Privacy Policy

1. Introduction

This Privacy Policy (the "Policy") is issued by 99kopi ("the Platform", "we", "us", "our"), the operator of the online gaming and sports betting service available at 99kopi.cam. It applies to all individuals who register an account, access the Platform as a visitor, or interact with 99kopi through any of our supported channels.

99kopi is committed to protecting the privacy and personal data of all users, including players based in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and throughout Malaysia. This Policy describes what personal data we collect, why we collect it, how it is used and stored, with whom it may be shared, and what rights you hold in relation to your data.

By registering an account or using the Platform in any capacity, you acknowledge that you have read and understood this Policy and that you consent to the processing of your personal data in the manner described herein.

2. Definitions

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial data, and behavioural data generated through use of the Platform.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" — 99kopi, the entity that determines the purposes and means of processing personal data.
• "Data Processor" — any third party that processes personal data on behalf of 99kopi pursuant to a written agreement.
• "User" — any registered account holder or visitor accessing the Platform.
• "KYC Data" — identity and address verification documents submitted in accordance with Know Your Customer obligations, including copies of MyKad, passport, utility bills, and related materials.
• "Cookies" — small text files stored on your device by the Platform or authorised third-party analytics providers to support session management and performance measurement.

3. Data We Collect

3.1 Registration & Account Data

When you create a 99kopi account, we collect information including your full legal name, date of birth, Malaysian residential address, email address, and contact telephone number. This information is required to establish and administer your account.

3.2 Identity Verification (KYC) Data

To comply with regulatory requirements, we collect copies of your identity documents and proof of address. This typically includes a scan or photograph of your Malaysian MyKad, Driver's Licence, or Passport, together with a recent utility bill or bank statement and, where required, a selfie photograph taken while holding your identity document.

3.3 Financial & Transaction Data

We collect data related to deposits, withdrawals, and wagering activity, including payment method details (e-wallet identifiers such as those associated with Touch 'n Go eWallet, Boost, or GrabPay; bank account references for Maybank, CIMB, Public Bank, Hong Leong, FPX, and DuitNow transactions; cryptocurrency wallet addresses for USDT TRC20, BTC, ETH, and LTC deposits), transaction amounts in MYR, timestamps, and associated reference numbers.

3.4 Technical & Device Data

We automatically collect certain technical information when you access the Platform, including IP address, browser type and version, operating system, device identifiers, session duration, pages visited, and referring URL. This data is used for security monitoring, fraud prevention, and to improve Platform functionality.

3.5 Communications Data

We retain records of communications you initiate with our customer support team, including live chat transcripts and email correspondence. These records are used to resolve queries, ensure service quality, and comply with record-keeping obligations.

3.6 Behavioural & Gaming Data

We collect data about your gaming and betting activity on the Platform, including bet history, game preferences, promotional participation, session duration, and account balance changes. This data supports responsible gambling monitoring, bonus administration, and service personalisation.

4. How We Use Your Personal Data

99kopi processes personal data for the following purposes:

5. Legal Basis for Processing

We rely on the following legal bases to process your personal data:

• Contractual necessity: Processing required to deliver the services described in the Terms & Conditions, including account management, payment processing, and game access.
• Legal obligation: Processing necessary to comply with applicable regulatory requirements, including KYC, anti-money laundering obligations, and mandatory record retention.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gambling monitoring, and internal analytics, where such interests are not overridden by your rights and freedoms.
• Consent: Where we process data for optional purposes such as marketing communications, we rely on your explicit, freely given consent, which may be withdrawn at any time.

6. Sharing of Personal Data

99kopi does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share personal data with the following categories of recipients where necessary and proportionate:

• Payment processors and financial institutions — for the purposes of processing deposits and withdrawals through channels including DuitNow, FPX, and local Malaysian banks.
• Identity verification service providers — to facilitate KYC checks in accordance with regulatory requirements.
• Game software providers — limited technical identifiers may be shared with licensed game studios to enable game delivery and resolve technical disputes.
• Regulatory and law enforcement authorities — where disclosure is required by applicable law, court order, or a lawful request from a competent authority.
• Professional advisers — including legal, audit, and compliance service providers bound by confidentiality obligations.

7. International Data Transfers

The nature of online gaming infrastructure means that personal data may be processed by servers or service providers located outside of Malaysia. Where such transfers occur, 99kopi takes reasonable steps to ensure that adequate safeguards are in place to protect your personal data to a standard consistent with this Policy. This may include contractual data protection clauses, adequacy assessments, and technical security measures applied to data in transit and at rest.

8. Data Retention

We retain personal data for as long as is necessary to fulfil the purposes set out in this Policy, or as required by applicable law. Specific retention periods include:

• Active account holders: Personal and transaction data is retained for the duration of the account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• KYC documentation: Retained for a minimum of five (5) years from the date of submission, or longer where required by a specific regulatory obligation or ongoing investigation.
• Customer support communications: Retained for a minimum of two (2) years from the date of the interaction.
• Technical and device logs: Retained for up to twelve (12) months for security monitoring and fraud analysis purposes.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with our internal data lifecycle procedures.

9. Cookies & Tracking Technologies

99kopi uses cookies and similar tracking technologies to support the operation of the Platform, maintain your session state, measure performance, and detect security threats. The categories of cookies used include:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled without affecting core functionality such as login persistence and session security.
• Analytical cookies: Used to measure how the Platform is used in aggregate, identify performance issues, and improve user experience. Data collected is statistical and does not identify individual users.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and account takeover attempts.

You may manage or disable non-essential cookies through your browser settings. Note that disabling cookies may affect your ability to access certain features of the Platform.

10. Security of Personal Data

99kopi implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL (Transport Layer Security) encryption for all data transmitted between your device and the Platform.
• Encrypted storage of sensitive account credentials and KYC documents.
• Role-based access controls limiting internal access to personal data on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability management processes.
• Incident response procedures for detecting, reporting, and mitigating data breaches in accordance with applicable notification obligations.

While we take all reasonable precautions, no data transmission over the internet or electronic storage system can be guaranteed to be completely secure. We encourage you to use strong, unique passwords for your account and to notify us immediately if you suspect any unauthorised access.

11. Data Processing and Minors

The 99kopi Platform is strictly intended for adults aged 21 and above. We do not knowingly collect or process personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person who does not meet the minimum age requirement, we will take immediate steps to delete that data and close the associated account. Parents and guardians who believe that a minor may have accessed the Platform are encouraged to contact us immediately at [email protected].

12. Your Rights in Relation to Personal Data

Subject to applicable law and the legitimate needs of our regulatory and security obligations, you hold the following rights in relation to your personal data:

• Right of Access: You may request a copy of the personal data we hold about you and information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. You can update most account information directly through your Account Settings.
• Right to Erasure: You may request deletion of your personal data in circumstances where continued retention is no longer necessary or lawful, subject to our legal record-keeping obligations.
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, for example where you contest its accuracy.
• Right to Object: Where we process data on the basis of legitimate interests, you have the right to object to such processing. We will assess your objection and cease processing unless compelling legitimate grounds exist.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact us using the details in Section 14. We will respond to verifiable requests within a reasonable timeframe and in accordance with applicable law. We may request confirmation of identity before processing a rights request.

13. Amendments to This Policy

99kopi reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, operational practice, or Platform functionality. Where material changes are made, we will notify registered account holders by a notice displayed on the Platform or by email communication to the address registered on your account, with reasonable advance notice where practicable.

The "Effective Date" shown at the top of this page indicates the date of the most recent revision. Your continued use of the Platform following any revision constitutes acceptance of the updated Policy. We recommend you review this Policy periodically.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the 99kopi Data Protection team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, accessible through your 99kopi account dashboard.
• Email: [email protected] — please include "Privacy Request" in the subject line when submitting a formal data subject rights request.

We aim to acknowledge all data-related enquiries within two (2) business days and to resolve formal requests within thirty (30) calendar days of receipt, subject to complexity and any need to verify your identity.