09win Privacy Policy

1. Introduction

09win ("we", "us", "our") operates the online gaming platform accessible at 09win.co and is the data controller in respect of personal data collected from users of that platform. This Privacy Policy applies to all personal data collected by 09win in connection with your use of the 09win website, account services, games, promotional activities, and customer support interactions.

By registering an account with 09win or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any aspect of this Privacy Policy, you should cease using the 09win platform and contact us to close your account.

This Privacy Policy should be read together with the 09win Terms & Conditions and Responsible Gaming Policy. In the event of any conflict between this Privacy Policy and the Terms & Conditions in relation to personal data matters, this Privacy Policy shall prevail.

2. Data We Collect

09win collects personal data through several channels, including account registration, KYC verification, platform usage, payment processing, and customer support interactions. The categories of personal data we may collect include:

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, or health information unless specifically required by law or regulatory obligation. Where we collect financial data from third-party payment processors (such as Maybank or CIMB), we receive only the data necessary to confirm transaction completion and verify payment method ownership — we do not store full card numbers or banking credentials.

3. How We Use Your Data

09win processes personal data for the following purposes:

• Account administration: Creating and managing your 09win member account, processing login authentication, and maintaining account security;
• KYC and compliance: Verifying your identity, age (minimum 21 years), and residential address as required under 09win's international gaming authority obligations and applicable anti-money laundering regulations;
• Transaction processing: Processing MYR deposits and withdrawal requests, reconciling payment records, and investigating disputed transactions;
• Game and platform operation: Delivering game results, recording bet history, calculating balances, and resolving disputes using server-side logs;
• Responsible gaming: Monitoring usage patterns to identify potential problem gambling behaviour and, where appropriate, applying account restrictions or making welfare contacts;
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates by email, where you have provided consent or where we have a legitimate interest in doing so;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, and unauthorised account access;
• Legal and regulatory compliance: Fulfilling our obligations under applicable gaming authority licensing conditions, anti-money laundering laws, and data protection regulations;
• Platform improvement: Analysing aggregated, anonymised usage data to improve product features, game selection, and user experience.

We do not use your personal data for automated individual decision-making that produces legal or similarly significant effects on you without first providing an opportunity for human review and explanation, except where expressly permitted or required by law.

4. Legal Basis for Processing

09win processes personal data on the following legal bases, depending on the purpose for which the data is used:

• Performance of contract: Processing necessary to administer your 09win account, execute transactions, and deliver gaming services in accordance with the Terms & Conditions;
• Legal obligation: Processing required to comply with KYC obligations, anti-money laundering regulations, gaming authority licensing conditions, and any applicable court orders or regulatory directions;
• Legitimate interests: Processing for fraud prevention, network security, responsible gaming monitoring, and aggregate platform analytics, where these interests are not overridden by your fundamental rights;
• Consent: Processing for direct marketing communications, where you have expressly opted in. You may withdraw consent for marketing at any time by contacting support or using the unsubscribe mechanism in marketing emails.

5. Data Sharing & Disclosure

09win does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly for the purposes described in this Privacy Policy:

• Payment service providers: Banks (Maybank, CIMB, Public Bank) and e-wallet operators (Touch 'n Go, Boost) for the purpose of processing deposits and withdrawals;
• Identity verification and KYC providers: Third-party identity verification services used to authenticate the documents you submit during the KYC process;
• Game software providers: Licensed game developers and live dealer studio operators who supply the games available on the 09win platform, limited to the data required for game session operation;
• Fraud prevention and security providers: Specialist fraud detection services used to identify patterns of fraudulent or suspicious activity;
• Regulatory authorities: Gaming regulators, anti-money laundering authorities, tax authorities, law enforcement bodies, and courts, where disclosure is required by law or valid legal process;
• Professional advisers: Lawyers, auditors, and accountants, subject to confidentiality obligations.

All third-party service providers who access personal data on 09win's behalf are required to process such data only for the specified purpose, under contractual data processing agreements, and in compliance with applicable data protection laws.

6. Cookies & Tracking Technologies

09win uses cookies and similar tracking technologies on the 09win platform to deliver core platform functionality, maintain session security, and analyse aggregate usage patterns. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for login session management, security token validation, and platform functionality. These cannot be disabled without breaking core features of the platform.
• Functional cookies: Used to remember your language and display preferences across sessions.
• Analytics cookies: Used to collect aggregate, anonymised data on platform usage — page views, session duration, navigation paths — to help us improve the user experience. This data does not identify you personally.

09win does not use third-party advertising or tracking cookies for behavioural advertising or cross-site tracking. You may manage non-essential cookies through your browser settings. Disabling strictly necessary cookies will impair your ability to log in and use the platform.

7. Data Retention

09win retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to the following minimum retention requirements:

• Account and KYC data: retained for a minimum of five (5) years from the date of account closure, as required by applicable anti-money laundering regulations and gaming authority licensing conditions;
• Transaction records: retained for a minimum of five (5) years from the date of the transaction;
• Customer support communications: retained for two (2) years from the date of resolution of the relevant matter;
• Marketing data (where consent-based): retained until consent is withdrawn or for two (2) years of inactivity, whichever is earlier.

Following expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised. Anonymised, aggregated data derived from your account activity may be retained indefinitely for statistical and platform improvement purposes, as it no longer constitutes personal data.

8. Data Security

09win implements technical and organisational security measures proportionate to the risks associated with processing your personal data. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 09win servers;
• Encryption of sensitive personal data and financial data at rest;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Two-factor authentication requirements for staff accessing internal systems containing personal data;
• Regular security auditing and vulnerability assessment;
• Incident response procedures for the detection, containment, and notification of personal data breaches.

In the event of a personal data breach that poses a risk to your rights and freedoms, 09win will notify affected individuals and, where required, the relevant regulatory authority within the timeframes mandated by applicable law.

9. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data held by 09win:

• Right of access: The right to request a copy of the personal data 09win holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to 09win's legal retention obligations;
• Right to restriction: The right to request that processing of your personal data be restricted in certain circumstances;
• Right to data portability: The right to receive your personal data in a structured, machine-readable format where processing is based on consent or contract;
• Right to object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact 09win's Data Protection team at [email protected]. We will respond to all valid requests within thirty (30) days. In some cases, particularly for complex requests or where we need to verify your identity before proceeding, the response period may be extended by a further sixty (60) days, with prior notification to you.

Please note that some rights are subject to limitations — for example, we cannot erase data we are legally required to retain under anti-money laundering regulations, regardless of a deletion request.

10. Children's Privacy

The 09win platform is strictly for adults aged 21 years or older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that an account has been registered by a person under the minimum age, we will immediately close the account, delete or restrict the associated personal data to the extent permitted by law, and handle any funds in accordance with our regulatory obligations.

If you have reason to believe that a minor has registered an account with 09win, please contact us immediately at [email protected] so that we may investigate and take appropriate action.

11. International Data Transfers

09win's primary operations are conducted in relation to the Malaysian market. Some of the third-party service providers we use — including game software providers and identity verification services — may be located outside Malaysia. Where personal data is transferred to recipients in jurisdictions that do not provide an equivalent level of data protection, 09win implements appropriate safeguards, such as contractual data protection clauses, to ensure your data receives a standard of protection consistent with this Privacy Policy.

12. Amendments to This Privacy Policy

09win may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be notified to registered members by email to the address on file and/or by prominent notice on the 09win platform, with a minimum of fourteen (14) days' advance notice prior to the effective date.

The date of the most recent revision is indicated at the top of this document. Continued use of the 09win platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

13. Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 09win handles your personal data, please contact our Data Protection team:

• Email: [email protected]
• Live Chat: Available 24/7 via the 09win platform
• Response target: Acknowledgement within 1 business day; resolution within 30 days

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction.