unsur138 is committed to protecting your personal data. This Privacy Policy explains what information we collect, why we collect it, how we use it, and the rights you hold over your data.
Last updated: 1 January 2026unsur138 (hereinafter referred to as "the Company", "we", "us", or "our") operates the online gaming and sports betting platform accessible at unsur138.cam (hereinafter "the Platform"). We are committed to maintaining the privacy, confidentiality, and security of all personal information that you provide to us in connection with your use of the Platform.
This Privacy Policy (hereinafter "the Policy") sets out the basis on which any personal data we collect from you — or that you provide to us — will be processed by us. It applies to all visitors to the Platform, all registered account holders, and all individuals who communicate with us through any channel, including live chat, email, or social media.
By registering an account with unsur138, making a deposit, placing a wager, or otherwise using any feature of the Platform, you confirm that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data in accordance with the terms described herein.
Your privacy matters to us. We do not sell, rent, or trade your personal data to third-party marketers under any circumstances. Your information is collected and used solely to operate the Platform, comply with our regulatory obligations, and improve your experience as a player.
For the purposes of this Privacy Policy, the following definitions shall apply:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person — including name, identification number, contact details, financial information, and behavioural data. |
| "Processing" | Any operation performed on personal data — including collection, storage, use, disclosure, alteration, or deletion. |
| "Data Subject" | The individual to whom the personal data relates — i.e., the registered player or site visitor. |
| "Data Controller" | The entity that determines the purposes and means of processing personal data — in this case, the Company operating unsur138. |
| "Third Party" | Any natural or legal person other than the Data Subject, the Company, and persons who process personal data under the Company's direct authority. |
| "KYC" | Know Your Customer — the identity and age verification process conducted prior to withdrawal processing and in other prescribed circumstances. |
| "Cookie" | A small text file placed on a user's device by a website for the purpose of storing session or preference data. |
Depending on how you interact with the Platform, we may collect and process the following categories of personal data:
We collect personal data through the following mechanisms:
The Company processes your personal data on one or more of the following legal bases, depending on the specific processing activity:
| Legal Basis | Applicable Circumstances |
|---|---|
| Contractual Necessity | Processing required to fulfil our contractual obligations to you as a registered player — including account management, payment processing, and gameplay facilitation. |
| Legal Obligation | Processing required to comply with anti-money-laundering (AML) regulations, KYC obligations, and reporting requirements under our licensing framework. |
| Legitimate Interests | Processing carried out in our legitimate business interests — including fraud prevention, platform security, responsible gambling monitoring, and service improvement — where those interests are not overridden by your rights. |
| Consent | Processing based on your freely given, specific, and informed consent — such as the sending of optional promotional communications. You may withdraw consent at any time. |
We use the personal data we collect for the following purposes:
The Company does not sell, rent, or trade personal data to third-party marketing organisations. We may share your personal data with the following categories of recipients only where necessary and proportionate:
Third-party providers engaged by the Company to deliver specific operational functions — including payment processors (e.g., the technical operators behind FPX, DuitNow, and e-wallet integrations), identity verification services, cloud infrastructure providers, customer support software vendors, and fraud detection platforms. All such providers operate under data processing agreements that restrict their use of your data to the specific purpose for which they were engaged.
We may disclose personal data to regulatory authorities, law enforcement agencies, or courts where we are under a legal obligation to do so, where disclosure is necessary to protect the Company's legal rights, or where we reasonably believe a user has engaged in illegal activity.
The Company may be required to share player data with its international gaming licensing authority as part of routine audits, compliance inspections, or formal investigations.
In the event of a merger, acquisition, restructuring, or sale of the Company's business or assets, personal data held by the Company may be transferred to the acquiring entity. In such circumstances, the Company will endeavour to notify affected players via their registered email address prior to any transfer taking effect.
The Company retains personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law and regulatory obligation. The following general retention periods apply:
| Data Category | Retention Period |
|---|---|
| Identity & KYC documents | 5 years from the date of account closure, or as required by the applicable licensing authority — whichever is longer. |
| Financial transaction records | 5 years from the date of each transaction, for AML compliance purposes. |
| Gameplay & account history | 5 years from account closure, or 7 years where relevant to a dispute, investigation, or legal proceedings. |
| Support & communications records | 3 years from the date of last contact, unless the record relates to an open dispute. |
| Marketing consent records | Retained until consent is withdrawn, and for 1 year thereafter as evidence of the original consent. |
| Technical & device data | 12 months from collection, unless extended by a security investigation. |
Where personal data is no longer required, it is securely deleted or anonymised in accordance with the Company's data destruction procedures.
The Company employs appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:
Notwithstanding the above, no method of electronic transmission or storage is entirely free from risk. Players are responsible for maintaining the security of their own account credentials and should report any suspected unauthorised access to our support team immediately.
The Platform uses cookies and similar tracking technologies to provide and improve the user experience, maintain session state, and gather analytics data. The categories of cookies used on unsur138 are as follows:
These cookies are essential for the Platform to function and cannot be disabled without significantly impairing your ability to use the site. They include session management cookies, authentication tokens, and security cookies. No consent is required for these cookies as they are technically necessary.
These cookies help us understand how visitors interact with the Platform — including which pages are most frequently visited, how long sessions last, and where users encounter difficulties. Data collected is aggregated and anonymised wherever possible.
These cookies enable the Platform to remember your preferences — such as language settings, display preferences, and previously used payment methods — to provide a more personalised experience.
Where you have consented, we may use cookies to track your interaction with promotional content so that we can present more relevant offers. You may withdraw this consent at any time by adjusting your browser cookie settings.
The Company operates under international licensing arrangements and uses service providers located in multiple jurisdictions. As a result, your personal data may be transferred to, stored in, or processed in countries outside of Malaysia. This may include countries whose data protection laws differ from those applicable in Malaysia.
Where such transfers occur, the Company takes steps to ensure that adequate safeguards are in place — including data processing agreements with transferee parties that include appropriate data protection clauses. By using the Platform, you acknowledge and consent to such transfers taking place on the basis described herein.
Subject to applicable law and certain limitations, you have the following rights in relation to your personal data held by unsur138. To exercise any of these rights, please contact us through the channels listed in Section 16.
You may request a copy of the personal data we hold about you, along with information about how it is being processed.
You may request correction of any inaccurate or incomplete personal data we hold about you.
You may request deletion of your personal data where we have no continuing legal or regulatory basis to retain it. Note that AML and KYC data must be retained for prescribed periods.
You may request that we restrict processing of your data in certain circumstances — for example, where you contest the accuracy of the data while we verify it.
Where processing is based on your consent or a contract, you may request your personal data in a structured, machine-readable format.
You may object to processing of your personal data based on our legitimate interests, including direct marketing communications. Objections to marketing are processed with immediate effect.
The Company will respond to all verified rights requests within 30 days. In complex cases, this may be extended by a further 60 days, with notification provided to you within the initial 30-day window.
The Platform is strictly intended for individuals aged 21 years and above. The Company does not knowingly collect or process personal data from individuals under the age of 21. Age verification is conducted as part of the KYC process, and accounts found to belong to individuals below the minimum age will be closed immediately, with any deposited funds returned in full.
If you believe a person under the age of 21 has registered an account or provided personal data to the Platform, please contact us immediately at [email protected] or via live chat, and we will take appropriate action without delay.
The Platform may contain links to third-party websites, game interfaces provided by licensed studio partners, or payment gateway portals. This Privacy Policy does not apply to those third-party websites or services. The Company has no control over, and is not responsible for, the privacy practices of any third-party operator. We encourage you to review the privacy policies of any external site or service you access through the Platform.
The Company reserves the right to update or modify this Privacy Policy at any time. Where changes are material — for example, changes to the categories of data collected, the purposes of processing, or your rights — we will notify registered players via email to the address on file or through an in-platform notification, at least seven (7) days before the changes take effect.
Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this page periodically. The date of the most recent update is displayed at the top of this document.
If you have any questions, concerns, or requests in relation to this Privacy Policy, or if you wish to exercise any of your data rights as set out in Section 12, please contact the Company through the following channels:
Our support team is available in English and serves players across Malaysia — including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam. All privacy requests are handled confidentially and in accordance with this Policy.
These are the six core commitments that define how unsur138 handles your personal information.
We do not sell, rent, or trade your personal data to third-party advertisers or data brokers — under any circumstances. Your information exists to serve your account, not to be monetised externally.
All data in transit between your device and unsur138 is protected by SSL/TLS 256-bit encryption — the same standard used by major financial institutions and e-wallet providers.
We collect only the data we need, use it only for the purposes stated in this Policy, and retain it only for as long as required by law or legitimate business necessity.
You have the right to access, correct, delete, and port your data. Rights requests are processed within 30 days and handled respectfully — no bureaucratic obstructions.
Identity verification is conducted to protect both players and the integrity of the Platform — not to build marketing profiles. KYC data is retained strictly for regulatory compliance purposes.
In the unlikely event of a data breach affecting your personal information, the Company has incident response procedures in place and will notify affected players promptly in accordance with applicable obligations.
Our 24/7 support team is available to address any privacy concern before or after you register. Visit the homepage or check our FAQ for more information about unsur138.