Clup99 Privacy Policy – Your Personal Data Protection

Clup99 is committed to protecting your privacy and the security of your personal data. As an online entertainment platform operating in Malaysia, we understand the importance of the trust you place in us every time you use clup99's services.

This Privacy Policy is drafted in accordance with the Malaysia Personal Data Protection Act 2010 (PDPA) and international data protection principles. It describes the types of information we collect, the purposes for collection, how we use it, and your rights as the data owner.

We encourage you to read this document from start to finish. If any section is unclear, our support team is always ready to assist via live chat on the clup99 platform.

Clup99 collects your personal information through several different means. Below is a detailed breakdown of the data categories we collect:

Automatically collected information: When you browse the clup99 platform, our systems automatically record certain technical information such as IP address, device and browser type, pages visited, session duration, and cookies. This information is used solely to enhance security and user experience.

Clup99 uses the personal information collected for legitimate and specific purposes. We do not use your data for any purposes beyond the scope stated here:

• Account Management: Registering and maintaining your account, processing logins, and ensuring secure access to the clup99 platform.
• Transaction Processing: Handling all deposits, withdrawals, and credit exchanges securely and accurately within the stipulated timeframe.
• Identity Verification (KYC): Fulfilling legal and regulatory obligations by verifying each member's identity, particularly before processing withdrawals.
• Security & Fraud Prevention: Monitoring account activity to detect any unauthorised access, fraud attempts, or money laundering.
• Customer Support: Processing enquiries, complaints, and assistance requests you submit through our support channels.
• Service Communications: Sending important notifications related to your account, security, and service terms updates.
• Marketing (with consent): Contacting you about promotions, bonuses, and special offers – only if you have given consent to receive marketing communications.
• Platform Improvements: Analysing overall usage patterns (not individual) to improve user experience and our services.
• Legal Compliance: Meeting the reporting and compliance obligations required by applicable Malaysian law.

Clup99 takes a very limited approach to sharing your personal data. We does not sell your data to any party. Data sharing only occurs in the following situations:

• Payment Service Providers: Required transaction information is shared with trusted payment processors (FPX, TNG, GrabPay, and others) solely for the purpose of processing your financial transactions.
• Game Providers: Minimal game session data is shared with third-party game providers integrated with our platform to ensure a smooth gaming experience.
• KYC Services: Identity information is shared with approved identity verification service providers for legal compliance purposes only.
• Legal Authority: clup99 will disclose required information to law enforcement agencies or regulatory bodies when mandated by a court order or applicable law.
• Business Transfers: In the event of a merger, acquisition, or asset sale, user data may be transferred to the new entity – and you will be notified in advance.

All third parties working with us are bound by strict data protection agreements and are required to comply with the security standards set by clup99.

Your data security is our top priority. clup99 implements multiple layers of technical and organisational protection to safeguard your information:

• Data Encryption: All sensitive data, including financial and personal identification information, is encrypted using AES-256 algorithms during storage and transmission.
• Access Control: Only authorised clup99 staff with a legitimate need are permitted to access your personal data.
• Regular Security Audits: Our platform undergoes regular penetration testing and security audits conducted by independent security experts.
• 24/7 Monitoring: Our automated monitoring system is always active to detect any anomalies or security threats in real time.
• Data Backup: Data is regularly backed up to secure, isolated servers to ensure service continuity.

Data Retention Period: clup99 retains your personal data for as long as necessary for the stated purposes, or as required by law. Generally, financial and transaction records are kept for seven (7) years in line with Malaysian legal requirements. Account data that has been inactive for more than two (2) years will undergo a review process and may be deleted or anonymized.

Clup99 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored in your web browser when you visit our site.

Types of Cookies We Use:

• Essential Cookies: Required for core platform functions such as login authentication, session security, and language preference memory. These cookies cannot be disabled.
• Performance Cookies: Helps us understand how users interact with the platform for improvement purposes. Information is collected in aggregate and anonymised form.
• Functional Cookies: Saving your preferences such as display settings, game preferences, and account configuration for your convenience.
• Marketing Cookies: Used to display relevant promotions and advertisements based on your interests — only activated with your consent.

You can manage cookie settings through your web browser. Please note that disabling essential cookies may affect certain functions of the clup99 platform.

Under the Malaysia Personal Data Protection Act 2010 and clup99's commitments, you have the following rights regarding your personal data:

To exercise any of the above rights, please contact our privacy team via live chat within the clup99 platform. We will process your request within 30 working days from the date the request is received.

Clup99 is an entertainment platform exclusively for individuals aged 18 years and above. We do not intentionally collect or process personal data from any individual under the age of 18.

If we discover that personal data of a minor has been collected without our knowledge, the account in question will be closed immediately and all data will be fully deleted from our systems as soon as possible.

If you believe we may hold personal data of an individual under the age of 18, please contact us immediately via live chat so we can take the appropriate action.

Clup99 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or service improvements.

You will be notified of any material changes to this Privacy Policy through:

• A clear notice on the clup99 platform's home page
• An in-account notification upon your next login
• Email notification to your registered address (for significant changes)

The "Updated" date at the top of this page will always reflect the date of the latest revision. Your continued use of the clup99 platform after any revision is published constitutes your acceptance of the updated Privacy Policy.

If you have any questions, concerns, or complaints about how we handle your personal data, we encourage you to contact us directly. Our privacy team is dedicated to addressing every enquiry seriously and thoroughly.

• Live Chat: Reach our support team directly via live chat on the clup99 platform — available 24 hours a day, 7 days a week.
• Email: Send your privacy enquiries to [email protected]
• Response Time: We are committed to responding to all privacy-related enquiries within 3 working days.