oren33 Privacy Policy

1 Introduction

This Privacy Policy (hereinafter "the Policy") is issued by oren33 (hereinafter "oren33", "we", "us", or "our"), the operator of the online gaming platform accessible at oren33.cam. This Policy applies to all individuals who visit, register on, or otherwise interact with the oren33 Platform (hereinafter "the Platform"), and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

oren33 is committed to processing personal data responsibly, transparently, and in accordance with applicable data protection laws and principles. We recognise that privacy is a fundamental concern for our players — particularly those based in Malaysia, where digital payment activity and online account management involve the sharing of sensitive personal and financial information.

This Policy should be read together with our Terms & Conditions, which govern your use of the Platform as a whole. In the event of any conflict between the two documents on a privacy matter, this Policy shall prevail.

2 Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings assigned to them below:

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, identification number, location data, email address, financial data, or any other identifier.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, alteration, or deletion.
• "Data Controller" — oren33, which determines the purposes and means of Processing Personal Data collected on the Platform.
• "Data Subject" — The individual whose Personal Data is being processed; in the context of this Policy, this means the registered Player or Platform visitor.
• "Platform" — The oren33 website at oren33.cam and all associated services, pages, and features.
• "Third Party" — Any entity other than oren33 and the Data Subject, including payment processors, KYC verification providers, analytics services, and regulatory bodies.
• "KYC" — Know Your Customer procedures, comprising identity verification, age verification, and source-of-funds checks conducted to comply with applicable legal requirements.
• "Cookies" — Small data files stored on a user's device by a web browser, used to recognise returning users and facilitate platform functionality.

3 Data We Collect

oren33 collects the following categories of Personal Data, depending on how you interact with the Platform:

3.1 Registration and Account Data

• Full legal name
• Date of birth
• Residential address (including city — e.g., Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam)
• Email address
• Mobile phone number
• Username and encrypted password
• Preferred currency (MYR)

3.2 Identity Verification (KYC) Data

• Government-issued photographic identification (e.g., Malaysian MyKad, passport)
• Selfie or liveness verification image (where required)
• Proof of address documentation
• Source-of-funds documentation (for high-value accounts, where applicable)

3.3 Financial and Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method identifiers (e.g., masked bank account numbers, Touch 'n Go eWallet reference IDs, Boost transaction references, DuitNow QR payment identifiers)
• Cryptocurrency wallet addresses (where USDT TRC20 is used)
• Account balance history

3.4 Gaming and Betting Activity Data

• Wager history, stake amounts, and settlement outcomes
• Games accessed and session durations
• Bonus claims, wagering requirement progress, and VIP tier status
• Responsible gambling tool settings (deposit limits, self-exclusion status)

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session timestamps and login history
• Cookie data and platform usage analytics

3.6 Communications Data

• Live chat transcripts and support ticket records
• Email correspondence with oren33's support team
• Feedback, survey responses, and promotional opt-in preferences

4 How We Collect Data

oren33 collects Personal Data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a survey or promotion.
• Automatically — through Cookies, server logs, and analytics tools when you access and navigate the Platform, regardless of whether you are logged in.
• From third parties — from KYC and identity verification service providers, payment processors (including Touch 'n Go, Boost, GrabPay, Maybank, CIMB, DuitNow, FPX), fraud detection services, and where required, regulatory or law enforcement authorities.

5 Data Processing & Use

oren33 processes your Personal Data for the following purposes. The table below maps each purpose to the category of data typically involved:

6 Legal Basis for Processing

oren33 processes Personal Data on the following legal grounds, depending on the purpose of processing:

• Contractual necessity — Processing required to perform our contract with you as a registered Player, including providing gaming services, processing financial transactions, and maintaining your account.
• Legal obligation — Processing required to comply with applicable law, including KYC and anti-money-laundering obligations, age verification requirements, and regulatory reporting duties.
• Legitimate interests — Processing carried out for oren33's legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent — Processing based on your freely given, specific, and informed consent, including the sending of direct marketing communications and the use of non-essential Cookies.

7 Data Sharing

oren33 does not sell, rent, or trade your Personal Data to third parties for their own marketing or commercial purposes. We share Personal Data only in the following circumstances and only to the extent necessary for each purpose:

• Payment processors — To facilitate deposits and withdrawals via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, and USDT TRC20 cryptocurrency networks. Payment processors receive only the data necessary to complete and verify each transaction.
• KYC and identity verification providers — To verify your identity, age, and, where applicable, source of funds, as required by our licensing obligations. These providers are contractually bound to process your data only for verification purposes.
• Fraud detection and anti-money-laundering services — To detect and prevent fraudulent transactions, account abuse, and financial crime.
• Platform analytics and technical service providers — To maintain, secure, and improve the Platform. These providers act as data processors under our instructions and may not use your data for their own purposes.
• Regulatory and legal authorities — Where oren33 is required by law, court order, or regulatory direction to disclose your Personal Data, we will comply with such requirements. Where legally permissible, we will attempt to notify you of such disclosure.
• Group companies and successors — In the event of a corporate restructure, merger, acquisition, or sale of assets, your Personal Data may be transferred to a successor entity, subject to the same data protection obligations.

8 Data Retention

oren33 retains Personal Data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Active account data — Retained for the duration of the account relationship.
• KYC and identity documents — Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later, in accordance with anti-money-laundering regulatory requirements.
• Transaction and financial records — Retained for a minimum of five (5) years from the date of each transaction.
• Customer support records — Retained for a minimum of three (3) years from the date of the interaction.
• Marketing consent records — Retained for the duration of the marketing relationship plus one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised. Where anonymisation is not practicable, data will be archived with access restrictions in place.

9 Data Security

oren33 implements comprehensive technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive Personal Data and payment credentials at rest in our databases.
• Role-based access controls limiting staff access to Personal Data on a strict need-to-know basis.
• Multi-factor authentication requirements for administrative access to production systems.
• Regular security audits, penetration testing, and vulnerability assessments conducted by qualified third parties.
• Intrusion detection and monitoring systems active on all production infrastructure.
• Secure data centre facilities with physical access controls and environmental protections.

Notwithstanding the above, no method of electronic transmission or storage is entirely secure. While oren33 takes its security obligations seriously and strives to apply industry-best practices, we cannot guarantee the absolute security of data transmitted over the internet. You are responsible for keeping your account credentials confidential and should notify us immediately if you suspect unauthorised access to your account.

10 Cookies & Tracking Technologies

oren33 uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies we use are as follows:

• Strictly Necessary Cookies — Required for the Platform to function correctly. These include session management cookies, authentication tokens, and security cookies. These cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies — Used to collect aggregate, anonymised data about how users navigate the Platform, including pages visited, time spent, and features used. This data helps us identify areas for improvement.
• Functional Cookies — Used to remember your preferences, such as language settings, display options, and last-visited game categories, to personalise your experience on return visits.
• Marketing and Targeting Cookies — Used to deliver relevant promotional content based on your browsing activity and preferences, where you have consented to receive marketing communications.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of the Platform. Consent for non-essential cookies may be withdrawn at any time by adjusting your browser settings or contacting our support team.

11 User Rights

Subject to applicable law, you hold the following rights with respect to the Personal Data that oren33 holds about you. To exercise any of these rights, please contact our support team via Live Chat or at [email protected]:

• Right of Access — You have the right to request a copy of the Personal Data we hold about you and information about how it is processed.
• Right to Rectification — You have the right to request correction of inaccurate or incomplete Personal Data. You may update many of your account details directly through your account settings.
• Right to Erasure — You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal obligations (e.g., regulatory retention requirements).
• Right to Restriction of Processing — You may request that we temporarily cease processing your Personal Data in certain circumstances, for example while a rectification request is being assessed.
• Right to Data Portability — Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that we provide your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object — You may object to the processing of your Personal Data where processing is based on legitimate interests, including the use of your data for direct marketing.
• Right to Withdraw Consent — Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

12 Minors & Age Policy

The oren33 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or store Personal Data relating to persons under the age of 21. During the registration process, all applicants are required to declare their date of birth and submit to KYC verification, which includes documentary proof of age.

If oren33 becomes aware or has reasonable grounds to believe that Personal Data has been collected from a person under the age of 21, the relevant account will be immediately suspended, all Personal Data relating to that individual will be securely deleted (subject to any legal obligations to retain records for regulatory purposes), and any funds in the account will be handled in accordance with our Terms & Conditions.

13 Third-Party Links

The oren33 Platform may from time to time contain references to third-party services, such as payment providers (Touch 'n Go eWallet, Boost, GrabPay, Maybank, DuitNow, etc.) whose interfaces you may access during a transaction. These third-party services operate under their own privacy policies, which are entirely independent of this Policy.

oren33 is not responsible for the privacy practices of any third-party service and does not endorse or make any representations regarding the content, policies, or practices of any third-party website or service. We encourage you to review the privacy policy of any third-party service you use in connection with your oren33 account.

14 Policy Amendments

oren33 reserves the right to update or revise this Privacy Policy at any time. Where changes are material, we will use reasonable efforts to notify registered Players via email or an in-platform notification at least fourteen (14) days before the changes take effect. The updated Policy will be published on this page with a revised "Last Updated" date.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this page periodically to stay informed of any updates to our data processing practices.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by oren33, you may contact us through the following channels:

• Live Chat — Available 24 hours a day, 7 days a week via the oren33 Platform on Malaysian time (MYT, UTC+8). Live Chat is the fastest way to reach our team for general privacy queries.
• Email — [email protected]. For formal privacy-related requests, please include the subject line "Privacy Request" along with your registered account username and a clear description of your query or request. We aim to respond to all email enquiries within 24 to 48 hours.

For formal data subject rights requests (e.g., access, rectification, erasure), please submit your request in writing via email with sufficient information to verify your identity. We will acknowledge receipt of all formal requests within five (5) business days.