Privacy Policy

1. Introduction

This Privacy Policy (hereinafter referred to as the "Policy") is published by sbk21 (hereinafter referred to as "sbk21", "we", "us", or "our"), the operator of the online casino and sports betting platform accessible at https://sbk21.cam (hereinafter referred to as the "Platform").

This Policy explains how sbk21 collects, uses, stores, shares, and protects personal data in connection with the operation of the Platform and the provision of services to registered users (hereinafter referred to as "User", "you", or "your"). It applies to all personal data collected through the Platform, including data submitted during registration, during use of Platform Services, and through any contact with our customer support team.

By registering an account on the sbk21 Platform, you acknowledge that you have read this Policy, that you understand its contents, and that you consent to the collection and processing of your personal data as described herein. This Policy should be read alongside our Terms & Conditions, which govern the broader contractual relationship between you and sbk21.

2. Definitions

For the purposes of this Policy, the following terms shall carry the meanings assigned to them:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including but not limited to name, date of birth, email address, IP address, and payment information.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" means sbk21, the entity that determines the purposes and means of Processing Personal Data collected through the Platform.
• "Data Subject" means the individual whose Personal Data is being Processed — in this context, a registered User of the sbk21 Platform.
• "Third Party" means any natural or legal person other than sbk21 and the Data Subject, including sbk21's service providers and technology partners.
• "Cookies" means small text files stored on a User's device by a web browser, used to recognise returning users and analyse platform usage patterns.
• "KYC" means Know Your Customer — the identity verification process required for regulatory compliance purposes.

3. Personal Data We Collect

sbk21 collects Personal Data across three broad categories, as described in the table below:

4. How We Collect Your Data

4.1 Data You Provide Directly

The majority of Personal Data we hold is provided by you directly at various points of interaction with the Platform, including:

• When you complete the account registration form;
• When you submit KYC verification documents;
• When you make a deposit or request a withdrawal;
• When you contact our customer support team via live chat or email;
• When you opt in to a promotional offer or VIP programme tier;
• When you submit feedback, complaints, or dispute requests.

4.2 Data Collected Automatically

When you access and use the sbk21 Platform, certain technical data is collected automatically by our systems. This includes your IP address, browser type and version, device identifier, operating system, referring URL, pages visited, time spent on each page, and session timestamps. This data is collected through server logs, cookies, and similar tracking technologies as described in Section 10.

4.3 Data from Third Parties

sbk21 may receive Personal Data about you from the following categories of third parties where relevant to the operation of your account:

• Payment processors and e-wallet providers (e.g., confirmation of transaction status from Touch 'n Go eWallet, Boost, GrabPay, DuitNow, Maybank, CIMB, or Public Bank);
• Identity verification service providers used to cross-check KYC documentation;
• Fraud prevention and AML screening services;
• Our gaming licence regulatory authority, where required for compliance reporting.

5. Legal Basis for Processing

sbk21 processes your Personal Data on the following legal bases, depending on the nature and purpose of each Processing activity:

• Contractual Necessity: Processing required to fulfil our obligations to you under the Terms & Conditions — including account management, deposit processing, withdrawal handling, and provision of Platform Services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including Anti-Money Laundering (AML) obligations, Know Your Customer (KYC) requirements, and reporting obligations to our regulatory authority.
• Legitimate Interests: Processing carried out for sbk21's legitimate business interests, including fraud detection, platform security monitoring, responsible gambling monitoring, and service quality improvement, where these interests are not overridden by your fundamental rights.
• Consent: Where we rely on your consent as the legal basis for a specific Processing activity — for example, sending you promotional communications — you have the right to withdraw that consent at any time without affecting the lawfulness of Processing carried out prior to withdrawal.

6. How We Use Your Personal Data

sbk21 uses the Personal Data described in Section 3 for the following specific purposes:

• To create, administer, and maintain your sbk21 account;
• To verify your identity and age in accordance with our KYC and 21+ age verification requirements;
• To process your deposits and withdrawals via your selected Malaysian payment method;
• To provide and improve Platform Services, including live casino, sports betting markets covering Liga Super Malaysia and EPL, slots, and crash games;
• To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, and other prohibited conduct as described in our Terms & Conditions;
• To monitor your gambling activity in connection with our responsible gambling commitments and, where necessary, to intervene to support player welfare;
• To resolve customer support queries, disputes, and complaints;
• To send you transactional communications relevant to your account — such as deposit confirmations, withdrawal status updates, and account security notifications;
• To send you promotional communications about sbk21 offers and VIP programme updates, where you have provided consent or where we have a legitimate interest in doing so;
• To comply with our regulatory and legal obligations, including maintaining records required by our gaming licence authority and AML compliance framework;
• To analyse aggregated, anonymised usage data to improve the Platform and user experience.

7. Data Sharing & Disclosure

7.1 Service Providers

sbk21 shares Personal Data with carefully selected third-party service providers who assist in the delivery of Platform Services. These providers are contractually required to process Personal Data only on sbk21's instructions and to maintain appropriate security standards. Categories of service providers with whom data may be shared include:

• Payment processing partners (including FPX gateway operators, e-wallet platforms, and cryptocurrency payment processors);
• Identity verification and KYC technology providers;
• Fraud detection and AML screening services;
• Cloud infrastructure and hosting providers;
• Customer support software providers;
• Game studio technology providers who supply content to the sbk21 Platform.

7.2 Regulatory & Legal Disclosure

sbk21 may disclose Personal Data to regulatory authorities, law enforcement agencies, courts, or other government bodies where required to do so by applicable law, by court order, or in connection with the fulfilment of our obligations under our gaming licence. Such disclosures will be limited to the minimum amount of data necessary to fulfil the legal requirement.

7.3 No Sale of Personal Data

sbk21 does not sell, rent, lease, or otherwise commercially transfer your Personal Data to any third party for their independent marketing or commercial purposes. This restriction applies without exception and regardless of any financial consideration offered.

7.4 Business Transfers

In the event that sbk21's business operations are transferred, merged, acquired, or otherwise restructured, Personal Data held by sbk21 may form part of the transferred assets. In such a scenario, sbk21 will provide reasonable advance notice to affected Users and ensure that the receiving entity commits to data protection standards no less protective than those described in this Policy.

8. Data Retention

sbk21 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, subject to any overriding legal, regulatory, or contractual retention obligations. The following general retention principles apply:

• Active Account Data: Personal Data associated with an active account is retained for the duration of the account's active status.
• Closed Account Data: Following voluntary account closure or sbk21-initiated account suspension, Personal Data is retained for a minimum of five (5) years to comply with AML regulatory record-keeping requirements and to facilitate resolution of any post-closure disputes.
• KYC Documentation: Identity verification documents are retained for a minimum of five (5) years from the date of submission in accordance with applicable regulatory requirements.
• Transaction Records: Financial transaction data is retained for a minimum of seven (7) years in accordance with applicable financial record-keeping standards.
• Communications Data: Customer support communications are retained for three (3) years from the date of the last interaction.
• Technical Logs: IP address logs and session data are retained for twelve (12) months unless a longer period is required for an active investigation.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with sbk21's internal data lifecycle management procedures.

9. Data Security

sbk21 implements a multi-layered security framework to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. Key security measures in place include:

• Encryption in Transit: All communications between your browser and the sbk21 Platform are encrypted using TLS 1.3 (256-bit SSL), the same encryption standard used by major financial institutions.
• Encryption at Rest: Personal Data and financial records stored on sbk21 servers are encrypted at rest using AES-256 encryption.
• Access Controls: Access to systems holding Personal Data is restricted to authorised sbk21 personnel on a strict need-to-know basis. All internal access is logged and subject to periodic access review.
• Two-Factor Authentication: sbk21 strongly recommends and supports two-factor authentication (2FA) for all user accounts to reduce the risk of unauthorised account access.
• Intrusion Detection: Our platform is monitored around the clock for anomalous access patterns, attempted breaches, and suspicious activity using automated detection systems.
• Regular Security Audits: sbk21 conducts periodic security assessments and penetration testing of its platform infrastructure.

Notwithstanding the foregoing, no security system is completely impenetrable. In the event of a data breach that is likely to result in a risk to your rights and freedoms, sbk21 will notify affected Users and, where required, the relevant regulatory authority, in accordance with applicable data breach notification obligations.

10. Cookies & Tracking Technologies

10.1 What Cookies We Use

sbk21 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies that keep you logged in during your visit. These cookies cannot be disabled without affecting core Platform functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised data about how Users interact with the Platform — such as pages visited, time on page, and navigation paths. This data helps us identify areas for improvement.
• Functional Cookies: Used to remember your preferences and settings, such as your preferred language or game lobby view.
• Security Cookies: Used to detect and prevent fraudulent activity, including cookies that identify unusual login patterns or device changes.

10.2 Managing Cookies

You can manage cookie preferences through your browser settings. Most major browsers — including Chrome, Firefox, Safari, and Edge — allow you to block or delete cookies. Please note that disabling strictly necessary cookies will impair your ability to log in to and use the sbk21 Platform. For detailed instructions on managing cookies in your specific browser, please consult your browser's help documentation.

sbk21 does not use cookies to deliver third-party advertising or to track your activity on websites outside of the sbk21 Platform.

11. Your Data Rights

As a Data Subject, you hold the following rights in relation to your Personal Data held by sbk21. These rights are exercisable by submitting a written request to our support team through the channels described in Section 15.

sbk21 will respond to all verifiable data rights requests within thirty (30) days of receipt. In cases of particular complexity, this period may be extended by a further thirty (30) days, in which case sbk21 will notify you of the extension and the reason for it within the initial thirty-day window.

12. Children & Minors

The sbk21 Platform is strictly intended for persons aged 21 years and above. sbk21 does not knowingly collect Personal Data from persons under the age of 21. Our registration process includes mandatory age declaration and is backed by KYC verification to enforce this requirement.

If sbk21 becomes aware that Personal Data has been collected from a person under the age of 21 — whether through a false declaration or circumvention of our verification systems — the account concerned will be immediately suspended, all associated Personal Data will be deleted to the extent permitted by regulatory obligations, and any funds held in the account will be returned to the deposit source after applicable checks.

If you are a parent or guardian and have reason to believe that a minor under your care has registered an account with sbk21, please contact our support team immediately via live chat or email at [email protected] (plain text — not a clickable link).

13. Third-Party Links

The sbk21 Platform may contain links to third-party websites or services in certain contexts. These links are provided for informational or operational purposes only. sbk21 does not operate, control, or endorse the content, privacy practices, or data handling of any third-party website. Once you navigate away from the sbk21 Platform to a third-party site, this Privacy Policy no longer applies, and you are subject to the privacy policy of the destination site.

sbk21 encourages Users to review the privacy policies of any third-party websites they visit, particularly payment provider platforms such as Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, or CIMB Clicks, whose own data practices govern your interactions with their respective platforms.

14. Amendments to This Policy

sbk21 reserves the right to update, amend, or replace this Privacy Policy at any time. Where amendments are material — meaning they significantly affect your rights or the way your data is processed — sbk21 will provide advance notice via email notification to registered Users or via a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is always displayed at the top of this document. Your continued use of the sbk21 Platform following the effective date of any revised Policy constitutes your acceptance of the revised terms. If you do not agree with the revised Policy, you must cease using the Platform and may request account closure as described in our Terms & Conditions.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy, the processing of your Personal Data, or the exercise of your data rights, please contact sbk21 through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly through the sbk21 Platform. This is the fastest channel for all account-related and data requests, and is accessible to players across Malaysia including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam.
• Email (plain text — not a clickable link): [email protected] — target response time within 1 business hour during peak operating periods, and within 24 hours at all other times.

When submitting a data rights request, please include your registered account username, the email address associated with your account, and a clear description of the right you wish to exercise or the concern you wish to raise. sbk21 may request additional identification to verify your identity before processing your request.