Privacy Policy 939 — Our Commitment to Protecting Your Personal Data

1 Introduction

939 is an online casino and wagering platform operating for users in Malaysia. We understand that your trust is our most valuable asset, and one of the most important ways to maintain that trust is by ensuring your personal data is handled responsibly, transparently and securely.

This Privacy Policy details the types of information we collect when you use the 939 platform, the purposes for which it is collected, how it is used, with whom it may be shared, and the rights you hold regarding your personal data. This Policy applies to all users who access the 939 platform via web browser, mobile app, or any digital channel we provide.

We comply with Malaysia's Personal Data Protection Act 2010 (PDPA) and relevant international data protection standards. Any collection and processing of personal data we carry out is based on a valid legal basis, whether on the grounds of your consent, contractual necessity, or the legitimate interests of 939 that do not override your fundamental rights and freedoms.

If at any time you have questions or concerns about how we manage your personal data, please contact our privacy team through the details provided at the end of this document. We are committed to responding to every inquiry promptly and transparently.

2 Information Collected

939 collects various types of information to enable us to provide a safe, fair and personalised service to every user. The information we collect falls into three main categories:

A. Information You Provide Directly

• Full name as it appears on a valid identity document.
• Date of birth — collected for the purpose of verifying the minimum age requirement of 18 and above.
• Email address and phone number for communication and account security purposes.
• Current residential address for identity verification and regulatory compliance purposes.
• Payment method details such as bank account numbers, account holder names, and e-wallet information required for processing deposits and withdrawals.
• Copies of identity documents (National ID, Passport) submitted during the KYC process.
• Any other information you provide when contacting customer support or participating in promotional programmes.

B. Automatically Collected Information

• IP address and general location data based on IP for security and geo-restriction compliance purposes.
• Device type, operating system, web browser version, and screen resolution.
• Session log data including the date, time and duration of access, pages visited, and clicks made within the platform.
• Technical data relating to app performance, error reports and diagnostic data that help us identify and resolve technical issues.

C. Gaming Activity Information

• A record of all deposits and withdrawals made to and from your account.
• Wagering history, games played, total bets placed, and game outcomes.
• Bonus and promotion usage, including rollover status and redemption dates.
• History of VIP status changes and loyalty levels achieved.

3 How We Use Your Data

Every piece of information we collect is used for a clear and lawful purpose. 939 does not use user data for purposes unrelated to platform operations without first obtaining your consent. The following are the data use purposes we practise:

• Service Delivery: To create, manage, and maintain your user account, process deposits and withdrawals, and ensure continued access to all features of the 939 platform.
• Identity Verification: To comply with KYC and AML (Anti-Money Laundering) requirements set by regulatory bodies, including verifying the age and identity of users.
• Account Security: To detect and prevent fraudulent activity, unauthorised access, system abuse, and other security breaches that may affect your account.
• Service Communications: To send important account notifications, transaction confirmations, security updates, and changes to terms that require your attention.
• Customer Support: To process and resolve complaints, enquiries, and assistance requests submitted through our various support channels.
• Personalize Your Experience: To personalise the platform display, promotional offers, and game recommendations based on your preferences and playing habits.
• Platform Improvements: To analyse usage patterns, identify areas for improvement, and develop new features that enhance the overall user experience.
• Legal Compliance: To comply with all legal obligations, regulatory requirements, and court orders applicable to 939's operations.

4 Information Sharing

939 does not sell or trade users' personal information. However, in the course of operating the platform, there are certain situations where we need to share information with trusted parties:

• Service Providers: We work with carefully selected third-party service providers, including payment processors, cloud service providers, identity verification companies, and gaming software providers. All parties are required to comply with strict data protection standards and are only permitted to use your data for the specific agreed purposes.
• Regulatory Bodies: 939 will disclose required information to regulatory bodies, law enforcement or government authorities when mandated to do so by law, regulation or a valid court order.
• Fraud Prevention: Certain information may be shared with fraud prevention organizations and financial institutions as part of an integrated fraud detection system that protects the digital financial ecosystem.
• Business Transfer: If 939 is involved in a merger, acquisition, or asset sale, user information may be transferred as part of that transaction. You will be notified in advance through a clear notice.

5 Data Security

Protecting your personal data is a core technical and operational priority for 939. We continuously invest in the latest security infrastructure to ensure your data is always protected. The security measures we employ include:

• End-to-End Encryption: All communications between your device and 939's servers are encrypted using TLS 1.3 protocol with SSL 256-bit encryption. This means data in transit cannot be read by unauthorised parties, even if the transmission is intercepted.
• Layered Access Controls: Access to databases containing user information is restricted to specifically authorised personnel only. All access is logged and continuously monitored by our security team.
• Two-Factor Authentication (2FA): 939's internal systems use two-factor authentication for all admin access. We also encourage users to enable this feature for their own accounts.
• Regular Security Scanning: Our platform is subject to regular penetration testing and vulnerability scanning conducted by trusted independent security experts.
• Secure Data Centre: Your data is stored in data centres that comply with the highest physical security standards, equipped with biometric access controls, 24/7 surveillance and redundant backup systems.
• Incident Response Plan: 939 maintains a well-structured incident response procedure. In the event of any data breach, we will respond within 72 hours and notify affected users in accordance with legal requirements.

While we take all reasonable precautions, no online system can guarantee absolute security. We encourage you to play your part in protecting your account by using a strong password, not sharing your login credentials, and reporting any suspicious activity to us promptly.

6 Cookie Policy

The 939 platform uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions smoothly. The following are the types of cookies we use:

• Essential Cookies: These cookies are required for core platform functions such as login authentication, session management, and security. Without them, the platform cannot function properly. These cookies cannot be disabled.
• Performance Cookies: Used to gather information on how users interact with our platform — which pages are visited most frequently, how long sessions last, and where users encounter issues. All data collected is aggregated and not individually identifiable.
• Functional Cookies: Allows the platform to remember your preferences such as language, display settings, and game preferences to provide a more personalized experience on future visits.
• Analytics Cookies: We use internal analytics tools to understand usage patterns and improve the platform. Analytics data is not shared with third-party advertising platforms.

You can manage cookie settings through your web browser settings. However, disabling certain cookies may affect the functionality and experience of using the 939 platform. For guidance on managing cookies across different browsers, please refer to your browser's help documentation.

7 Data Retention

939 retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy, or as required by applicable laws and regulations. Retention periods vary by data type as specified in the table in Section 2.

When your account is closed — whether at your own request or at 939's decision — your personal data will not be immediately deleted. We retain the necessary records to:

• Comply with legal and regulatory obligations that require financial records to be retained for a specified period (typically 7 years).
• Resolve any disputes, claims, or investigations that may arise after account closure.
• Prevent fraud and ensure individuals who have been banned cannot register a new account.

Once the designated retention period has ended, your data will be securely deleted or converted into an anonymised format that cannot be linked back to you personally.

8 User Rights

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have certain rights regarding your personal data held by 939. We fully respect these rights and provide clear channels for you to exercise them:

• Right to Access: You have the right to request a copy of the personal data we hold about you. We will process this request within 14 working days.
• Right to Rectification: If you find that personal data held by 939 is inaccurate or incomplete, you have the right to request a correction. You can update basic information directly through your account profile settings.
• Right to Erasure: In certain circumstances, you have the right to request deletion of your personal data. However, this right is subject to our legal obligations to retain certain records.
• Right to Object to Processing: You have the right to object to the processing of your personal data for direct marketing purposes at any time. Upon receiving your objection, we will cease using your data for that purpose.
• Right to Withdraw Consent: Where data processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the validity of processing carried out prior to the withdrawal.

9 Children's Privacy

The 939 platform is exclusively for individuals who are of age 18 years and above. We do not intentionally collect, store or process any personal data from individuals under the age of 18.

If we determine that personal information belonging to someone under the age of 18 has been collected without proper age verification, we will take immediate steps to delete that information and close the associated account. Such findings may also be reported to the relevant authorities.

If you believe your child or any minor has registered an account on the 939 platform, please contact our support team immediately so that appropriate action can be taken.

10 Third-Party Links

The 939 platform may contain links to third-party websites or services such as game providers and payment partners. This Privacy Policy applies only to the 939 platform and does not cover the privacy practices of any third parties.

We encourage you to read the privacy policy of every third-party service you use. 939 is not responsible for the content, privacy policies, or practices of any third-party websites or services that are not directly under our control.

11 Policy Amendments

939 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, legal requirements or new platform features. Any material amendments will be communicated to you via a prominent notice on the platform or through your registered email.

Continued use of the 939 platform after any amendments to the Privacy Policy take effect will be considered your acceptance of those changes. We encourage you to review this page periodically to ensure you are always informed about how we protect your information.

The "Updated" date at the top of this page will always reflect the effective date of the latest revision.

12 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how 939 handles your personal data, please do not hesitate to contact us. Our privacy team is available to assist you every business day.