Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how shoei33 ("shoei33", "we", "us", "our") collects, uses, stores, discloses, and otherwise processes personal data in connection with your use of the shoei33 website at shoei33.club and all associated products and services (collectively, the "Platform").

By registering an account on shoei33 or otherwise using the Platform, you acknowledge that you have read this Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read in conjunction with the shoei33 Terms & Conditions.

This Policy applies to all players accessing the shoei33 platform, including players based in Malaysia and other jurisdictions where the Platform is accessible. Where local data protection laws impose stricter requirements than those described in this Policy, shoei33 will comply with the applicable local standard.

2. Data Controller

For the purposes of applicable data protection legislation, shoei33 is the data controller responsible for personal data collected through the Platform. Questions regarding data control or processing may be directed to our support team at the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

shoei33 collects the following categories of personal data from players and prospective players:

3.1 Identity and Contact Data

• Full legal name as it appears on government-issued identification;
• Date of birth (collected to verify the 21+ age requirement);
• Residential address, including postcode and country;
• Email address;
• Mobile telephone number.

3.2 Identity Verification Data

• Copies of government-issued identification documents (e.g., MyKad, passport, driving licence) where required for KYC verification;
• Proof of residential address documents (e.g., utility bill, bank statement);
• Proof of payment method ownership where required for withdrawal processing.

3.3 Financial and Transaction Data

• Deposit and withdrawal amounts, dates, and payment methods used;
• Account balance history;
• Details of bonuses claimed and wagering activity associated with bonuses;
• Partial payment method identifiers (e.g., last four digits of a bank account or e-wallet reference).

3.4 Gaming Activity Data

• Betting history, including markets, stakes, odds, and outcomes;
• Casino and slot game session data, including games played, session duration, and results;
• Responsible gaming settings, including any limits or self-exclusion periods applied to your account.

3.5 Technical and Device Data

• IP address and approximate geolocation data derived from it;
• Device type, operating system, and browser version;
• Session timestamps and login location history;
• Cookies and similar tracking technologies as described in Section 9.

3.6 Communications Data

• Records of communications between you and shoei33 customer support, including live chat transcripts and email correspondence;
• Records of your responses to surveys or promotional communications where you choose to participate.

4. How We Collect Your Data

shoei33 collects personal data through the following means:

• Directly from you — when you register an account, complete identity verification, make a deposit or withdrawal, contact customer support, or voluntarily provide information through any feature of the Platform;
• Automatically — through cookies, server logs, and similar tracking technologies as you interact with the Platform;
• From third parties — including identity verification service providers, payment processors, fraud prevention services, and analytics providers, to the extent necessary and permitted by applicable law.

5. Purposes and Legal Basis for Processing

shoei33 processes your personal data for the following purposes and on the following legal bases:

• Contract performance — to create and maintain your account, process deposits and withdrawals, settle bets and gaming sessions, and deliver the core Services you have registered for;
• Legal obligation — to comply with anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, age verification requirements, and regulatory reporting obligations imposed by shoei33's international gaming authority licence;
• Legitimate interests — to detect and prevent fraud, abuse, and unauthorised access; to maintain Platform security; to analyse Platform performance and improve user experience; and to enforce the shoei33 Terms & Conditions;
• Consent — to send marketing communications where you have opted in to receive them. You may withdraw consent at any time as described in Section 12.

6. Sharing Your Personal Data

shoei33 does not sell, rent, or trade your personal data to third-party marketers or data brokers. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors and e-wallet operators — including operators of Touch n Go eWallet, Boost, GrabPay, Maybank, CIMB, Hong Leong Bank, Public Bank, and other integrated payment methods, to process deposit and withdrawal transactions;
• Identity verification providers — third-party KYC service providers used to verify your identity and age in compliance with licensing obligations;
• Game software providers — third-party casino and sports betting software providers whose games and platforms are integrated into shoei33, to the extent required to operate those games and maintain game audit trails;
• Fraud prevention and security services — to detect, investigate, and prevent fraudulent activity, account compromise, and money laundering;
• Analytics providers — to analyse platform usage and performance using anonymised or aggregated data where possible;
• Regulatory and law enforcement authorities — where required by law, court order, or our licensing authority's reporting requirements;
• Successors in business — in the event of a merger, acquisition, or sale of substantially all of shoei33's assets, your personal data may be transferred to the acquiring entity subject to equivalent privacy protections.

All third parties with whom shoei33 shares personal data are contractually required to process that data only for the specified purpose and in accordance with applicable data protection law.

7. International Data Transfers

shoei33 operates under international gaming authority licensing and may process or store certain player data on servers or through service providers located outside Malaysia. Where personal data is transferred internationally, shoei33 takes reasonable steps to ensure that appropriate safeguards are in place, including contractual protections equivalent to applicable data protection standards. By using the Platform, you consent to such international transfers subject to those safeguards.

8. Data Retention

shoei33 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, and licensing obligations. As a general guide:

• Account registration and identity verification data is retained for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• Transaction and betting history records are retained for a minimum of five (5) years from the date of the relevant transaction;
• Customer support communications are retained for a minimum of two (2) years from the date of the last communication in a given matter;
• Technical and device log data is retained for up to twelve (12) months from collection.

Where retention beyond these periods is required by applicable law or licensing authority direction, shoei33 will comply with that extended retention requirement.

9. Cookies and Tracking Technologies

shoei33 uses cookies and similar technologies (including local storage and session tokens) on the Platform for the following purposes:

• Essential cookies — required for Platform functionality, including maintaining your logged-in session and storing account preferences. These cannot be disabled without impairing Platform functionality;
• Analytics cookies — used to understand how players navigate and use the Platform, enabling shoei33 to improve the user experience. Data collected is aggregated and anonymised where possible;
• Security cookies — used to detect and prevent fraudulent login attempts, session hijacking, and other security threats.

You may manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the availability or functionality of some Platform features. shoei33 does not use third-party advertising or behavioural tracking cookies.

10. Security of Personal Data

shoei33 implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include, but are not limited to, 256-bit SSL encryption for all data in transit, encrypted storage for sensitive personal and financial data, role-based access controls limiting staff access to personal data to those with a legitimate operational need, regular security assessments, and multi-factor authentication requirements for administrative access to systems holding personal data.

Despite these measures, no data transmission over the internet or electronic storage system can be guaranteed to be completely secure. In the event of a personal data breach that poses a risk to affected individuals, shoei33 will notify affected players and relevant authorities in accordance with applicable notification obligations.

11. Your Rights

Subject to applicable law and our licensing obligations, registered players have the following rights in relation to their personal data held by shoei33:

• Right of access — you may request a copy of the personal data shoei33 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 purposes for which it was collected, subject to overriding legal retention obligations;
• Right to restrict processing — you may request that shoei33 limit its processing of your data in certain circumstances;
• Right to data portability — you may request a copy of certain personal data in a machine-readable format where technically feasible;
• Right to object — you may object to processing of your personal data based on legitimate interests, including profiling for direct marketing purposes.

To exercise any of these rights, please contact the shoei33 support team at the details provided in Section 15. We will respond to verified requests within 30 days. Note that certain rights may be subject to limitations where processing is required for compliance with legal obligations or the exercise of legal claims.

12. Marketing Communications

Where you have opted in to receive marketing communications from shoei33 at the time of registration or through your account settings, we may send you promotional emails, SMS messages, or in-platform notifications about bonuses, new games, and special offers. You may withdraw consent to marketing communications at any time by updating your notification preferences in your shoei33 account settings or by contacting our support team. Withdrawal of marketing consent does not affect the lawfulness of marketing communications sent prior to the withdrawal.

Note that transactional messages (such as deposit confirmations, withdrawal processing notifications, and account security alerts) are not marketing communications and will continue to be sent regardless of your marketing preferences.

13. Children and Minors

The shoei33 platform is strictly intended for adults aged 21 years and above. shoei33 does not knowingly collect personal data from persons under the age of 21. If shoei33 becomes aware that personal data has been collected from a person under 21, the relevant account will be closed immediately, all data will be deleted to the extent permitted by legal retention obligations, and any funds will be handled in accordance with applicable licensing authority guidance. If you believe a minor has registered on the shoei33 platform, please contact our support team immediately.

14. Changes to This Policy

shoei33 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or the structure of our services. Material changes will be communicated to registered players via email to the address on file or by a prominent notice on the Platform. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by shoei33, please contact our support team. Our support email is: [email protected]. Our support team is available 24 hours a day, 7 days a week, and we aim to respond to all data-related enquiries within three (3) business days.