Privacy Policy – 99ply Platform

1. Introduction

This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal data by 99ply ("we", "us", "our", "the Platform") in connection with your use of the 99ply online casino and sportsbook platform accessible at 99ply.com and any associated services operated under the 99ply brand.

99ply is committed to handling personal data in a lawful, fair, and transparent manner consistent with applicable data protection regulations, including the Malaysian Personal Data Protection Act 2010 (PDPA) and the data protection requirements of the jurisdiction under which 99ply holds its international gaming licence.

By registering a 99ply account or otherwise using the platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. This Policy is incorporated by reference into the 99ply Terms & Conditions. Where this Policy and the Terms & Conditions conflict, this Policy governs in matters relating to personal data.

2. Data Controller

99ply acts as the data controller in respect of personal data collected from players and visitors to the platform. As data controller, 99ply determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out in accordance with applicable legal obligations.

For all data protection enquiries, correction requests, deletion requests, and complaints, players should contact 99ply at: [email protected]. 99ply will respond to data-related requests within 30 calendar days of receipt.

3. Personal Data We Collect

99ply collects personal data in the following categories depending on how you interact with the platform:

99ply does not collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless directly relevant to a responsible gaming assessment initiated by the player or required by applicable law.

4. How 99ply Uses Your Personal Data

99ply processes your personal data for the following purposes:

• Account management: Creating, maintaining, and administering your 99ply player account;
• Identity and age verification: Confirming that you are a real person, aged 21 or above, entitled to use the platform;
• Payment processing: Processing deposits and withdrawals via your chosen MYR payment method (Touch n Go eWallet, Boost, DuitNow, FPX, and others);
• Platform delivery: Providing access to casino games, sportsbook markets, and all associated platform features;
• Fraud prevention and AML compliance: Detecting, investigating, and preventing fraudulent activity, money laundering, and other illegal conduct;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and implementing player protection measures where required;
• Customer support: Responding to your enquiries, resolving disputes, and processing complaints;
• Legal and regulatory compliance: Meeting obligations under applicable gaming licences, anti-money laundering regulations, and data protection laws;
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, and user experience;
• Marketing communications: Sending you promotional offers and platform updates where you have provided consent. You may withdraw marketing consent at any time via your account settings or by contacting support.

99ply does not use personal data for automated profiling that produces legal or similarly significant effects without human review.

5. Legal Basis for Processing

99ply relies on the following legal bases for processing personal data:

• Contractual necessity: Processing required to fulfil the player agreement, including account management, payment processing, and game delivery;
• Legal obligation: Processing required to comply with AML regulations, gaming licence conditions, KYC requirements, and applicable data protection laws;
• Legitimate interests: Processing for fraud prevention, platform security, and improving the 99ply service, where our interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and optional features, where you have given explicit, freely given, and informed consent. Consent may be withdrawn at any time.

6. Data Sharing & Third-Party Disclosure

99ply does not sell, rent, or trade your personal data to unaffiliated third parties for their independent commercial use. 99ply may share your data in the following limited circumstances:

• Payment service providers: Your transaction data is shared with payment processors (e.g., FPX, Touch n Go eWallet, Boost, DuitNow network operators) solely for the purpose of completing your requested deposit or withdrawal;
• Identity verification providers: KYC document data may be shared with regulated third-party identity verification services to confirm identity and age;
• Gaming and technology providers: Session and game data may be shared with certified game content providers for the purpose of game delivery, audit trails, and technical support;
• Regulatory and law enforcement authorities: 99ply will disclose personal data to gaming regulators, tax authorities, or law enforcement agencies where required by applicable law or a valid legal order;
• Fraud prevention networks: Data may be shared with cross-industry fraud prevention bodies where necessary to detect and prevent fraudulent activity;
• Corporate transactions: In the event of a merger, acquisition, or sale of substantially all assets, player data may be transferred as part of the transaction, subject to the same data protection obligations as set out in this Policy.

All third parties with whom 99ply shares personal data are required to implement appropriate technical and organisational security measures and are only permitted to process data for the specified, disclosed purpose.

7. Cookies & Tracking Technologies

99ply uses cookies and similar tracking technologies to operate the platform, personalise your experience, and analyse platform usage. The following categories of cookies are used:

• Strictly necessary cookies: Required for platform login, session management, and security. These cannot be disabled without breaking core platform functionality;
• Functional cookies: Remember your preferences (e.g., language, display settings) to improve your experience on return visits;
• Analytics cookies: Collect anonymised data on how players interact with the 99ply platform to help us improve navigation and performance;
• Marketing cookies: Used only where you have consented, to deliver relevant promotional content.

You may manage cookie preferences through your browser settings. Disabling all cookies may affect the functionality of the 99ply platform, including the ability to log in and maintain an active session.

8. Data Retention

99ply retains personal data for as long as necessary to fulfil the purposes for which it was collected, including ongoing legal and regulatory obligations. Specific retention periods are as follows:

• Active account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and gaming licence record-keeping requirements;
• KYC documents: Retained for a minimum of five (5) years from the date of verification or the date of account closure, whichever is later;
• Transaction records: Retained for a minimum of seven (7) years for financial compliance purposes;
• Support communications: Retained for three (3) years from the date of the communication;
• Marketing consent records: Retained for the duration of your account and for two (2) years following consent withdrawal.

Following the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of identifiable information.

9. Your Data Protection Rights

Subject to applicable law, you have the following rights in relation to your personal data held by 99ply:

• Right of access: You may request a copy of the personal data 99ply holds about you;
• Right of rectification: You may request correction of inaccurate or incomplete personal data;
• Right to erasure: You may request deletion of your personal data, subject to our legal obligation to retain certain records;
• Right to restrict processing: You may request that processing of your data be suspended in certain circumstances while a dispute or correction request is resolved;
• Right to data portability: Where technically feasible and legally applicable, you may request your data in a structured, machine-readable format;
• Right to withdraw consent: Where processing is based on consent (e.g., marketing), you may withdraw consent at any time without affecting prior processing;
• Right to object: You may object to processing based on legitimate interests, including direct marketing.

To exercise any of the above rights, submit a written request to [email protected]. 99ply will respond within 30 days. We may require identity verification before processing a data rights request to ensure we do not disclose data to an unauthorised party.

10. Data Security

99ply implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Security measures in place include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and the 99ply platform;
• Encrypted storage of all personal data and financial records at rest;
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments conducted by independent security professionals;
• Two-factor authentication available for all player accounts and mandatory for privileged internal access;
• Incident response procedures for detecting, containing, and reporting data breaches in accordance with applicable regulatory requirements.

No data transmission over the internet is entirely risk-free. While 99ply takes all reasonable precautions, we cannot guarantee absolute security. In the event of a data breach affecting your personal data, 99ply will notify you and relevant regulators in accordance with applicable law.

11. International Data Transfers

99ply's platform infrastructure may involve the transfer and storage of personal data in jurisdictions outside Malaysia. Where such transfers occur, 99ply ensures that adequate protections are in place, including contractual safeguards (standard contractual clauses) or transfers to jurisdictions with an equivalent level of data protection recognised under applicable Malaysian law. 99ply does not transfer personal data to jurisdictions that do not provide adequate protection without implementing appropriate contractual and technical safeguards.

12. Minors

The 99ply platform is strictly intended for adults aged 21 and above. 99ply does not knowingly collect personal data from individuals under the age of 21. If 99ply becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, all data associated with the account will be deleted, and any balance forfeited in accordance with the Terms & Conditions.

If you believe a minor has registered a 99ply account, please contact support immediately at [email protected].

13. Changes to This Privacy Policy

99ply reserves the right to update this Privacy Policy at any time. Where changes are material, 99ply will notify registered players via email or prominent platform notification prior to the revised Policy taking effect. The "Last updated" date at the top of this page reflects the most recent revision.

Your continued use of the 99ply platform following the effective date of a revised Policy constitutes acceptance of the changes. If you do not accept the revised Policy, you must cease using the platform and may request account closure.

14. Contact & Complaints

For all privacy-related enquiries, data access requests, correction requests, or complaints, please contact 99ply's data protection point of contact:

Email: [email protected]

99ply will acknowledge all data protection requests within 5 business days and provide a substantive response within 30 calendar days. If you are unsatisfied with 99ply's response to a privacy complaint, you have the right to escalate to the Personal Data Protection Commissioner of Malaysia or the relevant data protection supervisory authority in the jurisdiction applicable to your circumstances.