Clu99 Privacy Policy — Malaysia Player Personal Data Protection

Clu99 ("we", "our platform") is an online entertainment platform operator accessible at clu99.onl. We take our responsibilities as a data controller seriously and are committed to ensuring that all members' personal information is handled in a transparent, secure, and responsible manner.

This Privacy Policy applies to all users who register, browse, or use clu99's services, including our website, mobile app, and all official communication channels. By using this platform, you acknowledge that you have read and understood this policy.

We recommend reading this policy together with Terms and Conditions and Responsible Gaming Policy us for a full overview of how we manage your account and information.

Clu99 only collects data that is strictly necessary to provide you with a safe, compliant, and quality service. The following are the categories of data we collect:

The data we collect is used solely for legitimate purposes directly related to the services we offer. We do not use your data for any other purpose without your explicit consent.

• Verifying your identity during registration and the KYC process to ensure account security and comply with anti-money laundering (AML) legal requirements.
• Processing deposits and withdrawals quickly and securely through your preferred payment methods, including FPX, DuitNow, Maybank, CIMB and supported eWallets.
• Sending important security notices such as new login alerts, password changes, transaction confirmations and suspicious activity warnings to your registered email or phone number.
• Monitoring gameplay habits for Responsible Gaming purposes — including detecting concerning play patterns and proactively activating protective features.
• Improving the user experience on the platform by analysing aggregated and anonymised usage data to better understand player needs.
• Complying with applicable legal and regulatory obligations, including reporting suspicious activity to the relevant authorities when required by law.
• Sending you relevant promotional information and exclusive offers — only if you have given consent to receive marketing communications.

Clu99 does not sell, rent, or disclose your personal data to any third party for their own commercial purposes. However, there are limited situations where we need to share your information with trusted parties:

• Payment Service Providers — Transaction information is shared with licensed payment processors such as FPX, DuitNow, and banking partners to securely process your deposits and withdrawals.
• Game Software Providers — Minimal game session data is shared with licensed game providers to ensure continuity of play and resolution of any technical disputes.
• Authorities & Regulatory Agencies — clu99 will disclose the required information to lawful authorities when mandated by law, court order, or official investigation.
• Identity Verification Services — Your KYC documents are processed through a licensed identity verification platform that complies with international security standards.
• Analytics & Security — Anonymized usage data is shared with analytics and cybersecurity service providers to detect fraud and improve platform performance.

All third parties working with clu99 are bound by strict confidentiality agreements and are required to handle your data in accordance with our privacy policy. We do not permit them to use your data for any purpose other than what has been agreed upon.

Your data security is the absolute top priority at clu99. We invest in industry-grade security infrastructure to ensure your information is always protected against unauthorised access, loss or misuse.

• 256-bit SSL encryption is applied to all data transmissions between your browser or app and clu99's servers — the same level of protection used by leading banking institutions.
• Sensitive data such as passwords is stored using one-way hashing algorithms that cannot be decrypted, ensuring that even internal staff cannot view your actual password.
• KYC documents and financial information are stored on isolated servers protected by additional security layers with strictly limited access.
• Our 24/7 monitoring system detects and blocks unauthorized access attempts automatically in real time.
• Regular security audits are conducted by qualified independent parties to identify and address any system vulnerabilities before they can be exploited.
• Two-factor authentication (2FA) is available for all accounts to add an extra layer of security to your login process.

Clu99 uses cookies and similar tracking technologies to enhance the user experience, maintain session security, and understand how players interact with our platform.

• Essential Cookies — Required for core platform functions such as login verification, session management, and security. These cookies cannot be disabled.
• Preference Cookies — Stores your preferences such as language, display settings, and game preferences so you do not need to reconfigure them each time you log in.
• Analytics Cookies — Helps us understand aggregate usage patterns to improve navigation, platform performance, and the overall experience. This data is not linked to your personal identity.
• Security Cookies — Used to detect suspicious login attempts, fraud, and bot activity that could compromise your account security.

You can manage your cookie preferences through your browser settings. However, disabling essential cookies may affect certain platform features. For guidance on managing cookies in popular browsers, refer to your browser's official documentation.

As a clu99 user, you have clear rights regarding your personal data. We respect and facilitate the exercise of these rights without any unreasonable barriers:

To exercise any of the above rights, contact our support team via live chat or official email. We will process your request within 14 business days. Some requests may require additional identity verification before we can proceed.

Clu99 retains your personal data for as long as your account is active or as long as necessary for the purposes stated in this policy. Retention periods vary depending on the type of data and legal requirements:

• Financial transaction records and account history are retained for a minimum of 5 years in accordance with financial compliance requirements and applicable AML laws in Malaysia.
• KYC documents and identity verification records are retained for the duration of the active account plus 5 years after account closure for audit and compliance purposes.
• Customer support communication logs are retained for 2 years for dispute resolution and service improvement purposes.
• Game data and session logs are retained for 1 year for security, fraud prevention, and technical dispute resolution purposes.
• Once the retention period expires, data will be securely deleted or anonymized so that it can no longer be linked to your identity.

Clu99 is a platform exclusively for adults aged 18 and above. We do not intentionally collect or process personal data from minors.

• The registration process includes strict age verification through official identity documents. All accounts suspected of belonging to underage users will be immediately suspended and investigated.
• If we discover that we have inadvertently collected data from anyone under the age of 18, that data will be deleted immediately and the account will be terminated.
• Parents or guardians who suspect this platform has been accessed by their child are encouraged to contact us immediately so we can take the appropriate action.

In some cases, your personal data may be transferred to and stored on servers located outside Malaysia. This may occur when we engage cloud service providers or international technology partners.

• All cross-border data transfers are carried out with adequate safeguards, including data processing agreements that comply with international data protection standards.
• Clu99 ensures that all data recipients outside Malaysia provide a level of protection equivalent to that required within Malaysia.
• The most sensitive financial and KYC data is prioritised for storage on servers located within the Asia region to minimise the risk of long-distance data transfers.

Clu99 reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or service improvements. We are committed to informing you of any material changes.

• Any significant changes to this policy will be communicated to you via a notice published on the platform's home page or by email to your registered address.
• The "Updated" date at the top of this document will always reflect the latest version of our privacy policy.
• Continued use of the platform after changes are published constitutes your acceptance of the updated policy.
• If you disagree with any changes made, you have the right to stop using the platform and close your account, with all valid balances processed for withdrawal.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, our privacy team is ready to assist you.

Clu99 takes every privacy-related complaint seriously. If you are not satisfied with our response, you have the right to refer your complaint to the relevant data protection authority in Malaysia.