of any inaccurate or incomplete personal data. Many contact details can be updated directly within your Account settings.
• Right to Erasure ("Right to be Forgotten") You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent. This right is subject to exceptions where retention is required by law — for example, AML record-keeping obligations.
• Right to Restrict Processing You may request that gemebet restricts the processing of your personal data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability Where processing is based on your consent or on a contractual necessity, you have the right to receive your personal data in a structured, commonly used and machine-readable format, and to request its transfer to another data controller where technically feasible.
• Right to Object You have the right to object to the processing of your personal data where that processing is based on legitimate interests, including profiling for direct marketing purposes. Objections to direct marketing will always be honoured.
• Right to Withdraw Consent Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal. You may unsubscribe from marketing communications at any time via your Account settings.

To exercise any of the above rights, please contact gemebet's Data Protection team using the contact details in Section 15. We may require verification of your identity before processing any data subject request to prevent unauthorised access to your information.

13 Minors & Age Restrictions

The gemebet Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals below this age. Our registration process includes an age declaration requirement, and our KYC verification procedures are designed to confirm that Account holders meet the minimum age threshold.

If gemebet becomes aware that personal data has been collected from an individual below the age of 21, we will take immediate steps to delete that data and close the associated Account. If you are a parent or guardian and believe a minor has registered on the Platform, please contact us immediately via the details in Section 15.

14 Policy Amendments

gemebet reserves the right to update or amend this Privacy Policy at any time. Material changes — such as new categories of personal data, new purposes of processing or changes to your rights — will be communicated to registered Users by email notification and/or prominent notice on the Platform at least fourteen (14) calendar days prior to the effective date, except where an immediate update is required by law or regulatory directive.

The date of the most recent update is displayed at the top of this Policy. We recommend reviewing this Policy periodically. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy. If you do not accept the amended Policy, you must cease using the Platform and may request Account closure.

15 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the gemebet Data Protection team. We aim to acknowledge all privacy-related enquiries within 5 business days and to respond substantively within 30 calendar days.

For matters relating to our Terms & Conditions, please visit the Terms & Conditions page. For responsible gambling support tools or self-exclusion requests, please visit the Responsible Gambling page.