9club Privacy Policy

01 Introduction

9club ("we", "our", "us", "Platform") is committed to protecting and respecting the privacy of all users who access or interact with the website located at https://9club.casa and any associated services (collectively, the "Service"). This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed.

This Policy applies to all users of the 9club Service, including registered account holders and visitors who interact with the platform without registering. By accessing or using the Service you acknowledge that you have read, understood and agree to the data practices described herein. If you do not agree, you must discontinue use of the Service immediately.

This Policy should be read in conjunction with the 9club Terms and Conditions, which govern the contractual relationship between you and 9club. Where both documents address the same topic, this Policy applies specifically to personal data matters.

02 Definitions

The following defined terms are used throughout this Policy and carry the meanings set out below:

"Personal Data"

Any information relating to an identified or identifiable natural person, including but not limited to name, email address, device identifiers, IP address and payment reference details.

"Processing"

Any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination or erasure.

"Data Controller"

9club, the entity that determines the purposes and means of processing Personal Data collected through the Service.

"Data Subject"

The identified or identifiable natural person to whom Personal Data relates — in this context, the registered user or visitor of the 9club platform.

"Cookies"

Small text files placed on a user's device by a website for purposes such as session management, preference storage, analytics and targeted content delivery.

"KYC" (Know Your Customer)

Mandatory identity verification procedures performed by 9club to confirm the identity of users, comply with applicable legal obligations and prevent fraud.

"Third Party"

Any individual or entity other than the Data Subject and 9club, including payment service providers, analytics providers and regulatory authorities.

03 Data We Collect

9club collects Personal Data through several channels in the ordinary course of providing the Service. The categories of data collected include the following:

9club does not intentionally collect sensitive personal data — such as racial or ethnic origin, health information or biometric data — unless it is specifically required for an applicable legal or regulatory compliance obligation, in which case separate notice will be provided.

04 Data Processing

9club processes Personal Data for the following operational, legal and service-related purposes:

• Account creation and management: To register your 9club account, maintain your account profile, authenticate your identity and communicate account-related information to you.
• Transaction processing: To facilitate MYR deposits and withdrawals via supported Malaysian payment channels, including Maybank2u, CIMB Clicks, Public Bank Online, DuitNow, FPX, Touch 'n Go eWallet, Boost and GrabPay.
• Identity verification and fraud prevention: To conduct KYC checks, anti-money-laundering ("AML") screening and responsible gambling age verification in accordance with applicable obligations.
• Customer support: To respond to account queries, payment questions, bonus clarification requests and responsible gambling concerns submitted through live chat, email or other supported channels.
• Platform security: To detect, investigate and prevent fraudulent, abusive or unauthorised activity — including duplicate account detection and bot/automated-access controls.
• Legal and regulatory compliance: To meet obligations imposed by applicable laws, respond to requests from regulatory or law-enforcement authorities and enforce the 9club Terms and Conditions.
• Service improvement: To analyse aggregated and anonymised usage patterns that inform product development, content improvements and support workflow optimisation.
• Promotional communications: Where you have given consent or where a legitimate-interest basis applies, to send relevant promotional information about 9club offers, new features or updates. You may withdraw consent for marketing communications at any time.

05 Lawful Bases for Processing

9club processes Personal Data only where a recognised lawful basis exists. The primary bases on which 9club relies are as follows:

• Performance of a contract: Processing is necessary to deliver the Service to you in accordance with the 9club Terms and Conditions — for example, processing deposits in MYR and managing your account balance.
• Legal obligation: Processing is required to comply with applicable law — for example, conducting KYC identity checks, retaining transaction records and responding to regulatory enquiries.
• Legitimate interests: Processing is necessary for 9club's legitimate interests in operating a secure, functional and commercially viable service, provided those interests are not overridden by your data-protection rights. This includes fraud prevention, security monitoring and service analytics.
• Consent: Where no other lawful basis applies and processing is not strictly necessary for the Service — for example, optional marketing communications — 9club will seek your explicit consent and will not process that data unless consent is freely given and recorded.

06 Data Sharing

9club does not sell, rent or trade Personal Data to third parties for commercial purposes. Personal Data may be shared with the following categories of recipient only where necessary and proportionate:

• Payment service providers: Malaysian payment operators and processors — including those operating Maybank2u, CIMB Clicks, DuitNow, FPX, Touch 'n Go eWallet, Boost and GrabPay — receive only the transactional data required to process a specific MYR deposit or withdrawal.
• Identity verification providers: Third-party KYC and AML service providers who process identity and verification documents on 9club's behalf and under strict contractual data-processing terms.
• Technology and infrastructure providers: Hosting, content delivery, security and analytics vendors who process Technical Data and Usage Data only to the extent required to provide their contracted services.
• Regulatory and law-enforcement authorities: Where 9club is under a legal obligation to disclose Personal Data — for example, in response to a court order, regulatory notice or law-enforcement request — the minimum necessary data will be disclosed.
• Professional advisers: Lawyers, auditors and compliance consultants who are bound by confidentiality obligations and receive Personal Data only as strictly required for their engagements.

Where Personal Data is transferred to a third party, 9club requires that party to implement appropriate technical and organisational measures to protect the data and to process it only in accordance with 9club's documented instructions.

07 Cookies & Tracking Technologies

9club uses cookies and similar tracking technologies to operate and improve the Service. The categories of cookies used and their purposes are summarised below:

You can manage cookie preferences through your browser settings. Most modern browsers allow you to refuse non-essential cookies or to alert you when a cookie is being placed. Note that disabling certain cookies may affect the functionality of the 9club Service.

08 Data Retention

9club retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required to comply with applicable legal, regulatory or contractual obligations. General retention principles are as follows:

• Account data: Retained for the duration of your active 9club account and for a defined period following account closure, as required for fraud prevention, legal claims and AML obligations.
• Transaction records: Financial transaction data, including MYR deposit and withdrawal records, is retained for the period required by applicable financial record-keeping obligations.
• KYC and verification documents: Identity documents are retained for the period required by applicable anti-money-laundering regulations, which may extend beyond account closure.
• Support communications: Chat transcripts and correspondence are retained for a reasonable period to support ongoing dispute resolution and quality assurance.
• Technical and usage data: Aggregated analytics data may be retained in anonymised form indefinitely; individually identifiable technical logs are retained for a limited period consistent with security and fraud-prevention purposes.

When Personal Data is no longer required and no retention obligation applies, 9club will delete or anonymise it in a secure manner.

09 Security Measures

9club implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, destruction or disclosure. These measures include, but are not limited to, the following:

• Encryption of data in transit using current industry-standard protocols.
• Access controls that restrict Personal Data access to authorised personnel with a documented operational need.
• Regular review and testing of security infrastructure and data-handling procedures.
• Internal data-protection policies and confidentiality obligations applicable to all staff and contractors.
• Secure handling procedures for KYC documents submitted by Malaysian users for identity verification purposes.

10 User Rights

Subject to applicable law, you have the following rights in relation to the Personal Data that 9club holds about you:

• Right of access: You may request a copy of the Personal Data 9club holds about you, together with information about how that data is processed.
• Right to rectification: You may request that inaccurate or incomplete Personal Data be corrected without undue delay.
• Right to erasure: In certain circumstances, you may request that your Personal Data be deleted. This right is subject to any overriding retention obligation applicable to 9club under law.
• Right to restriction: You may request that processing of your Personal Data be restricted in certain circumstances, for example while an accuracy dispute is pending.
• Right to data portability: Where processing is based on consent or contract and is carried out by automated means, you may request a copy of your Personal Data in a structured, machine-readable format.
• Right to object: Where processing is based on legitimate interests, you may object to that processing. 9club will cease processing unless it can demonstrate compelling legitimate grounds that override your interests or the processing is necessary for legal claims.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact 9club support using the contact details set out in Section 14 of this Policy. We will respond to verifiable requests within a reasonable timeframe consistent with applicable law. We may need to verify your identity before processing a request.

11 Minors

The 9club Service is strictly intended for adults aged 21 years or older. 9club does not knowingly collect Personal Data from individuals under the age of 21. If you believe that a person under 21 has accessed the Service or submitted Personal Data without appropriate authorisation, please notify 9club support immediately. We will take prompt steps to investigate and, where confirmed, delete any data collected from an underage individual.

9club applies age verification controls during the registration and KYC process. Any account found to have been created by a person under 21 will be closed and all related balances may be forfeited in accordance with the 9club Terms and Conditions.

12 Third-Party Links

The 9club website may contain references to third-party payment service providers and banking institutions in Malaysia — including Maybank, CIMB, Public Bank, Hong Leong, Touch 'n Go eWallet, Boost and GrabPay — solely for informational purposes describing available payment channels. 9club does not operate or control those third-party services.

This Policy applies exclusively to the 9club Service. 9club is not responsible for the privacy practices of third-party websites, payment portals or services accessed through or in connection with the 9club Service. Users are encouraged to review the privacy policies of any third-party services they interact with.

13 Policy Amendments

9club reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, operational practices or the scope of the Service. Material changes will be communicated to registered account holders by email or by a prominent notice on the 9club platform prior to the effective date of the change, where reasonably practicable.

The "Last updated" date at the top of this Policy will be revised to reflect the date of the most recent amendment. Your continued use of the Service following the effective date of an amendment constitutes your acceptance of the revised Policy.

14 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data by 9club, please contact us using the following details:

For matters relating to responsible gambling, self-exclusion or account restrictions, please visit our Responsible Gambling page for guidance and available support resources.