9kme Privacy Policy

1. Data Controller

9kme ("the Platform", "we", "us", or "our") is the data controller responsible for the personal data of players registered at 9kme.org. 9kme operates under an international gaming authority licence and processes personal data in accordance with applicable data protection legislation and the data-related obligations imposed by its Licensing Authority.

For all data-related enquiries, players may contact 9kme's Data Protection contact point at [email protected] with the subject line "Data Privacy Enquiry".

2. Personal Data We Collect

9kme collects the following categories of personal data from players and prospective players:

3. How We Collect Your Data

9kme collects personal data through the following channels:

• Direct submission: Data you provide when registering your 9kme account, completing KYC, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Data collected automatically when you access the Platform, including Technical Data and Usage Data gathered via cookies, server logs, and similar tracking technologies.
• Third-party sources: Identity verification and fraud screening data from KYC service providers; payment data from payment processors such as Touch 'n Go eWallet, DuitNow, FPX, and linked Malaysian banks; and risk intelligence data from our licensed fraud prevention partners.
• Publicly available sources: Sanctions lists, politically exposed persons (PEP) databases, and adverse media databases consulted as part of 9kme's AML obligations.

4. Legal Basis for Processing

9kme processes personal data on the following legal grounds:

• Contractual necessity: Processing required to provide the services you have contracted for when registering a 9kme account — including account management, payment processing, and dispute resolution.
• Legal obligation: Processing required to comply with applicable law and regulatory requirements, including AML legislation, KYC obligations under 9kme's gaming licence, and mandatory reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of 9kme's services — where 9kme's interests do not override your fundamental rights.
• Consent: Processing for marketing communications and non-essential analytics where you have provided explicit consent. You may withdraw consent at any time by contacting [email protected].

5. How We Use Your Data

9kme uses the personal data it collects for the following specific purposes:

• Creating and managing your 9kme player account and wallet.
• Verifying your identity and age as required by 9kme's licensing obligations and the 21+ player eligibility requirement.
• Processing deposits and withdrawals via Malaysian payment methods including Touch 'n Go eWallet, Boost, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect.
• Detecting and preventing fraud, money laundering, account takeovers, and other prohibited conduct.
• Monitoring gaming behaviour to identify indicators of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Responding to customer support enquiries, resolving disputes, and handling formal complaints.
• Sending transactional communications (deposit confirmations, withdrawal notifications, security alerts, KYC updates) to your registered email and mobile number.
• Sending promotional communications about 9kme bonuses, new games, and loyalty rewards — where you have opted in to marketing communications.
• Maintaining audit trails and records as required by 9kme's Licensing Authority for regulatory inspection purposes.
• Improving and developing the 9kme Platform based on aggregated and anonymised usage analytics.

6. Data Sharing & Disclosure

9kme may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

6.1 Service Providers

Third-party service providers engaged by 9kme to operate the Platform, including game content providers, payment processors, KYC verification vendors, fraud screening providers, cloud hosting infrastructure operators, and customer support platform providers. All service providers are contractually bound to process your data only on 9kme's instructions and in accordance with applicable data protection standards.

6.2 Regulatory & Law Enforcement Bodies

9kme's Licensing Authority and competent regulatory bodies are entitled to receive player data as part of routine compliance inspections or specific regulatory investigations. 9kme may also disclose personal data to law enforcement agencies, financial intelligence units, or courts when legally compelled to do so under applicable law, including AML reporting obligations.

6.3 Fraud Prevention Networks

9kme participates in industry fraud prevention networks that allow licensed operators to share anonymised risk signals about fraudulent or abusive account activity. Individual personal data is not shared through these networks — only pseudonymised risk indicators are exchanged.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of 9kme's business, player data may be transferred to the acquiring entity as part of the transaction. Players will be notified of any such transfer and given the opportunity to close their accounts before the transfer is completed, where this is reasonably practicable.

7. Cookies & Tracking Technologies

9kme uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies: Required for the Platform to function — including maintaining your login session, storing your wallet currency preference, and enabling security features. These cannot be disabled without breaking Platform functionality.
• Performance cookies: Collect anonymised data about how players use the Platform — which games are loaded most frequently, where navigation errors occur, and how page load times vary across devices. This data is used solely to improve the Platform.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool settings across sessions.
• Analytics cookies: Used with consent to understand aggregate traffic patterns and player journeys on 9kme. Analytics data is anonymised before analysis and is not linked to individual accounts.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the 9kme Platform.

8. Data Retention

9kme retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by 9kme's licensing obligations:

• Account and identity data: Retained for a minimum of five (5) years from the date of account closure or the date of the last transaction, whichever is later. This period reflects AML regulatory requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming and betting history: Retained for a minimum of three (3) years from the date of each session or bet record.
• Customer support communications: Retained for two (2) years from the date of the last correspondence, unless the communication relates to an open dispute or regulatory matter.
• Technical and usage data: Retained for thirteen (13) months from the date of collection.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with 9kme's data destruction procedures.

9. Data Security

9kme implements the following technical and organisational security measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 9kme's servers.
• Passwords are stored using industry-standard one-way hashing with unique salts — 9kme staff cannot view your password in plaintext.
• Player funds are held in segregated bank accounts physically and legally separate from 9kme's operational accounts.
• Access to player data systems is restricted to authorised 9kme personnel on a strict need-to-know basis, with access logs maintained for audit purposes.
• Regular penetration testing and vulnerability assessments conducted by independent third-party security firms.
• Two-Factor Authentication available for all player accounts to prevent unauthorised account access.

Despite these measures, no data transmission over the internet is completely secure. 9kme encourages all players to use strong, unique passwords and to enable 2FA on their 9kme account. In the event of a data breach that poses a risk to player rights, 9kme will notify affected players and relevant authorities within the timeframes required by applicable law.

10. Your Rights

Subject to applicable law and the requirements of 9kme's licensing obligations, registered players have the following rights in respect of their personal data held by 9kme:

• Right of Access: You may request a copy of the personal data 9kme holds about you. Requests will be fulfilled within 30 days.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Minor updates (email address, mobile number) may be made directly in your 9kme account settings.
• Right to Erasure: You may request deletion of your personal data where processing is no longer necessary, subject to 9kme's legal retention obligations. Note that data subject to minimum retention periods under AML regulations cannot be deleted until those periods expire.
• Right to Restriction: You may request that 9kme restrict processing of your data in certain circumstances — for example, while a dispute is being investigated.
• Right to Data Portability: You may request your personal data in a structured, machine-readable format for transfer to another service provider, where technically feasible.
• Right to Object: You may object to processing based on legitimate interests or for marketing purposes. Marketing opt-outs take effect within 5 business days.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, contact 9kme at [email protected] with the subject line "Data Rights Request – [Your Account Username]". 9kme may need to verify your identity before processing your request.

11. Children's Privacy

9kme's Platform is strictly intended for individuals aged 21 and above. 9kme does not knowingly collect personal data from persons under the age of 21. KYC verification using MyKad is required before a player's first withdrawal, and 9kme's registration process is designed to prevent underage access. If 9kme becomes aware that personal data has been collected from a person under 21, the associated account will be closed immediately and all data will be deleted without delay, subject only to any retention obligations that arise from the prior collection.

12. International Data Transfers

9kme's Platform infrastructure and some of its third-party service providers operate outside of Malaysia. Where personal data is transferred to countries that may not offer the same level of data protection as Malaysia, 9kme ensures that appropriate safeguards are in place — including contractual data processing agreements incorporating standard data protection clauses, and selection of service providers certified under internationally recognised security frameworks.

By using the 9kme Platform, you acknowledge that your personal data may be transferred to and processed in countries outside Malaysia for the purposes described in this Policy.

13. Updates to This Policy

9kme reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or 9kme's data processing practices. When material changes are made, 9kme will notify registered players via email to the address on file and will post a prominent notice on the Platform at least 14 days before the changes take effect. The "Last updated" date at the top of this Policy will be revised accordingly. Continued use of the 9kme Platform after the effective date of any change constitutes acceptance of the revised Policy.

14. Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or 9kme's data processing practices, please contact:

• Email: [email protected] (subject: "Data Privacy Enquiry")
• Live Chat: 24/7 within the 9kme Platform after login

If you are not satisfied with 9kme's response to a data privacy complaint, you may escalate the matter to the data protection supervisory authority in your jurisdiction or to 9kme's Licensing Authority as applicable.