Privacy Policy best99 — Personal Data Security for Malaysian Members

1Policy Introduction & Scope

This Privacy Policy describes how best99 — the operator of the online entertainment platform at the official website best99.win — how we collect, use, store, disclose, and protect your personal information. This document applies to all individuals who visit our website, register as a member, or use any services we offer through our web platform or mobile app.

We take our responsibilities as a data controller seriously and are committed to safeguarding your privacy in accordance with Malaysia's Personal Data Protection Act (PDPA) 2010. By using the best99 platform, you agree to the terms set out in this privacy policy.

2Types of Personal Data Collected

Best99 only collects personal data that is necessary and relevant to the stated purposes. The following are the categories of data we collect from members:

2.1 Registration Information

• Full name as per identity card (MyKad) or passport
• Date of birth for age verification (18 and above)
• Active email address for account communications
• Mobile number for two-factor authentication (2FA)
• Current residential address in Malaysia

2.2 Identity Verification (KYC) Information

• Copy of valid identity card (MyKad) or passport
• Proof of current address such as a utility bill or bank statement dated within the last three months
• Additional information that may be requested for AML compliance checks

2.3 Transaction & Financial Data

• Bank account or digital wallet details for processing deposits and withdrawals
• Records of all financial transactions including deposits, withdrawals, and wagering
• History of bonuses and promotions used

2.4 Usage & Technical Data

• IP address, browser type, and device information used
• Logs of in-platform activity including games played
• Cookie data and similar tracking technologies to enhance user experience

Data Category	Purpose of Collection	Retention Period
Registration Information	Account management & communications	Throughout active account + 5 years
KYC Documents	Identity verification & AML compliance	5 years after account closure
Transaction Data	Payment processing & auditing	7 years (legal requirement)
Usage Data	Platform improvement & security	12 months rolling
Cookie Data	User experience & analytics	Up to 24 months or manual deletion

3Purpose of Personal Data Use

Best99 uses members' personal data solely for legitimate purposes related to platform operations. We do not use your data for any other purpose without first obtaining your consent. The primary purposes of data use are as follows:

• Account Management: Create, verify, and securely maintain your member account
• Transaction Processing: Process deposits, withdrawals, and all financial transactions accurately and securely
• Legal Compliance: Meet KYC, AML, and applicable licensing regulatory requirements
• Platform Security: Detect and prevent fraud, unauthorised access, and suspicious activity
• Service Communications: Send important notifications relating to your account, transactions, and platform updates
• Customer Support: Provide efficient and accurate assistance when you contact our team
• Continuous Improvement: Analyse usage patterns to improve service quality and user experience

4Data Sharing & Disclosure to Third Parties

Best99 does not sell, rent, or trade members' personal data to any third party for marketing or commercial purposes. However, in certain limited situations, data may be shared with trusted third parties as follows:

• Payment Service Providers: FPX, local banks, and digital wallet providers to process your financial transactions
• KYC Service Providers: Recognised third-party identity verification platforms for processing member verification documents
• Technology Infrastructure Providers: Hosting and cybersecurity partners that help maintain platform operations
• Statutory Authorities: Government agencies, enforcement bodies, or courts when required under Malaysian law

All third parties working with best99 are bound by strict confidentiality agreements and are only permitted to use your data for specified purposes. We ensure every partner upholds data protection standards equivalent to our own practices.

5Data Security & Protection

Best99 continuously invests in security infrastructure to ensure your personal data is always protected from cyber threats, unauthorised access, and data loss. Key security measures we implement include:

• 256-bit SSL/TLS encryption for all data transmitted over the network
• Encryption of data stored in databases using AES-256
• Two-factor authentication (2FA) for member account access and internal administration systems
• 24/7 security monitoring by a dedicated cybersecurity team
• Regular penetration testing by independent security experts
• Access controls based on the principle of least privilege — staff may only access data necessary for their duties
• Full audit logs for all data access and changes

6Your Rights as a Member

Under Malaysia's Personal Data Protection Act (PDPA) 2010, you have the following rights regarding your personal data held by best99:

To exercise any of the above rights, please contact the best99 customer support team via live chat on the platform. We will process your request within 30 business days and may require identity verification before taking action.

7Cookies & Tracking Technologies

Best99 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

7.1 Types of Cookies Used

• Essential Cookies: Required for core platform functions such as login verification and session security — cannot be disabled
• Performance Cookies: Collect anonymous information about how you use the platform to help us make improvements
• Functional Cookies: Remember your preferences such as language and display settings to deliver a more personalised experience
• Analytics Cookies: Help us understand traffic patterns and platform usage in an aggregated, anonymised manner

You can manage or delete cookies through your web browser settings. However, disabling essential cookies may affect certain platform functions. Continued use of the platform after the cookie notice is displayed constitutes your consent.

8International Data Transfers

In certain operational circumstances, your personal data may be stored or processed outside Malaysia by our technology infrastructure service providers. When this occurs, best99 ensures that such data transfers are carried out with adequate safeguards, including data processing agreements that comply with international data protection standards equivalent to Malaysia's PDPA.

We do not transfer data to countries or territories that do not provide an equivalent level of data protection, except with your consent or as required by law.

9Child Privacy

The best99 platform is strictly for adults aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18. Should we discover that a minor's data has been collected without our knowledge, such data will be deleted immediately and the relevant account will be closed.

If you find that your child has registered or attempted to access the best99 platform, please contact us immediately through our customer support team so that appropriate action can be taken.

10Contact Us Regarding Privacy

If you have any questions, concerns, or complaints regarding how best99 handles your personal data, we encourage you to contact us directly. Our privacy team will respond within seven business days.

You also have the right to lodge a complaint with the Department of Personal Data Protection Malaysia if you believe your privacy rights have been violated and we have failed to address your concerns satisfactorily.