Senju33 Privacy Policy

1. Introduction

Senju33 operates an online casino and sports betting platform accessible to eligible players including those located in Malaysia, and processes personal information as part of that operation. This Privacy Policy explains who we are, what personal data we collect, why we collect it, how we use and protect it, who we may share it with, how long we keep it, and what rights you hold as a data subject.

By registering an account, using any Senju33 service, or submitting information to the platform, you acknowledge that you have read this Privacy Policy. If you disagree with any part of it, you should refrain from using Senju33. This document is supplemented by our Terms & Conditions and any specific terms attached to individual promotions or features.

2. Definitions

In this policy, the following terms carry the stated meaning:

• Personal Data: any information that identifies or could reasonably identify a natural person, including name, identification number, contact details, payment data, device identifiers, and behavioural records linked to an account.
• Processing: any operation performed on personal data — including collection, storage, retrieval, use, disclosure, transmission, combination, restriction, or deletion.
• Data Controller: the entity determining the purposes and means of processing. Senju33 acts as data controller for player account data.
• Data Processor: a third party that processes personal data on behalf of and under instructions from Senju33, such as a payment gateway or KYC verification service.
• You / Player: the natural person accessing or registered on the Senju33 platform.
• We / Senju33: the operator of the Senju33 platform and associated services.

3. Personal Data We Collect

The categories of data Senju33 collects depend on how you interact with the platform. The principal categories are described below.

We do not request or store payment card CVV numbers, full account passwords, or complete card numbers beyond the tokenised reference provided by our payment partners.

4. How We Use Personal Data

Senju33 processes personal data for the following purposes:

• Account registration and management: to create and maintain player accounts, verify identity and age, and keep registration records accurate.
• Service provision: to operate games, settle wagers, administer deposits and withdrawals in MYR through Malaysian payment methods (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank), and deliver platform features.
• Age and eligibility verification: to ensure all active players are 21 years of age or above and meet other eligibility requirements.
• Compliance and regulatory obligations: to meet applicable anti-money-laundering, know-your-customer, fraud prevention, and responsible-gambling obligations.
• Security and fraud prevention: to protect accounts, detect suspicious activity, prevent unauthorised access, and investigate potential policy breaches.
• Customer support: to handle enquiries, complaints, disputes, and responsible-gambling requests efficiently.
• Responsible gambling: to monitor activity for signs of problem gambling and provide interventions including deposit-limit enforcement and self-exclusion.
• Platform improvement: to analyse anonymised or aggregated usage data and improve game selection, payment flows, and platform performance.
• Marketing communications: to send promotional offers and updates, subject to your stated communication preferences and any consent requirements.

5. Legal Basis for Processing

Senju33 processes personal data on one or more of the following grounds, as applicable to each processing activity:

• Contractual necessity: processing required to register an account, execute a wager, process a payment, or respond to a support request.
• Legal obligation: processing required to comply with applicable anti-money-laundering rules, age-verification requirements, or regulatory directions.
• Legitimate interests: processing necessary for platform security, fraud prevention, dispute resolution, and responsible-gambling monitoring — where those interests are not overridden by your privacy rights.
• Consent: processing undertaken for non-essential marketing communications, where valid consent has been obtained and may be withdrawn at any time.

6. Data Sharing and Third Parties

Senju33 does not sell personal data. We may share information with the following categories of recipients in the circumstances described:

• Payment service providers: Malaysian e-wallet operators, banks, FPX gateway, and card networks necessary to process deposits and withdrawals. Each is a regulated financial entity bound by applicable data-protection and financial-crime-prevention obligations.
• Identity and KYC verification providers: specialist services that verify document authenticity, check for sanctions and politically-exposed-persons lists, and confirm age where required by compliance obligations.
• Game technology providers: licensed game studios whose software runs on the Senju33 platform may receive session data required for round settlement, audit, and dispute resolution.
• IT and hosting infrastructure: cloud hosting, content delivery, and cybersecurity service providers operating under contractual data-processing agreements with appropriate safeguards.
• Regulatory and law-enforcement authorities: where Senju33 is required or permitted by law to disclose data, for example in response to a court order, regulatory investigation, or lawful demand from a competent authority.
• Professional advisers: lawyers, auditors, and consultants engaged in confidence and subject to professional secrecy obligations.

Any disclosure to a third party is limited to what is necessary for the stated purpose. Third-party processors operate under written agreements that require them to implement appropriate technical and organisational security measures.

7. Data Retention

Senju33 retains personal data only as long as necessary for the purpose for which it was collected, or as required by applicable legal, regulatory, accounting, or dispute-resolution obligations. General retention guidance is set out below; actual periods may be longer where a specific legal obligation applies.

• Identity and KYC records: retained for a minimum of five years following account closure or the last transaction, to meet anti-money-laundering record-keeping requirements.
• Transaction and gaming activity: retained for a minimum of five years to support audits, disputes, and regulatory review.
• Support communications: retained for two years following the resolution of the relevant matter.
• Marketing consents: retained until consent is withdrawn, plus a reasonable period thereafter to demonstrate compliance.
• Self-exclusion records: retained indefinitely to prevent re-registration during an active exclusion period and to meet responsible-gambling obligations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

8. Security Measures

Senju33 applies layered technical and organisational controls to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure.

Organisational measures include access controls that limit staff access to personal data on a need-to-know basis, confidentiality obligations in employment contracts, and documented data-handling procedures. No transmission method or storage system is entirely immune to risk, but Senju33 takes all commercially reasonable steps to maintain the security and integrity of personal data.

Players are responsible for maintaining the security of their own account credentials. Senju33 will never ask you to reveal your password through live chat, email, or any other channel.

9. Cookies and Tracking Technologies

Senju33 uses cookies and similar technologies on the platform to support essential functionality, security, session management, and performance analysis. Categories of cookies used include:

• Strictly necessary cookies: required for login sessions, navigation, and secure payment flow. These cannot be disabled without significantly impairing platform functionality.
• Performance and analytics cookies: anonymous data used to understand aggregate user behaviour, identify technical issues, and improve platform performance.
• Functional cookies: used to remember user preferences such as language selection and account settings across sessions.

Browser settings may be adjusted to restrict or delete cookies; however, disabling essential cookies may prevent access to certain Senju33 features. Third-party analytics tools used by Senju33 are bound by data-processing agreements and do not permit use of your data for independent commercial purposes.

10. Minors and Age Restriction

Senju33 does not knowingly collect personal data from or provide services to individuals under 21 years of age. Age is verified during account registration and prior to first withdrawal through identity document checks. If Senju33 becomes aware that personal data relating to a person under 21 has been collected, the account will be closed, pending transactions will be reviewed, and the data will be handled in accordance with applicable legal requirements.

Parents or guardians who believe that a minor has registered on Senju33 should contact customer support immediately with relevant information so that the matter can be investigated promptly.

11. Your Rights as a Data Subject

Subject to applicable law and any overriding retention or legal-obligation requirements, you may exercise the following rights in relation to personal data that Senju33 holds about you:

To exercise any of the above rights, contact Senju33 support through the live chat or via the platform. We may need to verify your identity before processing a request. Requests will be addressed within a reasonable period, subject to legal obligations that may require continued retention of certain data.

12. International Data Transfers

Senju33 may transfer and store personal data on servers located outside Malaysia. Where such transfers occur, Senju33 takes steps to ensure that the recipient jurisdiction or the specific transfer arrangement provides an appropriate level of data protection. Measures employed may include standard contractual clauses, data-processing agreements with appropriate safeguards, or transfers to recipients in jurisdictions that maintain equivalent data-protection standards.

13. Marketing Communications and Preferences

Senju33 may contact registered players about promotions, new games, sports-betting offers, loyalty-programme updates, and platform news. You may opt out of marketing communications at any time by updating your account notification preferences or by contacting customer support.

Opting out of marketing will not affect transactional communications such as deposit confirmations, withdrawal notifications, KYC requests, account security alerts, or responsible-gambling messages, which are sent as part of the service regardless of marketing preferences.

14. Policy Updates

Senju33 may revise this Privacy Policy from time to time to reflect changes in our data practices, platform services, applicable laws, or regulatory guidance. The revised document will be published on this page with an updated effective date. Where a change is material, Senju33 may also notify active players through an in-platform message or email. Continued use of Senju33 following publication of a revised policy constitutes acceptance of the updated terms.

15. Contact Us

If you have questions about this Privacy Policy, wish to exercise a data subject right, or want to raise a privacy concern, please contact Senju33 through the 24/7 live chat available on the platform. You may also write to us at the email address below — please note that a reply is not guaranteed through email, and for urgent matters live chat will receive a faster response.

Email (plain text — not a clickable link):

[email protected]

When submitting a data rights request, please include your registered account email address, a clear description of your request, and sufficient information to allow us to verify your identity. Do not include passwords or full financial account numbers in any message sent through unsecured channels.