payung99 Privacy Policy – How We Handle Your Personal Data

1. About This Policy

This Privacy Policy ("Policy") describes how payung99 ("payung99," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal data of individuals ("Members," "users," "you," or "your") who access or use the online gaming platform operated at payung99.club ("Platform").

This Policy applies to all personal data processed by payung99 in connection with your registration, account use, financial transactions, customer support interactions, and any other activity conducted via the payung99 Platform or related communications channels.

By creating a payung99 account or continuing to use the Platform following any update to this Policy, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2. Data Controller

payung99 is the data controller in respect of personal data collected from Members of the Platform. As data controller, payung99 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is conducted lawfully, fairly, and transparently.

For questions about how payung99 handles your personal data, or to exercise any of your data subject rights described in Section 11, please contact us using the details set out in Section 15 of this Policy.

3. Personal Data We Collect

payung99 collects the following categories of personal data from Members:

3.1 Registration & Identity Data. When you create a payung99 account, we collect your full legal name, date of birth, email address, Malaysian mobile number, and the username you select. This information is required to establish your account and verify that you meet the 21+ age requirement.

3.2 Verification & KYC Data. As part of our Know Your Customer (KYC) obligations, payung99 may collect copies of government-issued identification documents (e.g., Malaysian National Identification Card, passport), proof of residential address, and documentation evidencing ownership of payment methods used. This data is collected to satisfy anti-money laundering (AML) and regulatory compliance requirements.

3.3 Financial & Transaction Data. payung99 collects data relating to deposits, withdrawals, bonuses, wagers, and account balance movements. This includes the payment methods used (e.g., Touch 'n Go eWallet, Boost, FPX, Maybank, CIMB, Public Bank PBe), transaction amounts in MYR, and transaction timestamps. payung99 does not store full payment card numbers.

3.4 Gaming Activity Data. We collect records of your gaming sessions on the payung99 Platform, including games played, bet amounts, game outcomes, session durations, and any responsible gaming limits you have applied to your account.

3.5 Technical & Device Data. payung99 automatically collects technical data when you access the Platform, including your IP address, browser type and version, operating system, device identifiers, screen resolution, and referring URL. This data is used for Platform security, fraud prevention, and performance optimisation.

3.6 Communication Data. If you contact payung99's customer support team — whether via live chat, email, or any other channel — we retain records of those interactions, including the content of messages and any attachments provided, for quality assurance and regulatory compliance purposes.

3.7 Marketing Preference Data. Where you have given consent to receive marketing communications from payung99, we maintain a record of that consent together with your communication preferences, including your opt-out status.

4. How We Collect Your Data

payung99 collects personal data through the following means:

• Directly from you — during account registration, KYC verification, deposits and withdrawals, customer support interactions, and when you update your account settings;
• Automatically — via cookies, web beacons, server logs, and similar tracking technologies when you access and use the Platform (see Section 9);
• From third parties — including identity verification service providers, payment processors, fraud prevention agencies, and, where permitted, publicly available sources, for the purpose of verifying your identity and preventing financial crime.

5. Purpose and Legal Basis for Processing

payung99 processes your personal data only where a valid legal basis exists. The following table summarises the primary purposes for which we process your data and the corresponding legal basis:

• Account creation and management — processed on the basis of contractual necessity (to perform the agreement between you and payung99);
• Identity verification and KYC compliance — processed to comply with legal obligations under applicable AML and gaming regulations;
• Processing deposits and withdrawals — processed on the basis of contractual necessity and, where applicable, legal obligation;
• Fraud detection and Platform security — processed on the basis of our legitimate interests in protecting the Platform and its Members from financial crime and unauthorised access;
• Responsible gaming monitoring — processed on the basis of legal obligation and our legitimate interest in promoting safe gambling practices;
• Customer support — processed on the basis of contractual necessity and our legitimate interests in resolving Member queries efficiently;
• Sending marketing communications — processed solely on the basis of your explicit consent, which you may withdraw at any time;
• Platform analytics and performance monitoring — processed on the basis of our legitimate interests in maintaining and improving the Platform experience.

6. Sharing of Personal Data

6.1 Service Providers. payung99 shares personal data with a limited number of trusted third-party service providers who assist in the delivery of Platform services. These include payment processors (to facilitate MYR deposits and withdrawals), identity verification providers (to perform KYC checks), game providers (to deliver the gaming content accessible on the Platform), and IT infrastructure and cloud hosting providers. All third-party service providers engaged by payung99 are bound by contractual data processing agreements that prohibit them from using your personal data for any purpose other than delivering the agreed service to payung99.

6.2 Regulatory and Law Enforcement Authorities. payung99 may disclose personal data to regulatory bodies, law enforcement agencies, courts, or other government authorities where required to do so by applicable law, court order, or regulatory direction. payung99 will, where legally permissible, notify affected Members of such disclosures.

6.3 Fraud Prevention Agencies. Where payung99 has reasonable grounds to suspect fraudulent activity, money laundering, or other financial crime in connection with a Member account, we may share relevant account and transaction data with specialist fraud prevention agencies or banking partners for investigation purposes.

6.4 No Sale of Data. payung99 does not sell, rent, license, or otherwise transfer your personal data to third parties for their own commercial purposes. This prohibition applies without exception.

7. International Data Transfers

payung99 may transfer your personal data to countries outside your country of residence in connection with the delivery of Platform services — for example, where a game provider's servers are located in a different jurisdiction. Where such transfers occur, payung99 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that afforded in your home jurisdiction, including through the use of standard contractual clauses or equivalent transfer mechanisms recognised under applicable data protection law.

8. Data Retention

8.1 Active Accounts. payung99 retains your personal data for as long as your account remains active and for such additional period as may be required to fulfil the purposes described in this Policy or to comply with applicable legal and regulatory retention obligations.

8.2 Closed Accounts. Following the closure of a payung99 account, we retain your personal data for a minimum period of five (5) years from the date of account closure, in compliance with AML record-keeping requirements and other applicable regulations. After the expiry of this retention period, your data is securely deleted or irreversibly anonymised.

8.3 Transaction Records. Financial transaction records are retained for a minimum of seven (7) years from the date of each transaction, consistent with applicable financial record-keeping obligations.

9. Cookies and Tracking Technologies

9.1 Types of Cookies Used. payung99 uses the following categories of cookies on the Platform:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session management cookies that maintain your logged-in state. These cookies cannot be disabled without materially impairing Platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and responsible gaming limit configurations. These improve your experience on payung99.
• Analytical Cookies: Used to collect anonymised information about how Members interact with the Platform — including pages visited, session duration, and navigation paths — to help payung99 improve the user experience and Platform performance.
• Security Cookies: Used to support fraud detection and prevention mechanisms, including identifying unusual login patterns or device anomalies on your payung99 account.

9.2 Managing Cookies. You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the payung99 Platform. Detailed cookie management instructions are available from your browser provider's help documentation.

10. Security Measures

payung99 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and payung99 servers;
• Encryption of sensitive data fields at rest on payung99 databases;
• Role-based access controls restricting access to personal data to authorised personnel with a legitimate operational need;
• Multi-factor authentication requirements for payung99 internal systems handling Member data;
• Regular penetration testing and security audits of the Platform infrastructure;
• Intrusion detection systems and 24/7 security monitoring of Platform servers.

Notwithstanding the above, no data transmission or storage system can be guaranteed as completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, payung99 will notify you and the relevant regulatory authority in accordance with applicable law.

11. Your Data Subject Rights

Subject to applicable law and regulatory obligations, you have the following rights in relation to your personal data held by payung99:

• Right of Access: You may request a copy of the personal data payung99 holds about you, together with information about how that data is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held on your payung99 account.
• Right to Erasure: In certain circumstances, you may request the deletion of your personal data. This right is subject to override where retention is required for legal, regulatory, or fraud prevention purposes.
• Right to Restriction: You may request that payung99 restrict the processing of your personal data in certain circumstances — for example, while a data accuracy dispute is being resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and is conducted by automated means, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your personal data where that processing is based on payung99's legitimate interests. You have an absolute right to object to processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact payung99 using the details in Section 15. We will respond to your request within 30 days of receipt. We may require you to verify your identity before processing a data subject rights request.

12. Children's Privacy

The payung99 Platform is strictly intended for persons aged 21 years and above. payung99 does not knowingly collect personal data from individuals under the age of 21. If payung99 becomes aware that personal data has been collected from an individual who does not meet the age requirement, that account will be immediately closed, the data will be deleted, and any associated balance will be forfeited in accordance with the Terms & Conditions.

Parents and guardians of minors are encouraged to use parental control software to prevent access to online gambling websites. If you believe a minor has registered a payung99 account, please contact us immediately at [email protected] so that we may take appropriate action.

13. Third-Party Links and Services

The payung99 Platform may, from time to time, contain links to third-party websites or services. This Policy applies only to the payung99 Platform and does not extend to any third-party sites accessible via links on the Platform. payung99 is not responsible for the privacy practices of any third-party website. You are encouraged to review the privacy policies of any third-party sites you visit independently of the payung99 Platform.

14. Amendments to This Policy

payung99 reserves the right to amend this Privacy Policy at any time. Where changes are material, payung99 will provide notice to Members via email or a prominent notification on the Platform at least 14 days prior to the amended Policy taking effect. The date of the most recent revision is displayed at the top of this page. Your continued use of the payung99 Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

15. Contact Us & Data Protection

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how payung99 handles your personal data, please contact our team through the following channels:

• Live Chat: Available 24/7 via the payung99.club Platform — average response under 2 minutes
• Email: [email protected] — response within 2 business hours

Support is provided in English and Bahasa Malaysia. If you are not satisfied with payung99's response to a privacy concern, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.