Privacy Policy

This Privacy Policy ("Policy") is issued by Betwos ("Company", "we", "us", "our") and applies to all personal data collected through the Betwos platform accessible at https://betwos.cam (the "Platform"), including our website and any associated services.

Betwos is an English-language online gaming and sports betting platform serving Malaysian players. We are committed to protecting the privacy and security of all personal data entrusted to us by our users ("Player", "you", "your"). We recognise that privacy is a fundamental right and that transparency about how we process your data is essential to maintaining your trust.

This Policy sets out the categories of personal data we collect, the purposes for which that data is used, the conditions under which it may be disclosed to third parties, and the rights available to you in relation to your personal data.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, which together govern your relationship with Betwos.

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

• "Personal Data" means any information that identifies or could identify a living individual, directly or indirectly, including name, email address, IP address, device identifiers, and financial account details.
• "Processing" means any operation performed on Personal Data, whether or not by automated means, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means Betwos, as the entity that determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means any third party that processes Personal Data on behalf of Betwos pursuant to a written data processing agreement.
• "Consent" means any freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• "KYC Data" means identity and age verification documents submitted by Players as part of the Know Your Customer process, including government-issued identification such as a Malaysian MyKad, passport, or driver's licence.
• "Cookie" means a small text file stored on a Player's device by a web browser for the purpose of tracking, session management, or analytics.
• "Platform" means the Betwos website, mobile application, and all associated digital services.

Betwos collects the following categories of Personal Data, depending on how you interact with the Platform:

We do not collect sensitive Personal Data beyond what is required for KYC and age verification compliance. We do not collect biometric data, health data, or political opinions.

We collect Personal Data through the following means:

• Direct submission: Information you provide when creating your account, completing KYC, making deposits or withdrawals, or contacting customer support.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Payment processors: Financial transaction data received from our payment service providers, including Malaysian banks (Maybank2u, CIMB Clicks, Public Bank, Hong Leong Connect), e-wallet providers (Touch 'n Go eWallet, Boost, GrabPay), DuitNow, FPX, and cryptocurrency network confirmations.
• Identity verification providers: Data returned from third-party KYC and document verification services that assist us in confirming Player identity and age.
• Third-party analytics: Aggregated and anonymised behavioural data from analytics services used to improve Platform performance and user experience.

Betwos processes your Personal Data for the following specific purposes:

1. Account management: To create, maintain, and administer your Betwos account, including account verification, password resets, and account closure.
2. Identity and age verification (KYC): To verify that you are at least 21 years of age and to confirm your identity in compliance with applicable regulations. This is a mandatory process for full account activation.
3. Transaction processing: To process deposits and withdrawals in MYR via Malaysian payment methods and cryptocurrency networks, and to maintain accurate financial records.
4. Service delivery: To provide access to games, live casino, and sportsbook products available on the Platform, including personalisation of content based on your gaming history.
5. Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, multi-accounting, money laundering, and other prohibited activities that may harm players or the Platform.
6. Responsible gambling compliance: To monitor gameplay patterns for indicators of problem gambling behaviour and to enforce responsible gambling tools such as deposit limits and self-exclusion.
7. Customer support: To respond to your enquiries, resolve disputes, and maintain records of support interactions.
8. Marketing communications: To send promotional offers, bonus notifications, and product updates to Players who have opted in to receive such communications. You may opt out at any time.
9. Legal compliance: To meet our obligations under applicable laws and regulations, including anti-money-laundering requirements and data retention obligations.
10. Platform improvement: To analyse usage patterns and technical performance data for the purpose of improving the Platform's functionality, speed, and user experience.

Betwos processes your Personal Data under the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions, including account management, transaction processing, and KYC compliance.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit opt-in consent. Consent may be withdrawn at any time.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gambling compliance, where our interests are balanced against and do not override your privacy rights.
• Legal obligation: Processing required to comply with applicable laws, regulatory requirements, court orders, or the lawful requests of regulatory authorities.

Betwos does not sell your Personal Data to third parties under any circumstances. We may share your data with the following categories of recipients only where strictly necessary and subject to appropriate data protection obligations:

• Payment service providers: Malaysian banks, e-wallet operators (including Touch 'n Go eWallet, Boost, GrabPay), DuitNow, FPX, and cryptocurrency payment processors — solely for the purpose of processing transactions.
• KYC and identity verification providers: Third-party services that assist in verifying Player identity and age, operating under binding data processing agreements.
• Game content providers: Game studios and content licensors who may receive anonymised gameplay data for the purpose of game performance analysis and RTP reporting.
• IT and platform infrastructure providers: Cloud hosting, security, and software service providers who process data on our behalf under strict contractual controls.
• Customer support tools: Helpdesk and live chat software providers used to facilitate support interactions.
• Regulatory authorities and law enforcement: Where we are required by law, court order, or regulatory instruction to disclose Personal Data, we will comply with such lawful requests.
• Anti-fraud and AML networks: Shared fraud detection and anti-money-laundering databases where disclosure is required to prevent or investigate financial crime.

All third-party processors are contractually bound to process your data only for the specified purposes, to maintain appropriate security standards, and not to further disclose your data without our authorisation.

Betwos retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention guidelines apply:

• Account data: Retained for the duration of your active account relationship and for a minimum of five (5) years following account closure, in accordance with anti-money-laundering record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support correspondence: Retained for up to three (3) years from the date of the interaction, unless retention is required for an ongoing dispute or legal matter.
• Marketing data: Retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations.

Following the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents identification.

Betwos implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our Platform.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• Access controls restricting Personal Data access to authorised personnel on a need-to-know basis.
• Multi-factor authentication for internal systems and administrative access.
• Regular security assessments, penetration testing, and vulnerability scanning.
• Incident response procedures in place to detect, contain, and report data security breaches within applicable regulatory timeframes.

Betwos uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for Platform operation, including session management, authentication, and security functions. These cannot be disabled without affecting core Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display preferences, to provide a more personalised experience.
• Analytics cookies: Used to collect anonymised data about how Players navigate and use the Platform, enabling us to identify areas for improvement. Analytics data is aggregated and does not identify individual users.
• Preference cookies: Used to track your responsible gambling settings, including deposit limit configurations and session reminder preferences.

Non-essential cookies are only deployed with your consent. You may manage your cookie preferences at any time via your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

Betwos does not use third-party advertising cookies or behavioural targeting technologies that track you across external websites.

As a data subject, you hold the following rights in relation to your Personal Data held by Betwos. To exercise any of these rights, please contact our support team with your request. We will respond within a reasonable timeframe, and in any event within thirty (30) days of receipt.

• Right of Access: You have the right to request a copy of all Personal Data we hold about you, together with information about how it is 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, subject to legal retention obligations that may override this right.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your data in certain circumstances, including where you contest its accuracy or object to its use.
• Right to Data Portability: Where processing is carried out by automated means on the basis of your consent or a contract, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes. 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 consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please contact us at [email protected] (plain text — not a clickable link). We may require identity verification before processing your request.

The Betwos Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain Personal Data from individuals below the age of 21.

As part of our registration and KYC process, all Players are required to verify their age by submitting valid government-issued identification. Accounts found to belong to persons under the age of 21 will be immediately closed, all balances forfeited, and any Personal Data associated with the account deleted in accordance with this Policy and our legal obligations.

The Betwos Platform may contain references to third-party services, including payment providers and game software studios. These third parties operate their own independent privacy policies, and Betwos is not responsible for the privacy practices of those entities.

Where you interact with a third-party service through the Platform — for example, when completing a payment via Touch 'n Go eWallet, Maybank2u, or FPX — your interaction with that service is subject to the privacy policy of the respective service provider.

All third-party Data Processors engaged by Betwos are contractually required to comply with data protection obligations equivalent to those set out in this Policy.

Betwos reserves the right to update or amend this Privacy Policy at any time. Material changes — including changes to the categories of data collected, the purposes of processing, or your rights — will be communicated to registered Players via email or a prominent notice on the Platform at least seven (7) days before taking effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. We encourage you to review this Policy periodically to stay informed of how we protect your data.

Your continued use of the Platform following the effective date of any revised Policy constitutes acceptance of the updated terms.

For any privacy-related queries, data subject access requests, complaints, or concerns regarding how Betwos handles your Personal Data, please reach out through the following channels:

• Email (plain text only): [email protected]
• Live Chat: Available on the Platform, 24 hours a day, 7 days a week
• Subject line for data requests: "Privacy Request — [Your Account Username]"
• Response timeframe: We aim to acknowledge all privacy requests within 5 business days and provide a full response within 30 days.

If you are unsatisfied with our response to your privacy enquiry, you may have the right to lodge a complaint with a relevant data protection supervisory authority in your jurisdiction.