Hon33 Privacy Policy — Malaysia Member Personal Data Protection

01 Information We Collect

Hon33 collects several categories of personal information in order to provide you with a safe and comprehensive service. The information collected includes:

We only collect data that is strictly necessary for the stated purposes. Every data request is accompanied by a clear explanation of why it is needed.

02 How We Use Your Information

Hon33 uses your personal data solely for the following purposes:

• Processing account registration and verifying your identity through the KYC process
• Processing deposit and withdrawal transactions securely and accurately
• Detecting and preventing fraud, money laundering, and other illegal activities
• Sending important notifications related to your account and transactions
• Complying with legal obligations and regulatory requirements
• Improving platform quality and user experience based on usage patterns
• Sending promotional information — only if you have consented to receive it

03 Sharing Information with Third Parties

Hon33 does not share your personal information with third parties except in the following limited and controlled circumstances:

• Service Providers: Third parties that assist us in platform operations, such as payment processors, cloud computing providers, and KYC services — all bound by strict confidentiality agreements
• Legal Obligation: When required by court order, regulatory authority, or lawful law enforcement body
• Fraud Prevention: To fraud prevention agencies or relevant industry bodies to protect the interests of all platform users

Every third-party service provider working with hon33 has undergone thorough vetting and is bound by data processing terms that comply with high security standards.

04 Data Retention Period

Hon33 retains your personal data for as long as necessary to fulfil the original purpose of collection, or as required by applicable law. General guidelines on retention periods are as follows:

• Active account data: Throughout the active membership period
• Financial transaction records: Minimum 7 years after account closure (legal requirement)
• KYC documents: Minimum 5 years after the business relationship ends
• Technical and security logs: 12 months from the date of creation
• Customer support correspondence: 3 years from the date of last interaction

Once the applicable retention period has expired, your data will be securely deleted or anonymised in accordance with our data deletion procedures.

05 Your Rights as a Data Subject

As a hon33 member residing in Malaysia, you have the following rights under PDPA 2010:

To exercise any of the above rights, please contact our data protection team by email at [email protected] with the subject line "Data Rights Request". We will respond within 14 business days.

06 Cookies & Tracking Technologies

Hon33 uses cookies and similar tracking technologies to enhance the user experience on our platform. The types of cookies used are:

• Essential Cookies: Required for core platform functions such as login and session security — cannot be disabled
• Functional Cookies: Remembering your preferences and settings for a better experience
• Analytics Cookies: Helping us understand how the platform is used for continuous improvement (data collected anonymously)
• Security Cookies: Helping detect suspicious activity and protect your account

You can manage cookies through your web browser settings. Please note that disabling certain cookies may affect platform functionality. We do not use third-party advertising cookies or cross-site tracking cookies.

07 Data Security & Incident Response

Your data security is hon33's top priority. We implement multiple layers of technical and operational protection to safeguard the integrity and confidentiality of your information:

• Data encryption in transit (TLS 1.3) and at rest (AES-256)
• Role-based access control — only authorised staff may access sensitive data
• Regular security audits conducted by independent third parties
• 24/7 threat monitoring and intrusion detection systems
• Mandatory information security training for all staff
• A clear incident response plan that is regularly tested

While we take all reasonable precautions, no system can be guaranteed 100% secure. In the event of a material security breach, we will notify you and the relevant authorities in accordance with our legal obligations.

08 Cross-Border Data Transfers

In certain situations, your personal data may be processed or stored outside Malaysia — for example, when we use international cloud service providers. In such cases, we ensure:

• The recipient country maintains a level of data protection equivalent to Malaysia
• Legally binding data transfer agreements are established with receiving parties
• Additional safeguards are applied, including data encryption and anonymisation

You may request further information about the countries where your data may be processed by contacting our data protection team.

09 Privacy Policy Updates

Hon33 reserves the right to update this privacy policy from time to time to reflect changes in our practices, legal requirements, or the way we operate. Each time this policy is updated, the "Last Updated" date at the top of this document will be revised.

For material changes, we will notify you via your registered email at least 7 days before the changes take effect. Continued use of the platform after the effective date constitutes acceptance of the updated policy.

We encourage you to review this page periodically to stay informed about how we protect your information.