9 Club Privacy Policy – Malaysian User Data Protection

This Privacy Policy is published by 9 Club ("we", "platform", "9 Club") and applies to all users who access or use our services in Malaysia, including our website, mobile application, and all related services.

We are committed to protecting every user's privacy in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA). As an online entertainment platform serving Malaysians, we understand how sensitive personal and financial information can be — and we take that responsibility seriously.

By using the platform 9 Club, you agree to the collection and use of information as described in this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of our platform.

9 Club collect various categories of data depending on your interactions with the platform. Generally, the data collected includes:

Data You Provide Directly

• Registration information: full name, email address, mobile number, date of birth, and password;
• Identity verification (KYC) information: MyKad/passport number, copies of identification documents;
• Financial information: preferred payment methods (Touch 'n Go eWallet, DuitNow, GrabPay, Boost, ShopeePay, FPX Maybank2u, CIMB Clicks), deposit and withdrawal transaction history;
• Communications: live chat message content, emails to customer support, and feedback you submit to us.

Automatically Collected Data

• IP address and location information (city/state level);
• Web browser type, operating system, and device type;
• Platform activity logs including pages visited, visit timestamps, and in-game actions;
• Game usage data: betting history across Malaysia Super League, EPL, baccarat, slots, and other games.

9 Club collects personal data through a variety of clear and transparent channels:

• Account registration: When you complete the registration form on our platform;
• Platform usage: Each time you log in, place a bet, play a casino game, or carry out a financial transaction;
• Support interactions: Through live chat sessions, email tickets, or other written communications with our customer support team;
• Automated technology: Through cookies, web beacons, and other industry-standard tracking technologies (see Section 7);
• Identity verification: During the KYC process for withdrawals exceeding certain limits or upon compliance request;
• Legitimate third-party sources: In certain cases, we may receive data from authorised identity verification or anti-fraud service providers.

9 Club process your personal data solely for legitimate and necessary purposes, which include:

• Account management: Creating, verifying, and maintaining your account on the platform;
• Service provision: Enables you to access all platform features including Sports Betting, Live Casino, slots, jackpot, and lottery;
• Financial processing: Processing deposits via Touch 'n Go, DuitNow, GrabPay, and FPX, as well as withdrawals to verified accounts;
• Security & fraud detection: Identifying and preventing fraud, money laundering, and security breaches;
• Customer support: Responding to enquiries, resolving disputes, and providing technical support;
• Legal compliance: Fulfilling obligations under PDPA 2010, the Anti-Money Laundering Act (AMLA), and other applicable regulations in Malaysia;
• Platform improvements: Analysing usage patterns to enhance the user experience and develop new features;
• Marketing communications: Sending information about promotions and new offers (subject to your stated preferences).

9 Club do not sell, rent, or disclose your personal data to third parties for their own commercial purposes. However, we may share your data in the following limited and controlled circumstances:

Service Providers We Work With

• Payment gateway providers: Such as FPX, Touch 'n Go eWallet, DuitNow, and GrabPay providers to process financial transactions;
• Game providers: Evolution Gaming, Pragmatic Play, PG Soft, and other providers require game session information to deliver live casino and slots services;
• Identity verification services: Authorised third parties engaged to assist with KYC processes and fraud detection.

Legal Obligations

We may disclose your data when required by Malaysian law, including requests from the Royal Malaysia Police (PDRM), Malaysian Courts, Bank Negara Malaysia, or relevant regulatory authorities. In such cases, we will endeavour to notify you unless prohibited by law.

Your data security is our top priority 9 Club. We implement comprehensive technical and organisational security measures:

Technical Security

• Transmission encryption: All communications between your browser and our servers are secured with TLS 1.3 protocol;
• Storage encryption: Sensitive data is stored in encrypted form using AES-256 standards;
• Multi-layered firewall: Our servers are protected by next-generation firewall (NGFW) systems and intrusion detection and prevention systems (IDS/IPS);
• Two-Factor Authentication (2FA): Available to all user accounts and mandatory for internal staff access;
• 24/7 monitoring: Our cybersecurity team continuously monitors our systems for any anomalies.

Organisational Security

• Access to user data is restricted to personnel who require it to perform their duties (least privilege principle);
• All staff undergo regular privacy and security training;
• Independent security audits are conducted at least once a year.

9 Club use cookies and similar tracking technologies to enhance your experience on the platform. Cookies are small text files stored on your device by your web browser.

Types of Cookies We Use

• Essential Cookies: Required for core platform functions such as login verification and session security. Cannot be disabled.
• Functional Cookies: Saving your preferences such as your chosen language and display settings.
• Performance Cookies: Collecting anonymised data on how users interact with the platform for improvement purposes.
• Marketing Cookies: Used to display relevant promotions. Can be disabled through your account settings.

You can manage or delete cookies through your web browser settings. However, disabling essential cookies may affect the functionality of the platform.

As a financial platform that accepts real money, 9 Club has strict compliance obligations relating to user identity verification. This is a legal requirement under Malaysia's Anti-Money Laundering Act 2001 (AMLA).

KYC Process

The Know Your Customer (KYC) process involves verifying a user's identity using:

• A valid copy of MyKad or passport;
• Proof of current address (utility bill or bank statement not older than 3 months);
• In certain cases, a selfie alongside your identity document.

Payment Data Protection

We do not store full bank account numbers or payment card details. All transactions via Touch 'n Go eWallet, DuitNow, GrabPay, Boost, ShopeePay, FPX Maybank2u, and CIMB Clicks are processed through payment gateways that comply with PCI-DSS standards.

As a user 9 Club in Malaysia, you have the following rights under the Personal Data Protection Act 2010:

• Right to Access: Request a copy of the personal data we hold about you;
• Right to Rectification: Request correction of data that is inaccurate or incomplete;
• Right to Erasure: Request the deletion of your data (subject to our legal obligations to retain certain records);
• Right to Object to Processing: Object to the processing of your data for direct marketing purposes;
• Right to Withdraw Consent: Withdraw consent previously given for specific processing activities.

To exercise any of these rights, contact our Data Protection Officer at privacy@9club.cash or via the request form in your account settings. We will respond to your request within 21 working days.

As a global platform serving Malaysian users, some of our service providers (such as international casino game providers) may operate or store data outside Malaysia. In such cases:

• We ensure that all cross-border data transfers are carried out with protections equivalent to or greater than those required under PDPA 2010;
• Binding data processing agreements are signed with all international data recipients;
• We do not transfer data to countries that lack adequate data protection without additional safeguards in place.

9 Club is a platform strictly for adults aged 18 and above. We do not knowingly collect any personal data from individuals under the age of 18.

If we find that data from a child or individual under 18 has been collected inadvertently, we will promptly delete that data and close the account in question. If you believe your child has registered on our platform, please contact us immediately at support@9club.cash.

9 Club reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new technologies, or updated legal requirements.

When material changes are made, we will:

• Updating the "Last Updated" date at the top of this document;
• Sending email notifications to all registered users;
• Displaying a prominent notice on the platform's main page for a minimum of 30 days.

Continued use of the platform 9 Club after the amendment notice is deemed acceptance of the updated version of the Privacy Policy.

9 Club has appointed a Data Protection Officer (DPO) responsible for ensuring ongoing compliance with the PDPA 2010 and this privacy policy.

For any enquiries, complaints, or requests relating to your privacy and personal data, please contact our DPO:

• DPO Email: privacy@9club.cash
• General Support Email: support@9club.cash
• Live Chat: Available 24/7 on the platform (for general enquiries)
• Response time: Within 21 business days for official data-related requests