939 Privacy Policy – Personal Data Protection for Malaysian Members

1 Introduction

939 deeply values the trust you place in us by sharing your personal information. As a responsible online entertainment platform, we take every aspect of member data protection and privacy seriously.

This Privacy Policy is an official document that transparently explains how 939 collects, uses, stores, protects, and in certain circumstances shares your personal information. It applies to all use of the 939 platform, including the official website at 939.ad and our mobile app.

We comply with Malaysia's Personal Data Protection Act 2010 (PDPA) and all applicable related legislation. Our commitment to data protection goes beyond a legal obligation — it is a core value we uphold because we believe your trust is the most valuable asset we hold.

This policy may be updated from time to time. Any material changes will be communicated to you via an in-platform notice or through your registered email. The "Last Updated" date at the top of this document indicates when the policy was last reviewed.

2 Personal Information We Collect

939 collects various types of information depending on how you interact with our platform. The table below provides a clear overview of the data categories we collect:

We only collect information that is strictly necessary for the stated purposes. This "data minimisation" principle ensures we do not collect excessive or irrelevant data beyond what is needed to operate the platform.

3 How We Collect Information

Your personal information is collected through various channels when you interact with 939. Here are the main ways we obtain your information:

• Account Registration: When you register a new account at 939, you are required to fill in basic information such as your name, date of birth, email, and phone number.
• KYC Process: To verify your identity and comply with regulatory requirements, we will request supporting documents such as your MyKad or passport during the verification process.
• Platform Usage: We automatically record your activity on the platform, including games played, wagers placed, and interactions with the user interface.
• Financial Transactions: Every deposit and withdrawal generates a transaction record that is retained for compliance and audit purposes.
• Device and Browser: Technically, our platform automatically records technical information about your device whenever you access our website or app.
• Customer Communications: When you contact our support team, all communications are recorded for training and service improvement purposes.
• Cookies and Similar Technologies: We use cookies and similar tracking technologies to understand usage patterns and enhance your experience.

4 How We Use Your Information

939 uses collected information for legitimate, clearly stated purposes. We do not use your data in ways you would not expect. The primary purposes are as follows:

• Providing, operating, and maintaining your member account and all related services.
• Processing financial transactions including deposits, withdrawals, and bonus payments securely and accurately.
• Verifying your identity through the KYC process to prevent fraud, money laundering, and platform misuse.
• Sending important communications related to your account such as security notices, transaction confirmations, and policy updates.
• Monitoring activity to detect and prevent fraud, hacking, and any security threats to our platform and members.
• Complying with legal and regulatory obligations applicable to online gambling platform operations.
• Supporting responsible gaming initiatives by monitoring gameplay patterns that may indicate signs of problem gambling.
• Enhancing user experience, developing new features, and improving platform performance based on usage data.

5 Data Sharing with Third Parties

939 does not sell or trade your personal data to any third party for their own commercial purposes. However, in the course of operating the platform, we may share certain information with a limited and accountable set of third-party categories:

• Payment Service Providers: To process deposits and withdrawals, transaction information must be shared with licensed payment providers working with us, including FPX and e-wallet providers.
• KYC Service Providers: We use approved third-party identity verification providers to authenticate the documents you submit during the KYC process.
• Game Providers: Minimum technical information is shared with third-party game providers to ensure a smooth and secure gaming experience.
• Regulatory Authorities and Bodies: 939 will disclose information to regulatory authorities, law enforcement, or courts when required by applicable law.
• Analytics Services: Anonymised and aggregated data may be shared with analytics providers to help us understand usage patterns and improve the platform.

All third parties working with us are required to comply with data protection standards equal to or higher than our own. They are only permitted to use your data for purposes specified in their agreement with 939.

6 Security & Data Protection

Protecting your personal data is a responsibility we take extremely seriously. 939 continuously invests in the latest cybersecurity infrastructure to keep your data safe at all times.

The security measures we practise include:

• 256-bit SSL Encryption: All data transmitted between your browser and our servers is fully encrypted using the latest TLS protocol.
• Stored Data Encryption: Sensitive data such as financial information and identity documents are encrypted when stored in our database.
• Strict Access Control: Only authorised 939 staff may access member personal data, and such access is monitored and audited on a regular basis.
• Two-Factor Authentication (2FA): Our internal systems use multi-factor authentication to prevent unauthorized access by external parties.
• 24/7 Monitoring: Our cybersecurity team continuously monitors systems to detect and respond to any threats promptly.
• Regular Security Audits: We conduct regular penetration testing and security audits carried out by qualified independent security experts.

7 Cookie & Tracking Technology Usage

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

We use several types of cookies for different purposes:

• Essential Cookies: Required for core platform functions such as login, session management, and security. These cookies cannot be disabled.
• Performance Cookies: Collecting information on how you use the platform to help us improve performance and functionality.
• Functional Cookies: Enabling the platform to remember your preferences such as language, display settings, and personal configurations.
• Analytics Cookies: Helping us understand aggregate usage patterns to improve the overall platform experience.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect platform functionality. We recommend keeping essential cookies enabled for the best experience on 939.

8 Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have certain rights regarding the personal data we hold about you. 939 fully respects and supports the exercise of these rights.

To exercise any of the above rights, please contact our privacy team through the 939 customer support channel. We may need to verify your identity before processing your request to ensure your data remains secure.

9 Data Retention & Deletion

939 retains your personal data only for as long as necessary for the purposes stated in this policy, or as required by law. Retention periods vary by data type:

• Active Account Data: Retained for as long as your account is active and for three years after the account is closed.
• Financial Transaction Records: Retained for seven years in line with Malaysia's financial regulatory requirements.
• KYC Documents: Retained for five years from the date of verification or termination of the business relationship, whichever is later.
• Security Logs: Retained for two years for the purposes of investigating any potential security incidents.
• Support Communication Records: Retained for two years for training and service improvement purposes.

Once the retention period has ended and there is no legal requirement to store data further, 939 will securely delete or anonymize your personal data using methods that ensure the data cannot be recovered.

10 Contact Us Regarding Privacy

If you have any questions, concerns, or complaints regarding this privacy policy or how we handle your personal data, we encourage you to get in touch. The 939 privacy team is here to help.

You can reach us via:

• Privacy Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week via the chat icon on the platform.
• FAQ Section: Visit page FAQ ours for answers to common privacy-related questions.

We are committed to responding to all privacy-related enquiries within 3 working days. If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia.