S99my Privacy Policy — Malaysian Player Personal Data Protection

1. Introduction

Welcome to s99my, an online entertainment platform built exclusively for players in Malaysia. At s99my, we understand that privacy is more than a legal obligation — it is the foundation of trust we build with every player who joins our platform.

This Privacy Policy explains in detail how s99my, as data controller, collects, processes, stores, protects and, in certain circumstances, shares your personal data. This document applies to all users who browse the s99my website, register an account, use our mobile app or interact with any of the services we provide.

By using the s99my platform, you acknowledge that you have read, understood and agreed to the data protection practices as set out in this Privacy Policy. This policy should be read together with Terms and Conditions s99my for a full overview of your rights and responsibilities as a user of our platform.

2. Personal Data We Collect

S99my only collects personal data necessary to provide you with a safe, fair, and quality service. We do not collect data beyond what the platform's operations require. The following are the categories of data we collect:

In addition to data you provide directly during registration or platform use, s99my also collects certain data automatically when you browse or use our services, including server log data, session records, and device information used to access your account.

3. How We Use Your Data

All data collected by s99my is used for clear and legitimate purposes. We do not process your data for any purpose not stated in this Privacy Policy. The following are the primary purposes for which your personal data is used:

• Account management: Creating, verifying and managing your player account, including the KYC process and identity verification required by industry standards.
• Transaction processing: Processing deposits, withdrawals and all financial transactions on the s99my platform securely and accurately.
• Providing gaming services: Enabling you to access all games in the Game Lobby, Live Casino, sports betting, Bingo and all other available services.
• Platform security: Detecting, investigating and preventing fraud, money laundering, account abuse and other security threats.
• Customer support: Responding to enquiries, resolving complaints and providing the technical assistance you need.
• Marketing communications: Sending promotional information, bonus offers and the latest news about s99my — only to users who have given their consent.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling and provide appropriate support.
• Platform enhancements: Analysing aggregated usage data to improve platform performance, interface and overall user experience.
• Legal compliance: Meeting the reporting and compliance obligations stipulated by Malaysian law and relevant regulatory bodies.

4. Data Sharing with Third Parties

S99my does not sell your personal data to any party. However, in the course of operating the platform efficiently and securely, we may share your data in limited and controlled situations as follows:

• Payment service providers: DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay and other providers that assist in processing your financial transactions. These providers receive only the minimum data necessary to complete each transaction.
• Game providers: Third-party game software providers that supply games within the s99my platform. They may receive unique account identifiers but not your full identity information.
• Technical service providers: Hosting, cybersecurity, and IT infrastructure companies that support s99my's technical operations, subject to strict confidentiality agreements.
• Relevant authorities: Bank Negara Malaysia, the Labuan Financial Intelligence Unit (LFIU), police or courts where required by law or court order.
• Auditors and professional consultants: These parties are bound by strict professional confidentiality obligations when carrying out their duties for s99my.

5. Cookies and Tracking Technologies

S99my uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you browse the s99my website. The following are the types of cookies we use:

• Essential Cookies (Required): Required for core platform functions such as login, account sessions and security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collecting information on how users interact with our platform — such as the most frequently visited pages and time spent. This data is used to improve the platform.
• Functional Cookies: Saving your preferences such as language, display settings and game preferences to deliver a more personalised experience.
• Analytics Cookies: Used to understand aggregate platform usage patterns for continuous improvement purposes. This data does not contain personally identifiable information.

You can manage your cookie settings through your web browser at any time. Please note that disabling certain cookies may affect the functionality and your experience on the s99my platform. For guidance on managing cookies in popular browsers, please refer to your browser's help section.

6. Data Security

S99my continuously invests in robust security infrastructure to ensure your personal data is always protected against unauthorised access, disclosure, alteration, or destruction. The key security measures we implement include:

• 256-bit SSL encryption for all data transmitted between your device and s99my's servers.
• Encryption of data at rest for all personal and financial data stored in our databases.
• Two-Factor Authentication (2FA) available to all user accounts as an additional security layer.
• 24/7 security monitoring by a team of cybersecurity experts who detect and respond to threats in real time.
• Strict access controls — only specifically authorised personnel may access users' personal data, and every access is logged and audited.
• Penetration testing conducted periodically by independent parties to identify and patch security vulnerabilities.
• Incident response plan comprehensive, to ensure any data breach is handled swiftly and transparently.

7. Your Rights as a Data Subject

As an s99my user and data subject under Malaysia's PDPA, you have the following rights regarding your personal data. s99my is committed to ensuring you can exercise these rights easily and without obstruction:

To exercise any of the above rights, please contact the s99my support team via live chat on the platform. Your request will be processed within 30 calendar days. In complex cases, we may require additional time of up to 60 days, and we will notify you if this applies.

8. Data Retention Period

S99my retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy or as required by Malaysian law. The following are our data retention period guidelines:

• Active account data: Retained for the duration of your active account and for 7 years after account closure for financial regulatory compliance purposes.
• Financial transaction data: Retained for a minimum of 7 years in accordance with Malaysia's financial and tax legislation requirements.
• KYC and identity verification data: Retained for 5 years after account closure for anti-money laundering compliance purposes.
• Customer support communication logs: Retained for 2 years for service improvement purposes and reference in the event of a dispute.
• Technical data and server logs: Retained for 12 months for security and technical troubleshooting purposes.
• Marketing data: Retained until you withdraw consent or close your account.

Once the applicable retention period has ended, your data will be securely deleted or anonymised in a manner that can no longer be linked to you personally.

9. Links to Third-Party Platforms

The s99my platform may contain links to third-party websites or services such as payment providers or game providers. Once you click those links and leave the s99my platform, our Privacy Policy no longer applies.

S99my is not responsible for the privacy practices or content of third-party websites. We encourage you to read the Privacy Policy of each third-party website you visit before providing any personal information to them. Your decision to interact with third-party platforms is at your own risk.

10. Child Protection

S99my is an entertainment platform strictly restricted to users aged 18 years and above. We do not intentionally collect, store or process personal data from individuals under the age of 18.

All new account registrations go through a strict age verification process, including identity document verification during KYC. Should s99my discover that personal data of a minor has been collected inadvertently, we will take immediate steps to delete that data and close the account in question.

If you believe that an underage individual has successfully registered on our platform, please report this to the s99my support team immediately. We take every such report seriously and will investigate without delay.

11. Amendments to This Privacy Policy

S99my reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or industry developments. When we make significant changes:

• The "Updated" date at the top of this page will be changed to reflect the latest version.
• Notices will be sent to all active users via email or in-platform notifications at least 7 days before changes take effect.
• For highly significant amendments that require renewed consent, we will request your explicit consent before those changes take effect on your account.

We encourage you to review this Privacy Policy periodically. Your continued use of the s99my platform after any amendments take effect will be deemed as your acceptance of the updated Privacy Policy.

12. Contact Us Regarding Privacy

If you have any questions or concerns, or wish to exercise your personal data rights, the s99my Data Protection Officer (DPO) team is available to assist you 24 hours a day, 7 days a week.