Privacy Policy

This Privacy Policy ("Policy") describes the data practices of Gembet368 ("the Company", "we", "us", "our") in connection with your use of the Gembet368 website at gembet368.cam, its mobile-optimised interface, and all related services (collectively, the "Platform").

We are committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection principles. By accessing or using the Platform, registering an Account, or making a deposit, you acknowledge that you have read and understood this 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 must discontinue your use of the Platform immediately. This Policy should be read alongside our Terms & Conditions, which govern your overall use of the Platform.

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, phone number, identification number, financial data, IP address, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, erasure, or destruction.
• "Data Subject" — the individual whose Personal Data is being processed; in the context of this Policy, this refers to registered Players and Platform visitors.
• "Controller" — the entity that determines the purposes and means of processing Personal Data; for this Platform, the Controller is Gembet368.
• "Processor" — a third party that processes Personal Data on behalf of the Controller, such as a payment processor or KYC verification provider.
• "Cookies" — small text files stored on your device by a website that contain information about your interaction with that website.
• "KYC" — Know Your Customer; the identity verification process required of all registered Players prior to withdrawal processing.

Gembet368 collects Personal Data through several channels, including direct provision by you during registration and use of the Platform, automatic collection through technical means, and receipt from third-party service providers.

3.1 Data You Provide Directly

3.2 Data Collected Automatically

When you access the Platform, certain technical data is collected automatically without requiring you to provide it explicitly. This includes:

• Device and technical data: IP address, browser type and version, operating system, device identifiers, screen resolution.
• Usage data: Pages visited, features accessed, time spent on each page, links clicked, wagering patterns, game preferences.
• Location data: General geographic location inferred from IP address (country and city level only; precise GPS location is not collected).
• Session data: Login timestamps, session duration, authentication events.

3.3 Data Received from Third Parties

We may receive Personal Data from third-party service providers engaged to assist with the operation of the Platform, including:

• Payment processors (such as providers facilitating Touch 'n Go eWallet, DuitNow, FPX, Maybank, CIMB Clicks, and cryptocurrency transactions) who may share transaction confirmation and fraud-screening data;
• Identity verification (KYC) providers who conduct document authentication and sanctions screening on our behalf;
• Analytics providers who aggregate anonymised usage data to help us understand platform performance.

We process your Personal Data only for specific, legitimate purposes. The primary purposes for which Gembet368 processes your data are as follows:

• Account creation and management: To register and maintain your Player account, verify your identity, and manage your account settings and preferences.
• Service delivery: To facilitate deposits, withdrawals, and wagers; to process transactions via your chosen payment method (including Touch 'n Go eWallet, DuitNow, FPX, Boost, GrabPay, Maybank2u, and CIMB Clicks); and to ensure your gaming experience functions correctly.
• KYC compliance: To verify your age, identity, and source of funds in accordance with our anti-money laundering obligations and responsible gambling commitments.
• Fraud prevention and platform security: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, bot activity, and other security threats.
• Responsible gambling: To monitor usage patterns that may indicate problem gambling behaviour and to facilitate deposit limits, session reminders, and self-exclusion requests.
• Customer support: To respond to your enquiries, resolve account disputes, and maintain records of support interactions for quality assurance purposes.
• Marketing and promotions: To send you promotional offers, bonus notifications, and platform updates where you have provided consent to receive such communications.
• Platform improvement: To analyse anonymised usage data in order to improve the Platform's design, performance, and content.
• Legal and regulatory compliance: To comply with applicable legal obligations, including responding to lawful requests from regulatory or law enforcement authorities.

Gembet368 processes your Personal Data on one or more of the following legal grounds:

• Contractual necessity: Processing is necessary to perform our contractual obligations to you as a registered Player — including account management, payment processing, and service delivery.
• Legal obligation: Processing is required to comply with applicable legal and regulatory requirements, including KYC verification, anti-money laundering screening, and reporting obligations.
• Legitimate interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Where processing is based on your consent — such as for direct marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Gembet368 does not sell, rent, or trade your Personal Data to any third party for their independent marketing or commercial purposes. We may, however, share your data with the following categories of recipients where necessary:

6.1 Service Providers and Processors

We engage third-party companies to perform services on our behalf. These parties act as Data Processors and are contractually bound to process your data only for the purposes we specify and to maintain appropriate security standards. Categories include:

• Payment processors and e-wallet operators (for facilitating deposits and withdrawals via Touch 'n Go eWallet, DuitNow, FPX, Boost, GrabPay, Maybank2u, CIMB Clicks, and cryptocurrency networks);
• Identity verification and KYC service providers;
• Cloud hosting and infrastructure providers;
• Customer support platform providers;
• Analytics and fraud-detection technology providers.

6.2 Regulatory and Law Enforcement Authorities

We may disclose Personal Data to regulatory bodies, licensing authorities, law enforcement agencies, or other governmental authorities where required to do so by applicable law, court order, or in connection with the investigation of suspected fraud, money laundering, or other unlawful activity.

6.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of our business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection commitments.

We retain your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. Specific retention periods include:

• Account data: Retained for the duration of your active account relationship with Gembet368, and for a minimum of five (5) years following account closure, to comply with anti-money laundering and financial record-keeping requirements.
• 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 applicable regulatory obligations.
• Transaction records: Retained for a minimum of five (5) years to satisfy financial reporting and anti-money laundering compliance requirements.
• Customer support records: Retained for three (3) years following resolution of the support interaction, for quality assurance and dispute resolution purposes.
• Technical and usage data: Retained in anonymised or aggregated form for up to two (2) years for platform analytics purposes.

Following the expiry of the applicable retention period, your data will be securely deleted or anonymised in a manner that prevents reconstruction of your identity.

Gembet368 implements a range of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption in transit: All data transmitted between your device and our servers is protected by Transport Layer Security (TLS) encryption (256-bit SSL). The Platform is accessible exclusively via HTTPS.
• Encryption at rest: Sensitive personal and financial data stored on our servers is encrypted at rest using industry-standard encryption protocols.
• Access controls: Access to Personal Data is restricted to authorised personnel only, on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Intrusion detection: We operate continuous monitoring systems designed to detect and respond to security incidents, unauthorised access attempts, and anomalous data access patterns.
• Regular security reviews: We conduct periodic security assessments and vulnerability testing to identify and remediate potential weaknesses in our infrastructure.

While we take these measures seriously and maintain them as a core operational priority, no internet-based system can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you in accordance with our legal obligations.

The Gembet368 Platform uses cookies and similar tracking technologies to provide certain platform functions, enhance user experience, and collect anonymised analytics data. We categorise cookies as follows:

9.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function. They include session management cookies that maintain your authenticated state, security tokens that protect against cross-site request forgery, and cookies that remember your language and display preferences. These cookies cannot be disabled without impairing core platform functionality.

9.2 Performance and Analytics Cookies

These cookies collect anonymised information about how visitors use the Platform — such as which pages are visited most frequently, how long users remain on each page, and where users navigate from. This data helps us understand platform usage patterns and make improvements. The data collected by these cookies does not identify individual users.

9.3 Functional Cookies

These cookies allow the Platform to remember your preferences and personalise your experience — for example, remembering your preferred display settings or recently accessed game categories. Disabling functional cookies may reduce the convenience of your experience but will not prevent core functionality.

9.4 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of the Gembet368 Platform. Browser-level cookie management instructions are available in your browser's help documentation.

As a Data Subject, you have the following rights in relation to your Personal Data held by Gembet368. To exercise any of these rights, please contact us using the details in Section 14 of this Policy.

• Right of Access: You have the right to request a copy of the Personal Data we hold about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data we hold about you.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where: it is no longer necessary for the purposes for which it was collected; you withdraw consent and no other legal basis exists for processing; or processing is unlawful. This right is subject to overriding legal and regulatory obligations that may require us to retain certain data.
• Right to Restrict Processing: You may request that we limit the processing of your Personal Data in certain circumstances, such as while a dispute over accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you have the right to receive a structured, machine-readable copy of the Personal Data you have provided to us.
• Right to Object: You have the right to object to processing based on legitimate interests, including the use of your data for direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

We will respond to verified data subject requests within a reasonable timeframe — ordinarily within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days with prior notification.

The Gembet368 Platform is strictly for use by individuals who are at least 21 years of age. We do not knowingly collect Personal Data from persons under 21. Age is verified as part of our mandatory KYC process.

If we become aware that Personal Data has been collected from an individual under 21, we will take immediate steps to delete that data and close the associated Account. Any funds deposited by an underage user will be returned in accordance with our anti-fraud procedures.

If you believe that we may have inadvertently collected data from an underage individual, please contact us immediately at the address provided in Section 14.

The Gembet368 Platform may contain references to or integrations with third-party services — such as payment processing interfaces operated by Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, or CIMB Clicks — which are governed by those third parties' own privacy policies.

Gembet368 is not responsible for the privacy practices of any third-party service provider. Once you interact with a third-party interface (such as your bank's online portal or an e-wallet app), any data you provide within that interface is subject to that third party's privacy terms and not this Policy.

We encourage you to review the privacy policies of any third-party services you use in connection with your Gembet368 account.

Gembet368 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform functionality. The "Last Updated" date at the top of this page will be revised accordingly whenever a material change is made.

Where a change is material, we will notify registered Players via an in-platform notification or an email to the address on their Account. Your continued use of the Platform following publication of an updated Policy constitutes acceptance of the revised terms. If you disagree with any changes, you should cease using the Platform and may request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by Gembet368, please contact our support team through the following channels:

When submitting a data access, correction, or deletion request, please include your full registered name, the email address associated with your Account, and a brief description of your request. We may require identity verification before processing your request to protect against unauthorised data access.