Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is published by a66cool ("the Company", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at https://a66cool.cam ("the Platform"). This Policy governs the collection, use, storage, disclosure, and protection of personal data provided by or collected from users ("User", "you", "your") of the Platform.

By registering an account, accessing the Platform, or using any of our services — including online casino games, sports betting markets, live dealer tables, and customer support channels — you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

This Policy should be read in conjunction with our Terms & Conditions, which together constitute the full agreement between you and a66cool governing your use of the Platform.

2. Definitions

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

Term	Meaning
"Personal Data"	Any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, and online identifiers.
"Processing"	Any operation performed on Personal Data, including collection, storage, use, disclosure, transmission, alteration, or deletion.
"Data Controller"	The entity that determines the purposes and means of Processing Personal Data — in this context, a66cool.
"Data Processor"	A third party that processes Personal Data on behalf of a66cool strictly in accordance with our instructions and this Policy.
"Consent"	A freely given, specific, informed, and unambiguous indication of agreement to the Processing of Personal Data for a stated purpose.
"Cookie"	A small text file placed on a user's device by a website to store session or preference information.
"KYC"	Know Your Customer — identity and address verification procedures required under applicable compliance obligations.

3. Data Controller Identity

a66cool acts as the Data Controller in respect of all Personal Data collected through or in connection with the Platform. All decisions regarding the purposes for which your Personal Data is collected and the manner in which it is processed are made by a66cool.

For all privacy-related enquiries, data access requests, correction requests, deletion requests, or complaints, please contact our Data Protection team using the contact details provided in Section 16 of this Policy.

4. Personal Data We Collect

a66cool collects Personal Data across several categories depending on the nature of your interaction with the Platform. The categories of data we collect, and typical examples within each, are set out in the table below:

Category	Examples
Identity Data	Full legal name, date of birth, nationality, MyKad (NRIC) number, passport number, driver's licence number, selfie photographs, and other identity document data submitted during KYC verification.
Contact Data	Email address, mobile phone number, residential address (city, state, postcode), and correspondence records.
Financial Data	Payment method identifiers (e.g., masked bank account numbers, e-wallet identifiers for Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX), transaction history, deposit amounts in MYR, withdrawal requests, and source-of-funds documentation.
Account & Gaming Data	Username, account preferences, login timestamps, session durations, game history, betting activity, wager amounts, bonus claims, and VIP tier status.
Technical Data	IP address, device type and model, operating system, browser type and version, screen resolution, referring URL, and cookie identifiers.
Communications Data	Records of live chat conversations, email correspondence, support ticket content, and any feedback or survey responses you submit.
Behavioural Data	Clickstream data, page view sequences, feature usage patterns, promotional offer interactions, and responsible gambling tool usage.

5. How We Collect Personal Data

We collect Personal Data through the following channels:

5.1 Directly from You

When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in promotions, or submit any form on the Platform, you provide Personal Data to us directly.

5.2 Automatically

When you access the Platform, we automatically collect Technical Data and Behavioural Data through cookies, web beacons, server logs, and similar tracking technologies as described in Section 10 of this Policy.

5.3 From Third Parties

We may receive Personal Data about you from the following third-party sources:

• Payment Processors: Malaysian payment service providers including Maybank, CIMB, Public Bank, Hong Leong, DuitNow, and FPX operators may provide transaction confirmation data to facilitate payment processing and fraud prevention.
• Identity Verification Partners: Third-party KYC service providers who assist us in verifying the authenticity of identity documents submitted during account verification.
• Fraud and Compliance Databases: Industry-standard responsible gambling registers, sanctions screening databases, and anti-fraud monitoring services.
• Analytics Providers: Aggregated and anonymised platform usage data from analytics service providers to support Platform performance improvement.

6. Data Processing & Use

a66cool processes your Personal Data for the following purposes:

• Account Management: Creating, maintaining, and administering your registered account, including authentication and security verification.
• Service Delivery: Enabling you to access and use the Platform's gaming and sports betting services, processing your deposits and withdrawals in MYR, and administering bonuses and promotions.
• Identity Verification (KYC): Verifying your identity and address in compliance with applicable regulatory obligations, including age verification to enforce the 21+ age requirement.
• Financial Processing: Executing payment instructions, preventing fraud and unauthorised transactions, and maintaining accurate financial records of all account activity.
• Customer Support: Responding to your enquiries, resolving disputes, processing complaints, and providing technical assistance.
• Regulatory Compliance: Fulfilling our legal obligations under applicable anti-money laundering, counter-terrorism financing, and responsible gambling regulations.
• Responsible Gambling: Monitoring gaming behaviour to identify potential problem gambling indicators, administering self-exclusion requests, and enforcing deposit and wagering limits set by you or required by our compliance obligations.
• Platform Security: Detecting, investigating, and preventing fraudulent activity, account takeover attempts, prohibited conduct, and other security threats.
• Platform Improvement: Analysing aggregated usage patterns, conducting A/B testing, and improving the functionality, performance, and user experience of the Platform.
• Marketing Communications: Where you have provided consent, sending you promotional offers, bonus notifications, and news relevant to your use of the Platform. You may withdraw consent at any time as described in Section 12.

7. Legal Basis for Processing

a66cool relies on the following legal bases to process your Personal Data:

• Contractual Necessity: Processing required to perform our contract with you — specifically, the Terms & Conditions governing your account — including account creation, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC verification, anti-money laundering obligations, and responsible gambling requirements.
• Legitimate Interests: Processing carried out for the legitimate interests of a66cool, including fraud prevention, Platform security, and Platform improvement, where these interests are not overridden by your rights and interests.
• Consent: Where you have specifically consented to Processing for a particular purpose, such as receiving marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

8. Data Sharing & Disclosure

a66cool does not sell, rent, or trade your Personal Data to third-party advertisers or commercial data brokers under any circumstances. We may share your Personal Data only in the following limited circumstances:

8.1 Service Providers and Data Processors

We engage trusted third-party service providers who process Personal Data on our behalf strictly in accordance with our instructions and under contractual obligations of confidentiality. These include payment processors, KYC verification providers, cloud infrastructure providers, customer support platform operators, and fraud detection services.

8.2 Regulatory and Law Enforcement Authorities

We may disclose Personal Data to regulators, law enforcement agencies, courts, or other competent authorities where required by applicable law, a valid legal order, or in connection with an investigation into fraudulent, unlawful, or suspicious activity. We will notify you of such disclosures where legally permitted to do so.

8.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of a66cool's business, your Personal Data may be transferred to the acquiring entity as part of the transaction. We will provide notice of any such transfer and the applicable privacy terms before your data is transferred or becomes subject to a different privacy policy.

8.4 Responsible Gambling Registers

Where required by our responsible gambling obligations, we may share limited data with industry-wide self-exclusion or responsible gambling registers to honour your self-exclusion requests across participating operators.

9. Data Retention

a66cool retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, to comply with applicable legal obligations, and to resolve disputes or enforce our agreements. Indicative retention periods are as follows:

• Account and KYC records: For the duration of the account relationship plus a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• Transaction and financial records: A minimum of seven (7) years from the date of each transaction, consistent with applicable financial record-keeping obligations.
• Customer communications: Up to three (3) years from the date of the last communication, unless longer retention is required for dispute resolution or regulatory purposes.
• Marketing consent records: For the period during which consent is active, plus two (2) years following withdrawal of consent as evidence of prior consent status.
• Technical and behavioural data: Typically up to twenty-four (24) months in identifiable form, after which it is aggregated or anonymised.

When Personal Data is no longer required, we delete or irreversibly anonymise it in a secure manner.

10. Cookies & Tracking Technologies

a66cool uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit the Platform. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management, authentication, and security features. These cannot be disabled without impairing core Platform functionality.
• Performance and Analytics Cookies: Collect anonymised or aggregated data about how users interact with the Platform — such as pages visited, session duration, and error occurrences — to help us improve Platform performance.
• Functionality Cookies: Remember your preferences, such as language settings, display options, and responsible gambling limit configurations, to personalise your experience.
• Targeting and Marketing Cookies: Used to deliver relevant promotional content based on your activity on the Platform. These are only deployed where you have provided consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may limit the functionality of the Platform. For further details on specific cookies used, please contact our support team.

11. Data Security

a66cool implements comprehensive technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, or alteration. Our security framework includes:

• Encryption: All data transmitted between your device and the Platform is protected by 256-bit SSL/TLS encryption. Sensitive data stored at rest is encrypted using industry-standard algorithms.
• Access Controls: Strict role-based access controls ensure that employee access to Personal Data is limited to those with a legitimate operational need. All access is logged and audited.
• Two-Factor Authentication: Available to all users and mandatory for administrative accounts to prevent unauthorised account access.
• Vulnerability Management: Regular security assessments, penetration testing, and patch management procedures to identify and remediate security vulnerabilities.
• Incident Response: A documented data breach response procedure, including notification obligations to affected users and relevant authorities where required by law.

12. Your Data Rights

As a user of the a66cool Platform, you hold the following rights in respect of your Personal Data. To exercise any of these rights, please contact our Data Protection team using the details in Section 16. We will respond to all verifiable requests within a reasonable period and in any event within the timeframe required by applicable law.

13. Minors & Age Policy

The Platform is strictly prohibited for use by persons under the age of 21. a66cool does not knowingly collect, process, or retain Personal Data from individuals under 21 years of age. Age verification is a mandatory component of the registration and KYC process for all new accounts.

If we become aware that Personal Data has been collected from a person under the age of 21, we will promptly suspend the relevant account, delete the collected data where not required for compliance purposes, and refund any deposits made in accordance with applicable requirements. If you believe a minor has registered an account on the Platform, please contact us immediately using the details in Section 16.

14. International Data Transfers

In the course of providing our services, your Personal Data may be transferred to, or processed in, countries outside of your country of residence. Where such transfers occur, a66cool ensures that appropriate safeguards are in place to protect your Personal Data at a standard equivalent to the protections described in this Policy.

Safeguards we rely upon for international transfers include contractual obligations imposed on recipients through data processing agreements, binding corporate rules, and reliance on adequacy determinations where applicable. If you require further information regarding the specific safeguards applicable to any particular transfer, please contact us.

15. Amendments to This Policy

a66cool reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform operations. Where changes are material, we will provide reasonable advance notice via email notification to registered users or through a prominent notice on the Platform prior to the effective date of the updated Policy.

The current version of this Policy, along with its effective date, is always available on this page. Your continued use of the Platform following publication of a revised Policy constitutes acceptance of the updated terms. If you do not agree with the updated Policy, you should cease using the Platform and may request account closure by contacting our support team.

16. Contact Us

For all privacy-related enquiries, data subject access requests, correction or deletion requests, consent withdrawal requests, or complaints regarding our data practices, please contact our Data Protection team using the details below: