Privacy Policy Club 999 – Personal Data Protection for Malaysian Members

To provide the best possible service to our Malaysian members, Club 999 collects several categories of personal information. We only collect what is strictly necessary to manage your account and ensure a safe and enjoyable gaming experience.

We do not collect sensitive data such as medical information, religious beliefs, or political views, except where required by applicable Malaysian law.

Club 999 collects your personal data in a number of ways when you interact with our platform:

• Account Registration: Information you provide when registering a new Club 999 account, including your name, phone number, and email address.
• Identity Verification (KYC): Documents you upload during the verification process, such as a copy of your MyKad or Malaysian passport.
• Financial Transactions: Data generated when you make a deposit via Touch 'n Go eWallet, GrabPay, DuitNow, FPX internet banking (Maybank2u, CIMB Clicks, RHB Now), or any other registered payment method.
• Platform Usage: Data collected automatically as you browse and use the Club 999 platform, including games played and session duration.
• Communications with Us: Information you share when contacting customer support via Live Chat, WhatsApp, or email.
• Cookies & Similar Technologies: Data collected via cookies, tracking pixels, and similar technologies as you browse our platform.
• Third-Party Sources: In certain circumstances, we may receive information from trusted third-party payment processors or identity verification bodies for verification purposes.

Club 999 uses your personal data only for legitimate and transparent purposes. The following are the primary purposes for which your data is used:

• Account Management: To create, verify, and manage your Club 999 account, including the processing of deposits and withdrawals in Malaysian Ringgit (RM).
• Legal Compliance: To meet KYC (Know Your Customer), AML (Anti-Money Laundering), and other legal obligations under Malaysian legislation.
• Customer Service: To efficiently and effectively handle your enquiries, complaints, and support requests.
• Platform Security: To detect, prevent, and investigate fraud, hacking, and any suspicious activity that may compromise the security of your account.
• Marketing & Promotions: To send you information about relevant Club 999 bonuses, promotions, and exclusive offers – only where you have given your consent.
• Platform Improvements: To analyze usage patterns and improve the user experience, technical performance, and various features of the Club 999 platform.
• Responsible Gaming: To monitor gaming patterns and identify members who may require assistance related to responsible gambling.

Club 999 does not sell, rent, or disclose your personal data to third parties for their own marketing purposes. However, in certain circumstances, we may need to share your data with the following parties:

• Trusted Service Providers: Payment processors handling Touch 'n Go, GrabPay, Boost, ShopeePay, and DuitNow transactions; game providers; and IT service providers that support our platform operations.
• Regulatory & Enforcement Bodies: When required by Malaysian law, the Malaysian Communications and Multimedia Commission (MCMC), the police, or a court of competent jurisdiction.
• Identity Verification Bodies: Companies that assist us in verifying member identities and complying with applicable KYC/AML requirements.
• Business Partners: In the event of a merger or business acquisition, member data may be transferred as part of the business assets, subject to appropriate notice being given to members.

All third parties who receive your personal data from Club 999 are required to maintain the confidentiality and security of that data to a standard equal to or higher than our own.

The security of your personal data is Club 999's highest priority. We implement robust technical and organisational measures to protect your information from unauthorised access, loss, or misuse:

• 256-bit SSL Encryption: All data transmitted between your device and Club 999's servers is encrypted using industry-standard 256-bit SSL technology.
• Encryption of Stored Data: Sensitive data such as financial information and identity documents is stored in encrypted form on secure servers.
• Strict Access Controls: Only authorised Club 999 staff who require access to your data in order to carry out their permitted duties are allowed to access it.
• 24/7 Monitoring: Our security systems are monitored around the clock to detect any threats or suspicious activity in real time.
• Regular Security Audits: We conduct regular penetration testing and security audits to ensure our systems remain current and robust.
• Two-Factor Authentication (2FA): We offer and encourage the use of 2FA on all member accounts for an additional layer of security.

While we take every reasonable measure to protect your data, no security system can be guaranteed 100% secure. In the event of any material data breach affecting your personal data, we will notify you within the timeframe prescribed by applicable Malaysian law.

The Club 999 platform uses cookies and similar tracking technologies to enhance the user experience and analyze platform performance. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login authentication, session management, and security. These cookies cannot be disabled.
• Performance Cookies: Helps us understand how users interact with the platform, which pages are visited most frequently, and where technical issues occur.
• Functional Cookies: Saves your preferences such as language selection and display settings to deliver a more personalised experience.
• Analytics Cookies: Used to collect aggregated data on platform usage for the purposes of continuous improvement.

You can control or disable cookies through your web browser settings. Please note, however, that disabling certain cookies may affect the functionality and usability of the Club 999 platform.

Club 999 retains your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Malaysian law. The following are our data retention guidelines:

• Active Account Data: Retained for the duration your account remains active, plus 7 years after account closure to comply with Malaysia's financial regulatory requirements.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with the requirements of the Companies Act and Malaysia's anti-money laundering regulations.
• Communication Data: Customer support conversation records are retained for 3 years for reference and dispute resolution purposes.
• Technical & Log Data: System logs and technical data are retained for 12 months for security and troubleshooting purposes.
• KYC Documents: Identity document copies are retained for the duration of the active account plus 5 years after account closure.

Once the applicable retention period has elapsed, your personal data will be securely deleted or anonymised so that it can no longer be linked to you. Data deletion is carried out using methods that comply with industry security standards.

As a Club 999 platform user based in Malaysia, you have the following rights under the Personal Data Protection Act 2010 (PDPA):

To exercise any of the rights above, please contact our Data Privacy Officer at privacy@club999.wine. We will process your request within 21 working days as stipulated under Malaysia's PDPA.

The Club 999 platform is exclusively for individuals aged 18 and above. We do not knowingly collect, process, or store any personal data from individuals under the age of 18.

If we discover that personal data belonging to an individual under the age of 18 has been collected without our knowledge, we will take immediate steps to delete that data and close the account in question. Parents or guardians who find that their child has registered an account at Club 999 are requested to contact us immediately at support@club999.wine.

Club 999 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, technological requirements, or new Malaysian legal obligations. You will be notified of any material amendments through:

• A notification email to your registered address at least 14 days before the amendments take effect.
• A prominent notice on the Club 999 platform's main page.
• A pop-up notice at login for amendments that require renewed consent.

Your continued use of the Club 999 platform after any amendments take effect constitutes your acceptance of the revised Privacy Policy. We recommend that you review this page periodically. The "Updated" date at the top of this page indicates when this Privacy Policy was last reviewed.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by Club 999, please contact our Data Privacy Officer (DPO) through the following channels:

• Privacy Email: privacy@club999.wine
• Support Email: support@club999.wine
• Live Chat: Available 24/7 on the Club 999 platform

We are committed to responding to all privacy-related enquiries within 5 business days and resolving any issues within 21 business days as required by Malaysia's PDPA. If you are not satisfied with our response, you have the right to refer your complaint to the Department of Personal Data Protection Malaysia.