CLY88 Privacy Policy

This Privacy Policy ("Policy") is issued by CLY88 ("cly88", "we", "us", "our"), the operator of the online gaming platform accessible at https://cly88.cam and all associated subdomains and mobile interfaces. This Policy describes the personal data we collect from you when you use the cly88 platform, the purposes for which that data is processed, the parties with whom it may be shared, and the rights you hold as a data subject.

By registering an account, accessing the platform, or using any service provided by cly88, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the platform.

cly88 is committed to handling all personal data with transparency, integrity, and in accordance with applicable data protection principles. Our data practices are designed not only to meet our regulatory obligations as an internationally licensed gaming operator, but to genuinely respect the privacy expectations of our members across Malaysia and beyond.

The following defined terms are used throughout this Policy:

cly88 collects the following categories of personal data from Members and platform users:

We do not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, health data (except where voluntarily disclosed in the context of a responsible gambling request), or biometric data, except where biometric verification is specifically required as part of an enhanced KYC procedure and you have been separately informed and consented.

cly88 collects personal data through the following channels and methods:

• Direct submission: When you register an account, complete the KYC process, make a deposit or withdrawal, update your account profile, contact customer support, or respond to a promotion.
• Automated collection: Technical data and behavioural data are collected automatically as you access and use the platform, through server logs, session tracking, and platform analytics tools.
• Cookies and similar technologies: The platform uses cookies and similar tracking mechanisms to manage your session, remember preferences, and provide anonymised analytics data. See Section 10 for full details.
• Payment processors: When you make a financial transaction, our payment processing partners (including those facilitating DuitNow, FPX, and eWallet transactions) may provide us with confirmation data including payment reference numbers and partial payment identifiers necessary to reconcile your account.
• Third-party identity verification providers: Where cly88 uses third-party KYC or age-verification services, those providers may supply identity confirmation results back to cly88 as part of the account verification workflow.
• Fraud prevention and security services: cly88 may receive flagged data from fraud detection partners where your account activity has been identified as potentially suspicious.

cly88 processes your personal data for the following specific purposes:

1. Account creation and management: To register your account, authenticate your identity at login, maintain your account settings, and manage your ongoing relationship with the platform.
2. KYC and regulatory compliance: To verify your identity and age (21+), comply with anti-money-laundering (AML) and counter-terrorism financing (CTF) obligations, and satisfy the conditions of cly88's gaming licence.
3. Transaction processing: To process deposits and withdrawals in MYR via DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, and other approved payment methods.
4. Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, bonus abuse, and any other conduct that violates our Terms & Conditions or applicable law.
5. Customer support: To respond to your support requests, resolve disputes, process complaints, and maintain records of support interactions.
6. Responsible gambling: To monitor for indicators of problem gambling behaviour, enforce self-exclusion requests, apply deposit and loss limits set by the Member, and take protective action where required.
7. Platform improvement and analytics: To analyse how Members use the platform in aggregate, identify technical issues, improve game performance, and develop new features.
8. Marketing and promotions: Where you have provided consent or where permitted under applicable law, to inform you of promotions, bonuses, and platform updates via email or in-platform notifications. You may opt out at any time.
9. Legal obligations and dispute resolution: To comply with court orders, regulatory requests, and to defend or pursue legal claims where necessary.

cly88 processes your personal data on the following legal bases, each of which applies to one or more of the processing purposes described in Section 5:

• Contract performance: Processing necessary to provide the services you have requested by registering and using a cly88 account, including account management, transaction processing, and customer support.
• Legal obligation: Processing required to comply with applicable laws, including KYC/AML obligations, gaming licence conditions, and responses to lawful authority requests.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gambling monitoring, and aggregate analytics, where these interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have provided freely given, informed, and specific consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

cly88 does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, solely as described and subject to contractual data protection obligations:

• Payment processing partners: Entities facilitating your DuitNow, FPX, eWallet, or banking transactions receive the minimum data necessary to process and confirm your financial transactions.
• KYC and identity verification providers: Third-party services engaged to verify your identity documents and confirm age eligibility as part of the compliance process.
• Fraud prevention and security services: Providers that assist cly88 in detecting and preventing fraudulent account activity, unauthorised access, and AML violations.
• Game content providers: Game studios whose titles are hosted on the cly88 platform may receive anonymised gameplay data for the purpose of game performance analytics. No personally identifiable information is shared with game providers for this purpose.
• IT infrastructure and cloud service providers: Entities that host or maintain the technical infrastructure supporting the platform, operating under strict data processing agreements.
• Regulatory and legal authorities: Where required by law, court order, or the conditions of our gaming licence, cly88 may disclose personal data to applicable authorities, including anti-money-laundering regulators and law enforcement agencies.
• Professional advisers: Lawyers, auditors, and insurers who provide professional services to cly88, subject to confidentiality obligations.

As an internationally licensed gaming operator, cly88 may transfer personal data to, or process personal data in, jurisdictions outside of Malaysia. Where such transfers occur, cly88 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required in your home jurisdiction.

Safeguards may include: standard contractual clauses approved by relevant data protection authorities, data processing agreements with binding obligations on recipient parties, or transfers to jurisdictions assessed to provide an adequate level of data protection.

Where personal data is transferred to third-party processors in other countries, those processors are contractually prohibited from using your data for any purpose other than the specific service they are providing to cly88.

cly88 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including our legal and regulatory obligations. The following general retention periods apply:

• Account data and transaction records: Retained for a minimum of five (5) years following account closure, or longer where required by AML regulations or applicable law.
• KYC documents: Retained for a minimum of five (5) years from the date of verification, or the date of account closure, whichever is later, in accordance with anti-money-laundering obligations.
• Customer support communications: Retained for a minimum of two (2) years from the date of last interaction.
• Technical and log data: Typically retained for up to twelve (12) months for operational and security purposes.
• Marketing consent records: Retained for the duration of your subscription to marketing communications and for a reasonable period thereafter to evidence consent history.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification. Where deletion is not technically feasible within normal operational systems (such as backup archives), data remains subject to this Policy and is not actively processed until deletion occurs.

cly88 uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are in use:

• Strictly necessary cookies: Essential for the operation of the platform, including session authentication, security functions, and load balancing. These cookies cannot be disabled without impairing platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gambling tool configurations.
• Analytics cookies: Used to collect anonymised data on how Members use the platform, enabling cly88 to identify performance issues and improve the user experience. Analytics data is aggregated and does not identify individual users.
• Marketing and tracking cookies: Where you have consented, these cookies may be used to deliver relevant platform promotions and to measure the effectiveness of our marketing activities. You may withdraw consent at any time.

You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to use core platform features. A cookie consent notice is presented on your first visit to the platform, through which you can set your preferences for non-essential cookie categories.

Subject to applicable law, you have the following rights over your personal data held by cly88. To exercise any of these rights, contact our support team as described in Section 16.

cly88 implements a multi-layered security framework designed to protect personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption at rest for all personal data and KYC documents stored within our infrastructure.
• Two-factor authentication (2FA) available for Member accounts, strongly recommended for all users.
• Access controls: Strict role-based access to personal data by staff, with access limited to those whose specific job function requires it.
• Regular security audits and penetration testing by independent third-party security assessors.
• Real-time fraud and anomaly detection systems monitoring for unusual account activity, unauthorised login attempts, and transaction irregularities.
• Incident response procedures designed to detect, contain, and notify relevant parties in the event of a personal data breach, in accordance with applicable regulatory requirements.

While cly88 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your account credentials confidential. cly88 will never ask for your password through any communication channel.

The cly88 platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. Age verification is a mandatory component of the KYC process, and accounts found to belong to individuals under 21 will be closed immediately with any balance returned to the verified payment source where possible.

If you have reason to believe that a minor has registered an account on the cly88 platform, please contact us immediately using the details in Section 16. We will investigate and take appropriate action as a matter of priority.

The cly88 platform may reference third-party payment processors, technology partners, or services. Where interaction with a third-party service is required (for example, completing a DuitNow or FPX transaction through your bank's interface), that third party's own privacy policy and data practices apply to the data you provide to them directly.

cly88 is not responsible for the privacy practices of any third-party services. We encourage you to review the privacy policies of any third-party service you interact with in connection with your cly88 account. Our responsibility for your data extends only to data that passes through cly88's own systems.

cly88 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or our service offering. Material changes will be notified to existing Members via the email address registered on their account or through a prominent in-platform notification at least 14 days before the amendment takes effect, where reasonably practicable.

The "Last Updated" date at the top of this Policy will reflect the date of the most recent revision. We encourage you to review this Policy periodically. Continued use of the platform after an amendment takes effect constitutes acceptance of the revised Policy. If you disagree with any material change, you should close your account and request the deletion of your personal data as described in Section 11.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the cly88 Data Privacy team through the following channels:

• 24/7 Live Chat: Accessible directly on the cly88 platform. For privacy-related requests, please state clearly that your inquiry is a data protection matter. Average response time: 3–5 minutes.
• Email: [email protected] — mark your email subject line "Privacy Request" to ensure prompt routing to our data privacy team. (Plain text address — not a clickable link.)
• Written requests: For formal data rights requests, we recommend submitting your inquiry in writing via the email address above, including your full registered name and the specific right or concern you wish to raise. We may request identity verification before processing your request.

cly88 takes all privacy inquiries seriously and is committed to responding promptly and transparently. We aim to resolve all data rights requests within 30 calendar days of receipt of a complete, verifiable request.