Privacy Policy

1. Introduction

comel88 ("the Platform", "we", "us", "our") operates the online casino and sports betting platform accessible at comel88.cam. This Privacy Policy ("Policy") describes in full how comel88 collects, uses, stores, shares, and protects the personal data of individuals ("User", "Player", "you") who access or use any part of our Services.

comel88 is committed to responsible and transparent data handling. We process personal data only for clearly defined, lawful purposes and in accordance with recognised data protection principles, including data minimisation, purpose limitation, accuracy, storage limitation, integrity, confidentiality, and accountability.

This Policy forms part of the overall legal framework governing your relationship with comel88, alongside our Terms & Conditions and our Responsible Gambling Policy. If there is any conflict between this Policy and the Terms & Conditions in relation to data matters, this Policy shall prevail.

By registering an account, making a deposit, placing a bet, or otherwise engaging with the Platform, you confirm that you have read this Policy, that you understand how your personal data will be used, and that you consent to that use as described herein.

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. This includes name, identification number, contact details, IP address, financial data, and behavioural data.
• "Processing" — Any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Data Controller" — comel88, as the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" — A third party that processes Personal Data on behalf of comel88 under contractual instruction.
• "KYC" — Know Your Customer: identity and address verification procedures required to comply with anti-money laundering (AML) regulations.
• "Cookies" — Small text files placed on your device by a website to store session data, preferences, or analytics information.
• "Services" — All games, betting markets, promotions, customer support, and related functions offered through the comel88 Platform.
• "MYR" — Malaysian Ringgit, the currency in which all Platform financial transactions are conducted.

3. Data We Collect

comel88 collects the minimum amount of personal data necessary to provide our Services, comply with legal obligations, and maintain Platform security. The categories of data we collect are detailed below.

3.1 Data You Provide Directly

• Registration data: Full name, date of birth, email address, phone number, username, and password.
• KYC documentation: Copy of national identity card (MyKad), passport, utility bill, or bank statement submitted to verify your identity and address.
• Payment data: Bank account details, e-wallet account identifiers (Touch 'n Go, Boost, GrabPay, DuitNow), and cryptocurrency wallet addresses used to process deposits and withdrawals in MYR or supported cryptocurrencies.
• Communications: Messages sent to our support team via live chat or email, including any complaint submissions.
• Responsible gambling submissions: Deposit limit preferences, cooling-off requests, and self-exclusion requests submitted through our Responsible Gambling tools.

3.2 Data Collected Automatically

• Device and technical data: IP address, browser type and version, operating system, device type, and screen resolution.
• Usage data: Pages viewed, games played, bet amounts, session duration, navigation paths, and click-stream data.
• Transaction logs: A complete log of all deposits, withdrawals, bonuses credited, wagers placed, and game outcomes associated with your account.
• Cookie data: Session identifiers, authentication tokens, and analytics data as described in Section 7 (Cookies).
• Geolocation data: Approximate location data derived from your IP address, used for fraud detection and access controls.

4. How We Use Your Data

comel88 uses the personal data we collect for the following purposes:

5. Legal Basis for Processing

comel88 processes personal data on the following legal grounds, as appropriate to each processing activity:

1. Contractual Necessity: Processing required to fulfil our contractual obligations to you — including providing access to games, processing financial transactions, and delivering customer support.
2. Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and financial record-keeping obligations.
3. Legitimate Interests: Processing carried out to pursue the legitimate interests of comel88, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your fundamental rights and freedoms.
4. Consent: Processing based on your freely given, specific, and informed consent — including opt-in marketing communications. You may withdraw consent at any time by contacting our support team.

6. Data Sharing and Third-Party Disclosure

comel88 does not sell, rent, or trade your personal data to any third party. We share personal data only in the following limited circumstances:

6.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process data on our behalf under strict data processing agreements. These include payment processors (for FPX, DuitNow, Touch 'n Go, Maybank, CIMB, and similar), KYC verification providers, fraud detection services, and cloud infrastructure providers. All such processors are contractually bound to handle your data only as directed by comel88 and in accordance with this Policy.

6.2 Licensed Game Studio Partners

Where technically necessary, anonymised session and gameplay data may be shared with our licensed game studio partners to facilitate game delivery, RNG certification, and dispute resolution. No personally identifiable financial data is shared with studio partners for marketing purposes.

6.3 Legal and Regulatory Authorities

comel88 may disclose personal data to law enforcement agencies, financial intelligence units, or regulatory authorities where required to do so by applicable law, court order, or in connection with any investigation into suspected fraud, money laundering, or other criminal activity.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of comel88's business assets, personal data held by comel88 may form part of the transferred assets. In such circumstances, we will endeavour to notify affected users in advance and ensure the receiving entity is bound by data protection obligations consistent with this Policy.

7. Cookies and Tracking Technologies

comel88 uses cookies and similar tracking technologies to operate core Platform functions, maintain session security, and analyse aggregate usage patterns. A summary of the cookie types we use is provided below.

• Essential / Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication tokens and security cookies. They cannot be disabled without disrupting Platform use.
• Functional Cookies: Store your preferences such as language settings and display options to personalise your experience across sessions.
• Analytics Cookies: Collect anonymised usage data (pages visited, features used, session duration) to help us understand how the Platform is used and identify areas for improvement. Data is aggregated and not linked to individual identities.
• Security Cookies: Used to detect and prevent fraudulent login attempts, account takeovers, and other suspicious activity.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality or availability of some Platform features.

8. Data Retention

comel88 retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to any overriding legal, regulatory, or contractual obligations. Our general retention periods are as follows:

• Account and KYC data: Retained for the duration of your account and for a period of at least 5 years following account closure, in compliance with AML record-keeping obligations.
• Transaction records: Retained for at least 5 years from the date of the transaction, as required under applicable financial record-keeping regulations.
• Support communications: Retained for up to 3 years from the date of the interaction, or longer if related to an open dispute or legal matter.
• Marketing preference data: Retained until you withdraw consent or request deletion.
• Analytics data: Retained in anonymised or aggregated form with no fixed expiry, as it cannot be linked to identifiable individuals.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard methods to prevent unauthorised reconstruction.

9. Data Security

comel88 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data transmitted between users and the Platform.
• Encrypted storage of all sensitive data at rest, including passwords (stored as salted hashes — never in plain text) and payment credentials.
• Two-factor authentication (2FA) options for user accounts.
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis.
• Continuous monitoring of Platform infrastructure for intrusion attempts, anomalous activity, and security vulnerabilities.
• Regular independent security audits and penetration testing of Platform systems.
• Staff training on data protection obligations and secure data handling practices.

Notwithstanding these measures, no data transmission over the internet or electronic storage system is completely immune to risk. In the event of a data breach that is likely to result in a risk to your rights, comel88 will notify affected users and relevant authorities in accordance with applicable data breach notification obligations.

10. Your Data Rights

Subject to applicable data protection law, you have the following rights in relation to your personal data held by comel88. To exercise any of these rights, please contact our support team using the details in Section 14.