Privacy Policy luck99 – Member Personal Data Protection

01 Introduction

Luck99 values the privacy of every member and visitor to our platform. This Privacy Policy is designed to ensure you fully understand how your personal information is managed — from the point of collection through to how it is protected and when it may be shared.

We operate in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA) and adhere to international information security standards. Every decision regarding data is made with the interests and safety of our members as the top priority.

This policy applies to all users of the Luck99 platform, including those accessing via our website and mobile app. If you use third-party services integrated with our platform, their separate privacy policies also apply to their portion of the services.

02 Data We Collect

Luck99 only collects data that is strictly necessary to provide a safe, fair, and efficient service to our members. The following are the categories of data we collect:

We do not collect sensitive information such as health data, political views, or religious beliefs unless required by applicable law. Credit card data is not stored directly by luck99 — all card transactions are processed through PCI-DSS certified payment gateways.

03 How We Use Your Data

The data we collect is used in a limited and purposeful manner. Luck99 processes your personal data for the following purposes:

• Account Management: Creating, verifying, and maintaining your account, and ensuring login security.
• Transaction Processing: Processing deposits, withdrawals, and all financial transactions efficiently and securely.
• KYC Verification: Meeting Know Your Customer (KYC) requirements in line with anti-money laundering laws.
• Platform Security: Detecting and preventing fraudulent activity, money laundering, and platform abuse.
• Responsible Gaming: Monitoring gaming patterns to identify and support members who may be at risk of problem gambling.
• Customer Support: Resolving enquiries, complaints, and providing technical support to members.
• Marketing (with consent): Sending promotions, bonus offers, and product information to members who have consented to receive them.
• Analytics and Improvement: Understanding how the platform is used to improve the overall user experience.

04 Data Sharing with Third Parties

Luck99 does not sell your personal data to any third party for commercial purposes. However, we may share your information in the following limited situations:

• Operational Service Providers: Technical partners such as payment gateway providers, cloud service providers, and KYC solution providers that help us operate the platform. All such providers are bound by strict confidentiality agreements.
• Relevant Authorities: When required by Malaysian law, court order, or a lawful request from law enforcement agencies. We disclose only the minimum data necessary in such situations.
• Game Service Providers: Selected game content providers may receive anonymised statistical data for technical purposes and game fairness auditing.
• Business Transfers: In the event of a merger, acquisition, or asset sale, user data may be transferred to the receiving entity, subject to protections equivalent to those in this Privacy Policy.

05 Cookies and Tracking Technologies

The luck99 platform uses cookies and similar tracking technologies to enhance user experience, secure login sessions, and analyze platform usage patterns. The following are the types of cookies we use:

• Essential Cookies: Required for core platform operations, including login session verification and security. These cookies cannot be disabled as they are critical to platform functionality.
• Performance Cookies: Gathering information on how visitors use our platform to help us improve site performance and speed.
• Functional Cookies: Saving your preferences such as language, time zone, and display settings to deliver a more personalised experience.
• Analytics Cookies: Enabling us to understand the most frequently visited pages and user navigation paths for continuous improvement.

You can manage cookie settings through your browser settings. However, disabling essential cookies may affect platform functionality. Luck99 does not use cookies to track your activity on other websites outside our platform.

06 Data Security

Luck99 continuously invests in security infrastructure to ensure your personal data is protected at all times. The technical and organisational security measures we implement include:

• Data in transit is encrypted using TLS 1.3 and 256-bit SSL protocols.
• Data at rest is encrypted using the AES-256 algorithm for all sensitive information.
• Two-factor authentication (2FA) is available for all member accounts as an additional layer of protection.
• Round-the-clock security monitoring by our cybersecurity team to detect threats in real time.
• Periodic penetration testing conducted by independent security experts.
• Mandatory data security training for all staff with access to user data.
• Tested incident response procedures to ensure a rapid response in the event of a data breach.

07 Your Rights as a Data Subject

Under the Malaysian Personal Data Protection Act 2010 (PDPA), you have the following rights regarding the personal data we hold:

• Right of Access: You have the right to request and receive a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request correction of any inaccurate or outdated personal data.
• Right to Restriction of Processing: In certain circumstances, you have the right to request that we restrict how we process your data.
• Right to Object to Marketing: You have the right to object to the use of your data for direct marketing purposes at any time.
• Right to Erasure (subject to legal requirements): You may request deletion of your personal data when it is no longer needed for its original collection purpose, subject to our data retention obligations under the law.

To exercise any of the above rights, contact the luck99 support team via Live Chat or our official email. We will process your request within 21 working days. Identity verification may be required before requests are processed.

08 Data Retention

Luck99 retains your personal data for as long as necessary to fulfil the purpose for which it was collected and to meet our legal obligations. Our general data retention guidelines are as follows:

• Active Account Data: Retained for the duration your account is active and for the period following account closure as required by AML and PDPA legislation.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with Malaysian financial legal requirements.
• Support Communication Logs: Retained for 3 years for complaint resolution and service quality improvement purposes.
• Technical Log Data: Retained for 12 months for security and incident investigation purposes.

Upon expiry of the retention period, data will be securely deleted or anonymized so that it can no longer be personally associated with you.

09 Changes to This Privacy Policy

Luck99 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological developments. Any material changes will be communicated to members via:

• A prominent notice on the platform's home page for at least 14 days before the changes take effect.
• Email to your registered address for changes that directly affect your privacy rights.
• Update the "Last Updated" date at the top of this document.

Continued use of the luck99 platform after changes take effect will be deemed as your acceptance of the updated Privacy Policy. If you do not agree with the changes made, you have the right to close your account in accordance with the prescribed procedure.

10 Contact Us Regarding Privacy

If you have any questions, concerns, or complaints about how Luck99 handles your personal data, we encourage you to reach out to us directly. Our Data Protection Officer (DPO) team is ready to assist.

• Primary Channel: Live Chat 24/7 within the luck99 platform — the fastest way to get a response.
• Privacy Email: [email protected] (response within 3 working days).
• Response Time: General inquiries are resolved within 3 working days; formal data subject rights requests within 21 working days.

If you are not satisfied with how we handle your complaint, you have the right to refer the matter to the Personal Data Protection Commissioner of Malaysia under PDPA 2010.