Privacy Policy

This Privacy Policy ("Policy") is issued by 9eclub ("the Company", "we", "us", or "our"), the operator of the online gaming and sports betting platform accessible at 9eclub.cam ("the Platform"). This Policy describes how we collect, use, store, share, and protect personal data in connection with your use of the Platform and our associated services.

By accessing or registering on the 9eclub Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read together with our Terms & Conditions and Responsible Gambling Policy, all of which form part of your agreement with 9eclub.

We are committed to handling your personal data responsibly, in accordance with applicable data protection legislation and best practices in the online gaming industry. We do not sell, rent, or trade personal data to third parties for their independent marketing purposes.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, or online identifiers.
• "Data Controller" — 9eclub, which determines the purposes and means of processing your personal data.
• "Data Processor" — Any third party that processes personal data on behalf of 9eclub under our instructions and a written data processing agreement.
• "Processing" — Any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Consent" — A freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data for a specified purpose.
• "KYC Data" — Identity and address verification documents and information collected as part of the Know Your Customer process, including copies of government-issued identification and proof of address.
• "Cookies" — Small data files stored on your device by your web browser at the request of our Platform, used to remember your preferences and improve your experience.

We collect personal data that you provide directly, data generated by your use of the Platform, and data received from third parties in connection with your account. The categories of data we collect include:

3.1 Data You Provide Directly

• Account Registration: Full legal name, date of birth, residential address, email address, phone number, username, and password (stored in hashed form).
• Identity Verification (KYC): Copies of government-issued photo identification (Malaysian MyKad, Passport, or Driver's Licence), proof of address (utility bill or bank statement dated within three months), and selfie images for liveness verification.
• Financial Data: Payment method details used for deposits and withdrawals, including bank account numbers, e-wallet identifiers (Touch 'n Go, Boost, DuitNow), and payment card data (processed via tokenised systems — full card numbers are never stored on our servers).
• Communications: Records of your correspondence with our support team via live chat or email, including the content of messages, timestamps, and support ticket history.

3.2 Data Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and connection data.
• Usage Data: Pages visited, features accessed, games played, betting history, session duration, and click-path data.
• Location Data: Approximate geographic location derived from IP address, used for compliance and fraud prevention purposes only.
• Cookie Data: Session identifiers, preference settings, and analytics data as described in Section 8 of this Policy.

3.3 Data from Third Parties

• Identity verification results from KYC and anti-fraud service providers.
• Payment status confirmations and transaction reference data from payment processors such as FPX operators, e-wallet providers, and card networks.
• Fraud and sanctions screening results from compliance database providers.

We process your personal data for the following purposes. Each purpose is linked to a lawful basis as described in Section 5:

We do not use your personal data for fully automated decision-making that produces legal or similarly significant effects without human oversight. Where automated tools are used in fraud screening, a human reviewer is involved in any consequential decision affecting your account.

9eclub processes your personal data on one or more of the following lawful bases:

• Contract Performance: Processing is necessary to fulfil our obligations to you under the Terms & Conditions — including operating your account, processing transactions, and providing gaming services.
• Legal Obligation: Processing is required for compliance with applicable laws, including anti-money laundering (AML) regulations, counter-terrorism financing (CTF) requirements, and responsible gambling obligations imposed by our operating licence.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement — provided those interests are not overridden by your rights and interests.
• Consent: For optional processing activities such as marketing communications, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time by updating your account marketing preferences or contacting our support team.

9eclub does not sell, rent, or lease your personal data to third parties. We may share your data with carefully selected third parties only where necessary and under strict data protection obligations:

• Payment Service Providers: Financial institutions, e-wallet operators (including Touch 'n Go eWallet, Boost, and DuitNow platforms), FPX gateway providers, and card networks (Visa/Mastercard) — solely for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Licensed KYC and anti-money laundering service providers who assist us in verifying your identity, age, and address in accordance with our regulatory obligations.
• Game Content Providers: Licensed third-party game studios that supply casino, slot, and sports data content to our Platform. These providers may receive anonymised session data necessary to operate their games.
• IT and Cloud Infrastructure Providers: Hosting, database, and security service providers who process data on our behalf under binding data processing agreements.
• Regulatory and Law Enforcement Authorities: Where required by law, court order, or direction from a competent regulatory authority, we may disclose your data without prior notice.

We retain your personal data for no longer than is necessary for the purposes for which it was collected, subject to any mandatory retention periods imposed by applicable law or regulatory requirements:

• Account Data: Retained for the duration of your account and for a period of five (5) years following permanent account closure, in accordance with AML record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission, as required under applicable anti-money laundering legislation.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Support Communications: Retained for three (3) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Marketing Consent Records: Retained for the period of your consent and for two (2) years after withdrawal of consent, as evidence of consent compliance.

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

9eclub uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit our website. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the basic operation of the Platform, including maintaining your login session, remembering your language preferences, and ensuring security. These cannot be disabled.
• Performance and Analytics Cookies: Used to collect anonymised data about how visitors use the Platform — such as which pages are visited most frequently and where errors occur. This data helps us improve the user experience.
• Functional Cookies: Remember your preferences (such as preferred odds format or game category) so that you do not need to re-enter them on each visit.
• Security Cookies: Used to detect and prevent fraudulent activity and protect the integrity of your session.

You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may affect the functionality of the Platform. Continued use of the Platform without adjusting your browser cookie settings constitutes acceptance of our use of cookies as described above.

9eclub implements a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, loss, destruction, or alteration. Our security infrastructure includes:

• SSL/TLS 256-bit Encryption: All data transmitted between your device and our Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Password Hashing: Account passwords are never stored in plain text — they are processed through an industry-standard one-way cryptographic hashing function.
• Two-Factor Authentication (2FA): Available for all registered accounts as an additional layer of login security.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and regular third-party penetration testing.
• Access Controls: Personal data is accessible only to authorised personnel on a need-to-know basis, under strict internal access control policies.
• Incident Response: We maintain a documented data breach response procedure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users and relevant authorities within the timeframes required by applicable law.

Subject to applicable law and any overriding legal obligations, you have the following rights in respect of your personal data held by 9eclub. To exercise any of these rights, please contact our Data Protection contact as described in Section 14:

• Right of Access: You have the right to request a copy of the personal data we hold about you, together with information about how it is used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restrict Processing: You may request that we limit the processing of your data in certain circumstances, such as while you contest its accuracy.
• Right to Data Portability: Where processing is based on consent or contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests, including direct marketing. Where you object to marketing, we will cease such processing immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

We will respond to all valid data rights requests within 30 calendar days of receipt. In complex cases, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reason within the initial 30-day period. We will not charge a fee for responding to a data rights request unless the request is manifestly unfounded or excessive.

The 9eclub Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data from any person under the age of 21. Age verification is a mandatory step in our account registration and KYC process.

If we discover that we have inadvertently collected personal data from a person under the age of 21, we will take immediate steps to close the account, delete the associated personal data, and reverse any transactions processed in connection with that account. Any winnings associated with an underage account will be forfeited.

Parents and guardians who believe that a minor has registered on the Platform are encouraged to contact our support team immediately at [email protected] so that we can investigate and take appropriate action promptly.

In the course of operating the Platform, your personal data may be transferred to and processed in jurisdictions outside Malaysia, including where our server infrastructure, third-party processors, or game content providers are located.

Where such transfers occur, 9eclub ensures that appropriate safeguards are in place to protect your personal data at a level consistent with this Policy. These safeguards may include contractual arrangements with receiving parties, reliance on the adequacy of the destination jurisdiction's data protection framework, or other lawful transfer mechanisms recognised under applicable law.

9eclub reserves the right to update or revise this Privacy Policy at any time. Where amendments are material, we will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect. The date of the most recent revision is indicated at the top of this page.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed of how we protect your personal data.

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

• Email: [email protected] (plain text — not a clickable link. Mark your subject line as "Privacy / Data Request" for prioritised handling.)
• Live Chat: Available 24/7 on the Platform — suitable for general privacy queries.
• Response Time: We aim to acknowledge all privacy-related enquiries within 72 hours and to provide a substantive response within 30 calendar days.

If you are dissatisfied with our handling of your personal data or our response to a data rights request, you have the right to lodge a complaint with the applicable data protection supervisory authority in your jurisdiction. Please contact our team first so that we have the opportunity to address your concerns before escalation.