Privacy Policy City99 —
We Take Your Data Seriously

This Privacy Policy is issued by City99 and applies to all users who access or use the platform on the website city99.vin, including registered members, casual visitors, and anyone who interacts with our services.

We understand that privacy is something deeply valued by Malaysian users. That is why city99 is committed to ensuring that every piece of information you share with us is handled with the utmost respect, transparency and responsibility.

This policy details: what data we collect, why we need it, how it is used, who can access it, how long it is retained, and what your rights are as the data owner. We encourage you to read this policy in full and carefully.

City99 only collects data that is genuinely necessary to provide a safe, seamless, and responsible service to all members. We do not collect data excessively or beyond the scope stated here.

Information you provide directly:

• Full name as stated in your official identification document.
• An active mobile number registered in your name.
• A valid email address for communication and account verification purposes.
• Bank account or digital wallet details for processing deposits and withdrawals.
• Date of birth for age verification (city99 only accepts members aged 18 and above).
• Copies of identity documents (MyKad or passport) collected during the KYC process.

Information collected automatically:

• IP address and general location information of your device.
• Web browser type and operating system used.
• Login session data including date, time, and session duration.
• Gaming activity records and transaction history within the platform.
• Cookies and session data to enhance the user experience.

Every piece of data we collect has a clear and lawful purpose. city99 will not use your data for purposes other than those stated below without obtaining your consent first.

• Account Management: Creating, verifying and securely maintaining your member account.
• Transaction Processing: Processing deposits, withdrawals and all financial transactions within the platform.
• Identity Verification (KYC): Ensuring every member is a real individual who meets the platform's age and eligibility requirements.
• Fraud Prevention: Detecting and preventing fraudulent activity, money laundering and platform abuse.
• Customer Support: Providing technical support and accurately resolving member complaints or enquiries.
• Platform Communications: Sending important notifications related to your account, transactions and security updates.
• Marketing (with consent): Delivering promotional information, bonuses and exclusive offers where you have opted in to receive such communications.
• Legal Compliance: Fulfilling legal obligations and reporting requirements to the relevant regulatory authorities.
• Analytics & Improvement: Analysing usage patterns on an aggregated basis to improve platform quality and performance.

City99 takes your privacy very seriously and will not share your personal data indiscriminately. However, there are limited situations where data sharing is necessary to ensure the platform operates properly and complies with applicable laws.

Third parties that may receive your data:

• Payment Providers: Financial institutions and digital wallet providers such as DuitNow, Touch 'n Go eWallet, GrabPay, FPX and Boost to process your transactions.
• Game Providers: Game software providers that require minimal session information to deliver a seamless gaming experience.
• KYC Verification Services: Third-party identity verification service providers that help us securely verify member identities.
• Regulatory Bodies & Authorities: Where required by law, court order, or valid request from a law enforcement agency.
• Technical Infrastructure Providers: Cloud and technical service providers that help us operate the platform, subject to strict confidentiality agreements.

All third parties handling city99 member data are required to comply with our data protection policy and are not permitted to use that data for any purpose other than what is specified in their agreement with us.

The security of your personal data is city99's highest priority. We continuously invest in the latest security infrastructure to ensure your data is always protected against any cyber threats.

Security measures we implement:

• 256-bit SSL encryption for all communications between your browser and city99 servers.
• Encryption of sensitive data in databases using industry-standard encryption algorithms.
• Multi-layered firewall and active 24-hour intrusion detection and prevention systems (IDS/IPS).
• Two-factor authentication (2FA) is available for all member accounts for added protection.
• Regular security audits conducted by independent cybersecurity teams.
• Role-based access control — only authorised staff may access specific data.
• Real-time monitoring of suspicious activity with an automated alert system.
• Regular data backups stored at secure, separate server locations.

City99 uses cookies and similar tracking technologies to enhance user experience, analyze platform performance, and deliver more relevant content to you.

Types of cookies we use:

• Essential Session Cookies: Required for core platform functions such as login verification and session management. Cannot be disabled.
• Preference Cookies: Storing your personal settings such as language, theme and display preferences to make the platform easier to use.
• Analytical Cookies: Helping us understand how users interact with the platform for continuous improvement purposes.
• Security Cookies: Used to detect suspicious activity and protect your account from unauthorized access.

You can manage cookie settings through your web browser preferences. However, disabling essential cookies may affect certain platform functions. City99 does not use third-party cookies for advertising purposes.

City99 only retains your personal data for as long as it is needed for the purposes stated in this policy or as required by applicable laws and regulations.

• Active Account Data: Retained for as long as your account remains active and you continue using the City99 platform.
• Financial Transaction Data: Retained for a minimum of 7 years after a transaction occurs to fulfil financial and tax legal requirements.
• KYC Records: Retained for a minimum of 5 years after account closure to comply with AML/KYC legal requirements.
• Access & Activity Logs: Retained for 12 months for security and investigation purposes if required.
• Communication Data: Customer support communication records are retained for 2 years.

Once the retention period expires, data will be securely deleted or anonymised in accordance with established procedures.

As a city99 member, you have certain rights regarding your personal data. city99 is committed to respecting and facilitating the exercise of these rights within a reasonable timeframe.

To exercise any of the above rights, please contact the city99 customer support team via live chat or email. We will process your request within 14 working days.

The city99 platform is exclusively for adults aged 18 and above. We do not knowingly collect or process personal data from individuals under the age of 18.

If we discover that personal data of a child has been collected inadvertently, we will take immediate steps to delete that data and close the associated account. Parents or guardians who become aware that their child has registered an account on our platform are encouraged to contact us immediately.

City99 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our business practices, new legal requirements, or improvements in how we protect your data.

• Members will be notified of any material changes via email or in-platform notification at least 7 days before it takes effect.
• The latest version of the Privacy Policy will always be available on this page with the most recent update date clearly displayed.
• Your continued use of the city99 platform after changes take effect constitutes your acceptance of the updated version.
• If you disagree with any changes, you have the right to close your account and we will process that request promptly.

If you have any questions, concerns, or complaints regarding how city99 handles your personal data, we encourage you to contact us through the following channels:

• Live Chat: The fastest option — available directly within the City99 platform, with responses in under 2 minutes.
• Privacy Email: [email protected] — please include the subject "Privacy Inquiry" along with your account number.
• Response Time: Privacy-related inquiries are processed within 5 business days; urgent cases will be prioritised.

We take every privacy-related complaint seriously and will investigate and provide a comprehensive response within the stipulated timeframe. If you are not satisfied with our response, you have the right to refer the matter to the relevant regulatory authority.