22bb Club Privacy Policy – Malaysian Member Data Protection

22bb Club ("we", "Platform") are fully committed to protecting the privacy and personal data of every member who uses our platform at https://22bbclub.best. This Privacy Policy explains in detail the types of data we collect, the purposes of collection, how it is stored, retention periods, and your rights as a data subject.

This policy applies to all users of the platform 22bb Club — including visitors browsing the website without a registered account, members with active registered accounts, and former members whose accounts have been closed. By accessing or using the platform 22bb Club, you agree to the data handling practices described in this document.

We review and update this Privacy Policy periodically to reflect changes in our platform practices, legal requirements, or the technologies we use. The latest version is always available on this page with a clear last-updated date.

22bb Club collects your personal data through several channels. The following are the categories of data we collect and the primary purpose for each:

Account Registration Data:

• Full name as shown on your Malaysian identity card or passport
• An active Malaysian phone number (used for OTP verification)
• A valid email address
• Date of birth (for age verification of 18 and above)
• Username and encrypted password

Identity Verification (KYC) Data:

• A copy of your Malaysian identity card (MyKad) or passport — requested when withdrawals exceed RM5,000 or in cases that require identity verification.
• Proof of residential address (utility bill, bank statement) — in specific cases only
• Selfie with ID — if required by the compliance team

Financial Transaction Data:

• Deposit details including the method used (Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow, Maybank2u, CIMB Clicks, or FPX), transaction amount, and timestamp
• Withdrawal details including destination and amount
• Complete transaction history for audit and compliance purposes

Platform Activity Data:

• Records of slots, table games, poker, jackpot and Sports Betting activity
• Betting history including odds, markets, amounts and results for Liga Super Malaysia, EPL, BWF badminton, e-sports and other sports
• Login activity including timestamps, devices, and IP addresses
• Account preference settings and change history

Technical Data:

• Device IP address
• Browser type and operating system
• Cookie data and session identifiers
• Platform error logs and performance data

The data we collect is used solely for legitimate purposes directly related to the provision of our services 22bb Club. The purposes for which data is used are as follows:

• Account Management: Creating and managing member accounts, processing logins, updating profile information, and handling account-related requests.
• Transaction Processing: Processing deposits via Touch 'n Go, GrabPay, DuitNow, and other Malaysian payment methods, as well as withdrawals to members' e-wallets and bank accounts.
• Legal Compliance (KYC/AML): Verifying member identity to comply with anti-money laundering legal requirements and to prevent misuse of the platform.
• Customer Support: Handling enquiries, resolving complaints, and providing technical support to members in Bahasa Melayu.
• Platform Security: To detect and prevent fraudulent activity, account abuse, money laundering, and other security threats.
• Service Improvement: Analysing usage patterns in aggregate (not at an individual level) to improve the user experience, platform performance, and game selection.
• Service Communications: Sending important notifications about your account, changes to terms, promotions you have subscribed to, and security updates.
• VIP Programme: Calculating and crediting VIP points, cashback, and rewards based on your gaming activity at 22bb Club.
• Responsible Gaming: Monitoring gaming patterns to identify signs of problem gambling and to enforce the limits you have set for yourself.

22bb Club does not use your personal data for third-party marketing, data sales, or any other purpose not stated above without your explicit consent.

22bb Club processes your personal data on the following valid legal bases:

• Contract Performance: Data processing is necessary to fulfil the contract between you and 22bb Club when you register an account and use our services — including processing deposits, withdrawals, and account management.
• Legal Compliance: Some data is processed because 22bb Club required to do so by law — including KYC (Know Your Customer) and AML (Anti-Money Laundering) obligations.
• Legitimate Interest: We process certain data on the basis of legitimate business interests, such as fraud prevention, platform security improvements, and service analysis — provided these interests do not override your privacy rights.
• Consent: For optional marketing communications (such as promotions and special offers), we process your data based on consent given during or after registration. You may withdraw this consent at any time.

22bb Club does not sell, rent, or transfer your personal data to third parties for marketing or commercial purposes. However, data may be shared in the following limited circumstances:

• Payment Service Providers: Required transaction data is shared with Malaysian payment providers such as Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow, and FPX-participating banks to process your deposits and withdrawals. These providers are bound by strict confidentiality agreements.
• Game Providers: Minimum technical data required is shared with third-party game providers such as Pragmatic Play, PG Soft and others solely to enable gameplay. Full identity data is not shared with game providers.
• Legal Requirements: 22bb Club may disclose data to Malaysian authorities when required by court order, applicable law, or official investigation requirements. We will notify you of any such disclosure unless prohibited by law.
• Rights Protection: Data may be shared to protect rights, property or safety 22bb Club, its members, or the public — including in cases of suspected fraud or criminal activity.
• Business Transfers: In the event of a merger, acquisition or asset sale, member data may be transferred to the new entity. You will be notified in advance and given the option to withdraw consent where applicable.

22bb Club implements multiple layers of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction:

• Data Encryption in Transit: All communication between your browser and the 22bb Club encrypted using TLS 1.3 protocol with a 256-bit SSL certificate. This means your data cannot be intercepted during transmission.
• Stored Data Encryption: Sensitive data such as passwords (stored as hashes), KYC information, and transaction details are encrypted at rest using industry-standard encryption algorithms.
• Tiered Access Control: A role-based access control (RBAC) system ensures that staff can only access data necessary for their specific duties. All access to sensitive data is logged and monitored.
• Two-Factor Authentication: Two-factor authentication (2FA) is available for all member accounts and is mandatory for staff accessing internal systems.
• Regular Security Audits: 22bb Club conducts regular security assessments and penetration testing to identify and address system vulnerabilities.
• Continuous Monitoring: An automated monitoring system operates 24/7 to detect suspicious activity, unauthorised access attempts, and other security threats.
• Physical Security: Server 22bb Club housed in certified data centres with physical access controls, redundant cooling systems, and backup power.

While we take all reasonable steps to protect your data, no security system can be guaranteed 100% secure. You also play an important role in keeping your account safe — use a strong password and never share your login credentials.

22bb Club retains your personal data only for as long as necessary to fulfil the purposes stated in this policy or as required by law. Retention periods vary depending on the type of data:

• Active Account Data: Retained for as long as your account is active and all related transactions have been settled.
• Data After Account Closure: Financial transaction records and KYC data are retained for a minimum of 7 years after account closure to meet legal requirements related to financial compliance.
• Security Logs: Access and security log data is retained for 2 years.
• Support Communication Data: Customer support session records are retained for 3 years for reference and dispute resolution purposes.
• Technical Data (Cookies, Logs): Session data is deleted once a session ends. Aggregated analytics data may be retained longer in a form that cannot be used to identify any individual.

Once the specified retention period has lapsed, your data will be securely deleted or anonymised in accordance with industry-standard data disposal procedures. You may also request early deletion — see Section 9 on your rights.

Platform 22bb Club uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions properly. The following are the types of cookies we use:

• Essential Cookies (Required): Required for core platform functions such as maintaining login sessions, remembering language preferences, and securing transactions. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: Helps the platform remember your preferences such as odds format (Malay, Decimal or HK), language and display settings for a more personalised experience.
• Analytics Cookies: We use aggregated, non-personally identifiable analytics data to understand platform usage patterns — such as the most visited pages and session duration — for service improvement purposes.
• Security Cookies: Used to detect suspicious activity, prevent fraud, and protect member accounts from unauthorised access.

You can manage your cookie settings through your web browser. However, disabling essential cookies may affect the platform's functionality 22bb Club as a whole. A cookie notice is displayed on your first visit to the platform to obtain your consent.

As a member 22bb Club, you have the following rights regarding your personal data. To exercise any of these rights, contact us at support@22bbclub.best:

• Right of Access: You have the right to obtain a copy of the personal data we hold about you. Requests will be processed within 14 business days.
• Right to Rectification: If your data is inaccurate or incomplete, you have the right to request a correction. For basic information, you can update it yourself via your account settings. More complex data corrections will require a formal request.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data. However, this right is subject to our legal obligations — financial records must be retained for 7 years in accordance with compliance requirements.
• Right to Restrict Processing: In certain circumstances, you may request that the processing of your data be temporarily restricted — for example, while we are investigating a dispute regarding data accuracy.
• Right to Data Portability: You may request to receive your personal data in a machine-readable format (such as CSV or JSON) for transfer to another service provider.
• Right to Object: You may object to the processing of your data based on our legitimate interests, including for direct marketing purposes. You may unsubscribe from marketing communications at any time via the unsubscribe link in our emails.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the validity of any processing carried out prior to the withdrawal.

All data rights requests will be processed within 14 business days. In complex cases, this period may be extended to up to 30 days, with notice provided to you. 22bb Club does not charge a fee to process reasonable data rights requests.

Services 22bb Club is exclusively for individuals aged 18 and above. Our platform is not designed for, intended for or accessible to underage users.

22bb Club does not knowingly collect or process personal data of individuals under 18 years of age. Should we discover that a child's data has been collected without proper age verification, we will:

• Close the account in question immediately
• Deleting all data associated with that individual
• Returning any available balance to the original payment method

If you are a parent or guardian who believes your child has registered an account at 22bb Club, please contact us immediately at support@22bbclub.best with the relevant information. We will take prompt action to address the situation.

22bb Club reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our operational practices, the technologies we use, or applicable legal requirements. The amendment notification procedure is as follows:

• Material Amendments: Changes that materially affect how we use your data, or that reduce your rights, will be communicated via email to your registered address and through an in-platform notification at least 30 days before taking effect.
• Minor Amendments: Corrections to text errors, language clarifications, or updates to contact information may take effect immediately, with the date at the top of this page updated accordingly.
• Periodic Review: We recommend reviewing this Privacy Policy at least once every six months to stay informed about how we handle your data.

Continued use of the platform 22bb Club after the notified amendment effective date will be considered as your acceptance of the updated Privacy Policy. If you do not agree with the amendments, you may close your account before the effective date.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 22bb Club handle your personal data, please contact us through the following channels:

• Email: support@22bbclub.best — for privacy enquiries and data rights requests
• Live Chat: Available 24/7 within the platform 22bb Club for general enquiries
• WhatsApp: Support WhatsApp number available after logging in to your account

When contacting us regarding a privacy matter, please include the following information to help us process your request more efficiently:

• Username or account number 22bb Club you
• Type of request (data access, correction, deletion, etc.)
• Specific details about the data or issue in question

This document was last updated on 1 January 2026 and supersedes all previous versions of the Privacy Policy. By using the 22bb Club, you confirm that you have read and understood this Privacy Policy.