Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") applies to all personal data collected by 9kelab ("we", "us", "our") in connection with your use of the 9kelab online gaming platform accessible at 9kelab.one, including all games, account services, customer support interactions, and promotional communications.

1.2 9kelab acts as the data controller in respect of personal data collected directly through the Platform. Where 9kelab engages third-party service providers who process data on our behalf, those providers act as data processors under binding contractual obligations consistent with this Policy.

1.3 This Policy should be read alongside the 9kelab Terms and Conditions, which incorporate this Policy by reference. If you do not agree with the practices described in this Policy, you should not register an account or use the 9kelab platform.

2. Personal Data We Collect

2.1 Registration Data: When you create a 9kelab account, we collect your full legal name, date of birth, email address, residential address, and preferred contact details. This information is required to create and verify your account.

2.2 Identity Verification Data: To comply with anti-money laundering (AML) and know-your-customer (KYC) obligations, we may request copies of government-issued identification documents, proof of address, and proof of payment method ownership.

2.3 Financial Data: We collect details of deposit and withdrawal transactions, including payment method identifiers (e.g., bank account numbers partially masked, e-wallet identifiers), transaction amounts, and transaction timestamps. Full payment card numbers are never stored by 9kelab.

2.4 Gaming Activity Data: We record your game session history, wager amounts, game outcomes, bonus usage, and betting patterns for the purposes described in Section 3.

2.5 Device and Technical Data: When you access the 9kelab platform, we automatically collect your IP address, browser type and version, operating system, device identifiers, screen resolution, and session timestamps.

2.6 Communications Data: Records of your interactions with 9kelab's customer support team, including live chat transcripts and email correspondence, are retained for quality assurance and dispute resolution purposes.

2.7 Marketing Preferences: Where you have opted in to receive promotional communications from 9kelab, we retain records of your marketing preferences and communication history.

3. How We Use Your Personal Data

3.1 9kelab uses the personal data we collect for the following purposes:

• Account administration: Creating, maintaining, and securing your 9kelab account, verifying your identity, and processing login authentication;
• Service delivery: Processing deposits and withdrawals, crediting bonuses, and delivering the gaming services you request;
• Regulatory compliance: Meeting our obligations under anti-money laundering legislation, gaming licensing requirements, and applicable data protection laws, including conducting KYC and AML checks;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account abuse, and unauthorised access;
• Responsible gaming: Monitoring gaming activity for indicators of problem gambling behaviour, applying player-requested limits, and complying with self-exclusion requests;
• Customer support: Responding to your enquiries, resolving disputes, and improving our support services;
• Platform improvement: Analysing aggregated usage data to improve game offerings, platform performance, and user experience;
• Marketing communications: Sending you promotional offers, bonuses, and platform updates where you have provided consent to receive such communications.

4. Legal Basis for Processing

4.1 9kelab processes personal data on the following legal bases:

• Contract performance: Processing necessary to provide the gaming services you have contracted for by registering a 9kelab account;
• Legal obligation: Processing required to comply with AML regulations, gaming licence conditions, and applicable financial crime prevention laws;
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights;
• Consent: Processing for direct marketing communications, where we rely on your explicit, freely given, and withdrawable consent.

4.2 Where 9kelab relies on your consent as the legal basis for any processing activity, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing and Disclosure

5.1 9kelab does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial marketing purposes.

5.2 We share your personal data with third parties only in the following circumstances:

• Service providers: Third-party vendors engaged by 9kelab to provide services including payment processing, identity verification, fraud detection, customer support technology, and cloud infrastructure. These providers are bound by data processing agreements that restrict their use of your data to the specific services they provide to 9kelab;
• Game providers: Licensed game studios whose titles appear on the 9kelab platform may receive session-level data necessary to deliver their games. This data does not include your full identity profile;
• Regulatory and law enforcement authorities: Where we are legally required to disclose personal data in response to a lawful court order, regulatory demand, or law enforcement request;
• Business transfers: In the event of a merger, acquisition, or sale of substantially all of 9kelab's assets, personal data may be transferred to the acquiring entity subject to equivalent privacy protections.

5.3 Malaysian players' data processed in connection with Touch 'n Go eWallet, Boost, and Malaysian bank transactions is shared with the relevant payment service providers solely for the purpose of executing the requested financial transaction.

6. Cookies and Tracking Technologies

6.1 The 9kelab platform uses cookies and similar tracking technologies to operate and improve the Platform's functionality. These include:

• Essential cookies: Required for the Platform to function, including session management, login state maintenance, and security features. These cannot be disabled without affecting core functionality;
• Performance cookies: Used to collect anonymised data about how players navigate the Platform, enabling 9kelab to identify and resolve usability issues;
• Preference cookies: Store your Platform settings such as preferred language and display options;
• Analytics cookies: Enable aggregated analysis of Platform usage patterns to inform development decisions. These are operated under strict data minimisation principles.

6.2 You may configure your browser to refuse non-essential cookies. However, disabling essential cookies will impair your ability to use the 9kelab platform, including the login and payment functions.

7. Data Retention

7.1 9kelab retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following considerations:

• Account and identity verification records are retained for a minimum of five (5) years following account closure to meet AML and gaming licence record-keeping obligations;
• Transaction records are retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications are retained for two (2) years unless they relate to a dispute or regulatory matter that requires longer retention;
• Marketing preference records are retained until you withdraw consent or request deletion, subject to any applicable legal retention requirements.

7.2 Where personal data is no longer required for any retention purpose, 9kelab will securely delete or anonymise it in accordance with our data destruction procedures.

8. Data Security

8.1 9kelab implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS encryption for all data transmitted between your browser and the 9kelab platform;
• Encryption of sensitive data fields at rest within our database infrastructure;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of platform infrastructure;
• Incident response procedures for managing and notifying of data security incidents.

8.2 In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, 9kelab will notify affected players without undue delay and take all reasonable steps to contain and remediate the breach.

9. Your Data Rights

9.1 Subject to applicable data protection laws, you have the following rights in respect of your personal data held by 9kelab:

• Right of access: The right to request a copy of the personal data 9kelab holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data in certain circumstances, subject to applicable retention obligations;
• Right to restriction: The right to request that 9kelab restrict processing of your personal data in certain circumstances;
• Right to data portability: The right to receive personal data you have provided to 9kelab in a structured, commonly used, machine-readable format;
• Right to object: The right to object to processing based on legitimate interests or for direct marketing purposes;
• Right to withdraw consent: The right to withdraw any consent you have provided for processing at any time.

9.2 To exercise any of the above rights, contact 9kelab at [email protected]. We will respond to all valid requests within 30 days. We may need to verify your identity before processing certain requests.

10. Children's Privacy

10.1 The 9kelab platform is strictly intended for adults aged 21 years and above. 9kelab does not knowingly collect personal data from individuals under the age of 21.

10.2 If 9kelab becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe a minor has registered an account with 9kelab, please contact us immediately at [email protected].

11. International Data Transfers

11.1 9kelab may transfer personal data to service providers or infrastructure located outside of Malaysia. Where such transfers occur, 9kelab ensures that appropriate safeguards are in place to protect your personal data, including contractual mechanisms consistent with applicable data protection requirements.

11.2 9kelab will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate compensating controls.

12. Updates to This Policy

12.1 9kelab reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via their registered email address or by a prominent notice on the Platform prior to the changes taking effect.

12.2 Your continued use of the 9kelab platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised practices described therein. The date at the top of this Policy indicates when it was last revised.

13. Contact and Data Enquiries

For any questions, concerns, or requests relating to this Privacy Policy or 9kelab's data practices, please contact us:

• Email: [email protected]
• Live Chat: Available 8am – 2am (GMT+8) daily via the 9kelab platform

9kelab aims to acknowledge all privacy-related correspondence within two business days and to resolve substantive enquiries within 30 calendar days.