Privacy Policy of 91win88

Introduction

This Privacy Policy (hereinafter "Policy") describes how 91win88 (hereinafter "we", "us", "our", "the Platform") collects, processes, uses, stores, and protects the personal information of individuals who access or use the 91win88 online casino and sports betting platform, accessible at https://91win88.cam and its associated subdomains.

This Policy applies to all registered players, visitors, and any other individual whose personal data we process in connection with the operation of the 91win88 platform. It should be read in conjunction with our Terms & Conditions and Responsible Gambling Policy.

By registering an account or continuing to use the 91win88 platform, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with this Policy, you must not use the Platform.

Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information that identifies or can reasonably identify a natural person, either directly or indirectly — including name, email address, contact number, IP address, payment details, and identity documents.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 91win88.
• "Data Processor" means any third party that processes Personal Data on behalf of 91win88, subject to a binding data processing agreement.
• "Player" / "User" means any registered or prospective account holder on the 91win88 platform.
• "Cookies" means small data files placed on your device by the Platform to enhance functionality, remember preferences, and support analytics.
• "KYC" means the Know Your Customer identity and age verification process required under our licensing obligations.
• "Sensitive Data" means Personal Data that warrants heightened protection, including government-issued identity document numbers, payment card details, and source-of-funds information.

Data Controller Information

91win88 acts as the Data Controller for all Personal Data collected through the Platform. As Data Controller, we are responsible for determining the purposes for which your data is processed and for ensuring that processing activities are carried out lawfully, fairly, and transparently.

We operate under international gaming licensing, which imposes specific data protection and anti-money laundering obligations on us as an operator. Compliance with these licensing conditions forms part of the legal basis for certain processing activities described in this Policy.

Personal Data We Collect

We collect Personal Data through several channels and for different operational purposes. The categories of data we collect are set out below.

4.1 Registration Data

When you create a 91win88 account, we collect:

• Full legal name and date of birth.
• Email address and mobile phone number.
• Preferred username and password (passwords are stored in hashed form only — we never store plaintext passwords).
• Country and city of residence (e.g., Kuala Lumpur, Penang, Johor Bahru).

4.2 Identity Verification (KYC) Data

To satisfy our licensing obligations, we may collect:

• Copies of government-issued identity documents (e.g., MyKad, passport).
• Proof of address documents (e.g., utility bills, bank statements).
• Source of funds documentation where required by our AML procedures.
• Facial verification data where required for enhanced KYC (processed solely for age and identity confirmation).

4.3 Financial Data

In connection with deposits and withdrawals, we collect:

• Payment method identifiers (e.g., last four digits of a bank card, Touch 'n Go account reference, DuitNow-linked bank account, Maybank/CIMB/Public Bank details).
• Transaction history including deposit amounts, withdrawal requests, and wagering activity.
• Cryptocurrency wallet addresses where crypto payment methods are used (BTC, ETH, USDT, LTC).

4.4 Technical & Usage Data

When you access the Platform, we automatically collect certain technical data:

• IP address and approximate geographic location.
• Device type, operating system, browser type and version.
• Session data including login timestamps, pages visited, and features used.
• Betting and gaming activity logs.

4.5 Communication Data

When you contact our support team via live chat or email, we retain records of those communications — including the content of messages — for quality assurance, dispute resolution, and compliance purposes.

How We Use Your Personal Data

The table below summarises the primary purposes for which 91win88 processes your Personal Data and the corresponding legal basis for each processing activity.

5.1 Marketing Communications

Where you have provided explicit consent, 91win88 may contact you with promotional offers, bonus notifications, and platform updates via email or SMS. You may withdraw your consent at any time by updating your communication preferences within your account settings or by contacting our support team. Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to the withdrawal.

Legal Basis for Processing

91win88 processes Personal Data on one or more of the following legal bases:

1. Contract Performance: Processing is necessary to perform the contract between you and 91win88 — i.e., to provide you with the Platform's betting and gaming services, process your transactions, and manage your account.
2. Legal Obligation: Processing is required to comply with our international licensing conditions, anti-money laundering regulations, age verification requirements, and other applicable laws.
3. Legitimate Interests: Processing is necessary for our legitimate interests — including fraud prevention, platform security, improving our services, and responsible gambling monitoring — provided those interests are not overridden by your fundamental rights and freedoms.
4. Consent: For specific processing activities such as marketing communications or optional analytics, we will seek your explicit prior consent. You may withdraw this consent at any time without detriment to your account.

Data Sharing & Third-Party Disclosure

91win88 does not sell, rent, or share your Personal Data with third parties for their own marketing purposes. We may share your data only in the following circumstances:

• Payment Service Providers: Your transaction data is shared with licensed payment processors — including those facilitating Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Visa/Mastercard, and cryptocurrency gateway providers — strictly to process your deposits and withdrawals.
• Identity Verification Providers: KYC documentation may be shared with contracted third-party identity verification services to fulfil our age and identity verification obligations.
• Game Content Providers: Technical session identifiers (non-personally identifying) are shared with licensed game studios to facilitate game delivery and RNG auditing.
• Regulatory & Law Enforcement Authorities: We are required to disclose data to our licensing authority, financial intelligence units, or law enforcement agencies where mandated by applicable law, licensing conditions, or a valid legal order.
• Fraud Prevention Services: Transaction and behavioural data may be shared with anti-fraud and AML monitoring service providers under strict data processing agreements.
• Professional Advisers: We may share data with legal, audit, or compliance advisers where necessary and on a confidential basis.

All third parties with whom we share Personal Data are required to process that data in accordance with applicable data protection standards and are prohibited from using it for any purpose beyond the specific service they provide to 91win88.

International Data Transfers

As an internationally licensed platform, 91win88 may transfer your Personal Data to data processors or service providers located outside of Malaysia. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that required by applicable data protection law.

Safeguards we apply to international transfers include: contractual clauses requiring data processors to apply equivalent protection standards, selection of processors certified under internationally recognised security frameworks, and ongoing due diligence on the data protection practices of our third-party service providers.

Cookies & Tracking Technologies

The 91win88 platform uses cookies and similar tracking technologies to provide core functionality, remember your preferences, maintain your login session, and gather aggregated analytics data.

9.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function correctly, including session management and login persistence. These cannot be disabled without impairing your use of the Platform.
• Functional Cookies: Remember your preferences such as language settings, preferred currency (MYR/RM), and display options.
• Analytics Cookies: Collect anonymised data about how users navigate the Platform to help us identify areas for improvement. These are set only with your consent where required.
• Security Cookies: Assist in detecting and preventing fraudulent or anomalous account activity.

9.2 Cookie Control

You can manage cookie preferences through your browser settings or the cookie consent tool on the Platform. Disabling non-essential cookies may affect some features of the Platform but will not prevent you from accessing core betting and gaming functionality.

Data Retention

91win88 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by our legal and licensing obligations. Key retention periods are as follows:

• Account Data: Retained for the duration of your active account plus a minimum of 5 years following account closure, in accordance with AML and licensing record-keeping requirements.
• KYC Documents: Retained for a minimum of 5 years following the end of the business relationship, in line with standard anti-money laundering regulations.
• Transaction Records: Retained for a minimum of 5 years for financial auditing and regulatory purposes.
• Communication Records: Support chat and email records retained for a minimum of 2 years for dispute resolution and quality assurance purposes.
• Technical Logs: IP address and session logs retained for up to 12 months for security and fraud prevention purposes.
• Marketing Data: Retained until you withdraw consent or request deletion, subject to the above minimum retention periods where applicable.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Anonymised, aggregated data may be retained indefinitely for statistical or analytical purposes.

Security Measures

91win88 implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. Our security practices include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• AES-256 encryption for Sensitive Data stored at rest on our infrastructure.
• Two-factor authentication (2FA) available for all player accounts.
• Role-based access controls limiting staff access to Personal Data on a strictly need-to-know basis.
• Regular independent security audits and penetration testing of our platform infrastructure.
• Real-time anomaly detection and intrusion prevention systems monitoring for unauthorised access attempts.
• Secure, access-controlled data centres for all primary data storage.
• Documented incident response procedures including player notification protocols in the event of a data breach.

Your Data Rights

Subject to applicable law and our legal retention obligations, you hold the following rights with respect to your Personal Data held by 91win88. To exercise any of these rights, please contact our support team at [email protected] with the subject line "Data Rights Request". We will respond within 30 days of receiving a valid request.

Minors & Age Restrictions

The 91win88 platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain Personal Data from individuals under the age of 21. All accounts are subject to mandatory age verification through our KYC process.

If we become aware that Personal Data has been collected from an individual under the age of 21, we will take immediate steps to delete that data, close the associated account, and return any deposited funds in accordance with applicable procedures.

If you believe a minor has registered on 91win88, please notify us immediately at [email protected] so we can take prompt action.

Amendments to This Policy

91win88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, platform functionality, or applicable law. Where changes are material, we will notify registered players via email or an on-platform notification prior to the changes taking effect.

The most current version of this Policy is always accessible at 91win88.cam/privacy-policy. The "Last Updated" date at the top of this page indicates when the Policy was last revised. Your continued use of the Platform following any amendment constitutes your acceptance of the revised Policy.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or 91win88's data practices, please contact our dedicated support team. We take all privacy enquiries seriously and aim to respond within 30 days of receipt.

For related legal documents, please also review our Terms & Conditions and Responsible Gambling Policy, each of which forms part of the overall framework governing your use of the 91win88 platform.