Privacy Policy — How3we Protects Your Personal Data

This Privacy Policy ("Policy") issued by 3we ("3we", "we", "our", "the Company"), which operates the online gaming platform available at https://3we.cam ("the Platform", "the Website"). This Policy governs the collection, use, storage, disclosure, and protection of personal data relating to registered players, prospective players, and visitors to the Website ("you", "your", "the Data Subject").

3we is committed to protecting your personal data and handling it in a manner that is transparent, fair, and consistent with applicable data protection and privacy laws. By registering an account, accessing the Platform, or otherwise providing your personal information to 3we, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform generally. In the event of any conflict between this Policy and the Terms & Conditions with respect to data privacy matters, this Policy shall prevail.

The following terms carry the meanings set out below throughout this Privacy Policy:

Term	Meaning
"Personal Data"	Any information that identifies or can reasonably be used to identify a living individual, whether directly or in combination with other available data.
"Processing"	Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, alteration, or deletion.
"Controller"	3we, as the entity that determines the purposes and means of processing your Personal Data.
"Data Subject"	The individual whose Personal Data is being processed — in most cases, a registered player or Website visitor.
"Third Party"	Any entity other than 3we and the Data Subject, including payment processors, KYC verification providers, and IT infrastructure partners.
"Consent"	A freely given, specific, informed, and unambiguous indication by the Data Subject that they agree to the processing of their Personal Data for a stated purpose.
"Cookies"	Small text files placed on your device by the Website to facilitate platform functionality, analytics, and personalised user experience.

3we collects personal data through a variety of channels in the course of providing and improving the Platform. The categories of data we collect are set out below.

3.1 Registration & Account Data

When you register a player account on3we, we collect:

• Full legal name (as it appears on your government-issued identity document).
• Date of birth (for age verification — players must be at least 21 years of age).
• Residential address, including city (e.g., Kuala Lumpur, Petaling Jaya, Johor Bahru, Shah Alam, or Penang) and postcode.
• Email address and mobile phone number.
• Username and encrypted password credentials.
• Preferred currency (MYR) and language settings.

3.2 KYC & Identity Verification Data

To comply with our anti-money laundering (AML) obligations and to verify player identity, we collect:

• Copies of government-issued identity documents (e.g., Malaysian MyKad or passport).
• Proof of residential address documents (e.g., utility bill or bank statement dated within the last three months).
• Proof of payment method ownership (e.g., e-wallet account screenshot or bank statement header).
• Source of funds declarations where required by our compliance programme.

3.3 Financial Transaction Data

When you make deposits or withdrawal requests on3we, we record:

• Transaction type, amount (in MYR), date, and time.
• Payment method used (e.g., Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, or cryptocurrency).
• Transaction reference numbers and associated metadata.

3we does not store full card numbers or complete online banking credentials. All sensitive payment data is handled directly by our certified third-party payment processors.

3.4 Gameplay & Platform Activity Data

• Games played, bet amounts, wager outcomes, and session durations.
• Sports betting selections and live betting activity (e.g., Liga Super Malaysia, EPL, UFC).
• Bonus and promotion usage history.
• Login timestamps, IP addresses, and device identifiers.

3.5 Communications Data

• Records of customer support interactions via live chat, email ([email protected]), or any other support channel.
• Feedback, complaints, and survey responses submitted to3we.

3.6 Technical & Usage Data

• Browser type and version, operating system, and device type.
• Pages visited, time spent on each page, and navigation patterns within the Website.
• Referral URL and marketing attribution data (where you arrived from).

3we uses the personal data we collect for the following purposes:

Purpose	Details
Account Management	Creating, maintaining, and securing your player account; verifying your identity and age; processing login and session management.
Transaction Processing	Processing deposits and withdrawal requests in MYR; verifying payment source ownership; resolving transaction disputes.
KYC & AML Compliance	Verifying player identity in accordance with our regulatory obligations; monitoring transactions for suspicious activity; maintaining compliance records.
Platform Operation	Delivering gaming services; maintaining platform performance; detecting and preventing technical faults and security breaches.
Customer Support	Responding to enquiries, complaints, and support requests; maintaining records of interactions for quality assurance and dispute resolution.
Responsible Gambling	Monitoring gameplay patterns to identify problem gambling indicators; administering self-exclusion, deposit limits, and cooling-off periods.
Marketing & Promotions	Sending promotional offers, bonus notifications, and platform updates where you have provided consent; personalising promotional content based on your activity.
Analytics & Improvement	Analysing aggregated usage data to improve platform design, game selection, and user experience for all Malaysian players.
Legal & Regulatory	Complying with applicable laws; responding to lawful requests from regulatory or law enforcement authorities; enforcing our Terms & Conditions.

3we processes your personal data on the following legal grounds, which may apply individually or in combination depending on the specific processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions — including account creation, transaction processing, and delivering the gaming services you have requested.
• Legal Obligation: Processing necessary for compliance with applicable laws, including AML regulations, KYC requirements, and record-keeping obligations imposed by regulatory authorities.
• Legitimate Interests: Processing carried out for the legitimate business interests of 3we — such as fraud prevention, platform security, responsible gambling monitoring, and internal analytics — where those interests are not overridden by your rights and interests.
• Consent: Processing for optional purposes such as direct marketing communications, where we rely on your freely given and specific consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

3we does not sell your personal data to third parties. We may share your personal data with carefully selected third parties only in the following circumstances and subject to appropriate data protection obligations:

• Payment Processors: To facilitate deposits and withdrawals via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Malaysian banks (Maybank, CIMB, Public Bank, Hong Leong), and cryptocurrency networks. These processors are certified and bound by their own security and data protection standards.
• KYC & Identity Verification Providers: Third-party identity verification services used to confirm player identity and age in compliance with our KYC obligations. These providers receive only the minimum data necessary for verification purposes.
• IT Infrastructure & Cloud Providers: Hosting, server, and technology service providers who support the operation of the Platform. All such providers operate under data processing agreements with 3we that restrict their use of your data.
• Fraud Prevention & Security Services: Specialist security providers engaged to detect and prevent fraudulent transactions, account takeover attempts, and other malicious activity on the Platform.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order, or regulatory directive, 3we may disclose personal data to relevant authorities. We will notify affected players where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all of 3we's assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections being maintained.

3we uses cookies and similar technologies to operate and improve the Platform. Cookies are small data files stored on your device when you visit the Website. They enable core platform functions, help us understand how players interact with the Website, and allow us to personalise your experience.

The categories of cookies used on 3we are as follows:

Cookie Type	Purpose	Duration
Strictly Necessary	Required for core platform functions including login session management, security tokens, and transaction processing. Cannot be disabled.	Session / up to 1 year
Performance & Analytics	Collects anonymised usage data to help us understand how players navigate the Platform and identify areas for improvement.	Up to 2 years
Functional	Remembers your language preferences, display settings, and responsible gambling tool configurations between sessions.	Up to 1 year
Marketing	Used to deliver relevant promotional content and track the effectiveness of marketing campaigns where you have provided consent.	Up to 90 days

You can manage or withdraw your consent to non-essential cookies through your browser settings or the cookie preference centre on the Platform. Disabling strictly necessary cookies may impair your ability to use certain Platform features.

3we retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law. The general retention principles we apply are as follows:

• Active Account Data: Retained for the duration of your account's active status and for period of five (5) years following account closure, to meet AML record-keeping and audit requirements.
• KYC Documentation: Retained for a minimum of five (5) years from the date of completion of the business relationship, in accordance with applicable AML legislation.
• Financial Transaction Records: Retained for a minimum of seven (7) years to satisfy financial record-keeping and tax compliance obligations.
• Customer Support Records: Retained for three (3) years from the date of the interaction, to support dispute resolution and quality assurance reviews.
• Marketing Consent Records: Retained for the duration of the marketing relationship and for three (3) years following withdrawal of consent, as evidence of the consent given.
• Technical Logs: Retained for up to twelve (12) months for security monitoring and fraud detection purposes, after which they are anonymised or deleted.

When personal data is no longer required for any lawful purpose, 3we securely deletes or irreversibly anonymises it in accordance with our internal data disposal procedures.

3we implements a multi-layered approach to data security that encompasses technical, organisational, and procedural safeguards. Key security measures include:

• End-to-End Encryption: All data transmitted between your device and 3we servers is encrypted using TLS 1.2 or higher. Data at rest is encrypted using AES-256 encryption standards.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All internal access is logged, reviewed, and subject to regular audit.
• Penetration Testing: 3we engages independent cybersecurity specialists to conduct regular penetration testing and vulnerability assessments of the Platform.
• Incident Response: 3we maintains a documented data breach response procedure. In the event of a security incident that poses a material risk to your rights, affected players will be notified in accordance with applicable legal requirements.
• Payment Security: Payment credentials are processed exclusively through PCI-DS-compliant payment gateways. 3we does not store card or full banking credentials on its own systems.
• Staff Training: All staff with access to personal data receive regular data protection training and are bound by confidentiality obligations.

While 3we takes all reasonable and practicable measures to protect your personal data, no electronic transmission or storage system is completely immune from security risks. You are responsible for maintaining the security of your own account credentials and for notifying 3we promptly if you suspect any unauthorised access to your account.

As a Data Subject, you have a number of rights with respect to your personal data held by 3we. These rights are summarised below. To exercise any of these rights, please contact our support team at [email protected]. We will respond to verified requests within thirty (30) days.