Flay99 Privacy Policy – Data Protection & User Privacy

01 Personal Information We Collect

Flay99 collects various types of personal information to enable us to provide a secure, efficient, and high-quality service to every user. This information is categorized as follows:

Account Registration Information:

• Full name as it appears on your official identity document
• Active email address to be used for account communications
• Mobile number for two-factor authentication and notifications
• Date of birth for minimum age verification
• Full residential address for identity verification purposes
• Passwords are stored in hashed format and cannot be read by our staff

Identity Verification (KYC) Information:

• A copy of your MyKad national ID or valid passport
• Proof of residential address such as a utility bill or recent bank statement
• A selfie or facial photo for visual identity verification
• Bank account or digital wallet details for processing deposits and withdrawals

Platform Usage Information:

• Game records, betting history, and financial transactions
• IP address, device type, operating system, and web browser used
• Session data including login timestamps, session duration, and in-platform activity
• Your selected game preferences and account settings

02 How We Use Your Personal Data

Every piece of information collected by flay99 is used for clear and legitimate purposes. The following are the primary uses of your personal data on our platform:

Flay99 will not use your data for any purpose not stated in this Privacy Policy without obtaining your consent first. Should there be any change to the purpose of data use, you will be informed via email or an in-platform notification.

03 Data Sharing with Third Parties

Flay99 maintains strict controls over the sharing of users' personal data. We do not sell or rent your data to any party. However, in certain circumstances, data may be shared with the following parties:

• Payment service providers: Transaction information required to process deposits and withdrawals is shared with approved payment processors, all subject to strict confidentiality agreements.
• Game software providers: Limited game data necessary to deliver a seamless gaming experience is shared with licensed game providers that partner with flay99.
• Law enforcement authorities: flay99 will disclose required information if ordered by a competent court or Malaysian law enforcement authority.
• KYC service providers: Identity verification documents are shared with trusted KYC partners for document verification and fraud prevention purposes.
• Analytics services: Anonymised and aggregated usage data is used for platform analytics purposes. This information cannot be attributed to any specific individual.

04 Use of Cookies and Tracking Technologies

The flay99 platform uses cookies and similar tracking technologies to enhance user experience, analyze platform performance, and ensure the security of your session. The following are the types of cookies we use:

• Essential Cookies (Required): These cookies are required for core platform functions such as login, session security, and account management. Without them, the platform cannot function properly and they cannot be disabled.
• Performance Cookies: Used to collect information on how users interact with our platform, such as the most frequently visited pages and error messages encountered. All such information is collected anonymously.
• Functional Cookies: Allows the platform to remember your preferences such as language, region, and personal settings to deliver a more personalized experience.
• Marketing Cookies: Used to display relevant advertisements and promotions to you. These cookies require your consent and can be disabled through your privacy settings.

You can manage your cookie preferences through your web browser settings or via the privacy control panel in your flay99 account. Please note that disabling certain cookies may affect the functionality of some parts of the platform.

05 Data Security Measures

Flay99 continuously invests in the latest security infrastructure to ensure your personal data is always protected. The key security measures we implement include:

• 256-bit SSL/TLS Encryption: All data transmitted between your browser and flay99 servers is encrypted using SSL/TLS protocol with a 256-bit encryption key — the highest industry standard currently available.
• Two-Factor Authentication (2FA): flay99 offers two-factor authentication for all user accounts. We encourage every user to enable this feature for an added layer of protection.
• 24/7 security monitoring: Our security team continuously monitors platform activity to detect and respond to any security threats or suspicious activity.
• Database encryption: All sensitive data stored in the flay99 database, including KYC information and financial details, is encrypted at rest.
• Internal access controls: Access to user data within flay99 staff is restricted on a need-to-know basis and governed by role-based access controls (RBAC).
• Regular security audits: The flay99 platform undergoes regular independent security audits by qualified cybersecurity firms to identify and address any vulnerabilities.

06 Personal Data Retention Period

Flay99 retains your personal data only for as long as necessary to fulfill the purposes stated in this Privacy Policy or as required by applicable Malaysian law. The following are our data retention guidelines:

• Active account data: Retained for the entire period your account remains active on the flay99 platform.
• Financial transaction records: Retained for a minimum of 7 years in accordance with Malaysia's anti-money laundering laws and financial regulations.
• KYC documents: Retained for the duration of the active account plus 5 years after account closure to meet legal obligations.
• Customer support communication logs: Retained for 3 years from the date of last interaction.
• Login and session data: Retained for 90 days for security and investigation purposes.
• Marketing data: Retained until you withdraw consent or request deletion.

When data is no longer needed or upon expiry of the defined retention period, flay99 will securely delete or destroy the data using trusted erasure methods.

07 Child Data Protection

The flay99 platform is exclusively for individuals aged 18 and above. We do not knowingly collect or process personal data from children under the age of 18.

If we discover that a child's personal data has been collected without valid parental or guardian consent, we will take immediate steps to delete that information and close the associated account.

If you believe your child or any minor has registered an account at flay99, please contact our support team immediately so we can take the appropriate action.

08 International Data Transfers

In the course of its operations, flay99 may transfer your personal data to servers located outside Malaysia. When such transfers occur, flay99 ensures that adequate and equivalent protections are in place through the following mechanisms:

• Data processing agreements compliant with international data protection standards
• Use of recognized Standard Contractual Clauses
• Transfers to countries with an equivalent or higher level of data protection
• Data protection impact assessment prior to any new international transfer

Flay99 will not transfer your data to jurisdictions that do not provide an adequate level of data protection without first putting in place appropriate additional safeguards.

09 How to Exercise Your Privacy Rights

Flay99 provides a simple and transparent process for users to exercise their privacy rights. To submit any request regarding your personal data, you may:

• Via account settings: Log in to your flay99 account and navigate to the "Privacy Settings" section to manage your data preferences, download your data, or request account deletion.
• Contacting customer support: Contact the flay99 support team via live chat on the platform, available 24/7, and state the type of privacy request you wish to make.
• Via support email: Submit a written request to our privacy team, including your full name, account number, and the type of request being made.

Flay99 will respond to all valid privacy requests within 30 business days of receipt. For complex requests, this period may be extended to 60 days with prior notice to you.

Please note that certain requests, such as data deletion, may not be fully fulfilled if flay99 has a legal obligation to retain that information. In such cases, we will explain the relevant reasons to you.

10 Amendments to This Privacy Policy

Flay99 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, or service improvements. When significant changes are made:

• The "Last Updated" date at the top of this document will be revised
• Notifications will be sent via email to all registered users
• In-platform notices will be displayed to communicate changes
• For changes involving new ways of using your data, new consent may be requested

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Continued use of the flay99 platform after any amendments take effect constitutes your acceptance of the updated terms.

11 Contact Our Privacy Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or how flay99 handles your personal data, do not hesitate to contact us through the following channels:

• Privacy Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat icon at the bottom right corner of the platform

Flay99 takes every privacy complaint seriously and is committed to resolving each issue within a reasonable timeframe. If you are not satisfied with our response, you have the right to refer your complaint to the Department of Personal Data Protection Malaysia or the relevant regulatory body.