Privacy Policy Club 99 – Your Information is Always Safe

1 Privacy Policy Introduction and Scope

This Privacy Policy ("Policy") describes how Club 99, operating under the domain https://club99.bz ("Platform", "we", "us"), collects, uses, stores, discloses, and protects your personal information when you use our online entertainment platform.

This document forms part of the agreement between you and Club 99, together with our Terms and Conditions and Responsible Gaming Policy. By registering for or using Club 99's services, you consent to the processing of your personal data as described in this Policy.

Club 99 complies with Malaysia's Personal Data Protection Act 2010 (PDPA) and all related regulations. We take our role as a data controller seriously and continually strive to go beyond the minimum legal requirements in protecting your privacy.

2 Types of Personal Data Collected

Club 99 collects your personal information through various means, including during the account registration process, platform usage, identity verification (KYC), financial transactions, and communications with our support team. The categories of data we collect are as follows:

We only collect data that is strictly necessary for the stated purposes. Data minimization is central to our privacy approach — if a piece of information is not required, we will not ask for it.

3 How We Use Your Data

The personal data we collect is used for specific and legitimate purposes. Club 99 will not use your data for unrelated purposes without first obtaining your consent. Our data processing purposes are as follows:

• Account management: To create, verify, and maintain your member account, including the KYC process required before your first withdrawal.
• Transaction processing: Managing deposits, withdrawals, and all financial activities related to your account through payment methods such as DuitNow, local bank transfers, and digital wallets.
• Platform security: To identify and prevent fraud, money laundering, unauthorized access, and other suspicious activity that could compromise your safety or the security of our platform.
• Legal compliance: To fulfill our obligations under PDPA 2010, the Anti-Money Laundering Act 2001, and other applicable legislation in Malaysia.
• Customer support: To handle inquiries, complaints, and assistance requests submitted through live chat, email, or other support channels.
• Service communications: Sending important notifications relating to your account, transactions, promotions you have agreed to receive, and policy updates.
• Product improvement: To analyze aggregate platform usage patterns in order to improve the user experience, develop new features, and optimize our services.

4 Data Sharing With Third Parties

Club 99 does not sell, rent, or disclose your personal data to third parties for their own commercial purposes. However, in the course of operating the platform, there are limited situations in which we may need to share your information with certain parties:

• Payment service providers: Financial institutions and payment processors that help us securely process your deposit and withdrawal transactions. They are bound by strict confidentiality agreements.
• Technical service providers: Companies providing IT infrastructure, cloud services, analytics, and cybersecurity that help us maintain a reliable platform.
• Licensed authorities: Law enforcement agencies, regulatory bodies, or courts requiring data disclosure under valid legal obligations.
• Identity verification partners: KYC service providers who assist us in verifying member identities to meet anti-money laundering requirements.

All third parties who receive your data are required to protect that information to a security standard no less than our own. We conduct regular due diligence checks on all third-party service providers.

5 Data Retention Period

Club 99 retains your personal data for as long as necessary to fulfil the purpose for which it was collected, or for as long as required under applicable Malaysian law. The following are our data retention guidelines:

• Active account data: Retained for as long as your account is active and for a period after account closure for audit and compliance purposes.
• Financial transaction records: Retained for a minimum of 7 years in accordance with Malaysia's anti-money laundering legal requirements.
• KYC and identity verification records: Retained for a minimum of 5 years after the business relationship ends, in accordance with the PDPA and related legislation.
• Customer support communication logs: Retained for 2 years for reference and service improvement purposes.
• Technical data and system logs: Typically retained for 12 months for security and debugging purposes.

Once the specified retention period has expired, your data will be securely deleted or anonymised so that it can no longer be linked to your identity.

6 Data Security and Protection Measures

Protecting your data is club 99's top priority. We implement a comprehensive security framework covering technical, physical, and organisational measures:

• 256-bit SSL/TLS data encryption for all data transmitted between your device and our servers.
• Passwords are stored using an irreversible bcrypt hashing algorithm.
• Two-factor authentication (2FA) is available and encouraged for all member accounts.
• 24/7 security monitoring with automated threat detection and response systems.
• Periodic penetration testing conducted by independent security experts.
• Role-based access control (RBAC) to ensure staff can only access data within the scope of their duties.
• Encrypted data backups stored at geographically separate locations.

7 Cookies and Tracking Technologies

Club 99 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us remember your preferences and understand how you use our platform.

Types of cookies we use:

• Strictly necessary cookies: Essential for core platform functions such as login sessions and security. This cannot be disabled.
• Performance cookies: Collecting information about how you use the platform to help us improve its design and functionality.
• Functional cookies: Remembering your preferences such as language and settings to provide a more personalized experience.
• Analytics cookies: Helps us understand aggregate usage patterns through analytics tools used internally.

You can manage and delete cookies through your browser settings at any time. However, disabling certain cookies may affect platform functionality.

8 How to Exercise Your Privacy Rights

Club 99 makes it easy for you to exercise your privacy rights. To submit any request relating to your personal data, you may:

• Contacting the customer support team via live chat, which operates 24/7.
• Sending an official email to [email protected], stating the type of request and your account details.
• Using the privacy settings in your account portal for specific requests such as updating information or unsubscribing from marketing communications.

We will process and respond to your request within 30 calendar days of receipt. For more complex cases, this period may be extended up to 60 days with prior notice to you. We do not charge for the first request made within a year — repeated unfounded requests may be subject to a reasonable fee.

9 Amendments to the Privacy Policy

Club 99 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service improvements. When we make significant changes, we will:

• Displaying a clear notice on the platform's home page at least 14 days before changes take effect.
• Sending email notifications to all active registered members.
• Updating the "Last Updated" date at the top of this document.

For minor changes that do not materially affect your rights, we may update this document without prior specific notice. We encourage you to review this page periodically. Continued use of the platform after a policy change takes effect will be considered acceptance of the updated policy.

10 Contact Our Data Protection Officer

If you have any questions, concerns, or complaints regarding how club 99 handles your personal data, please contact our dedicated Data Protection Officer (DPO), appointed to ensure compliance with the platform's privacy policy:

• Email: [email protected] (please indicate "DPO Enquiry" in the email subject line)
• Live Chat: Available 24/7 via the club 99 platform
• Target response time: Within 2 business days for privacy inquiries

If you are not satisfied with our response, you have the right to file a complaint with the Malaysia Personal Data Protection Department or the relevant authority under PDPA 2010.