PTK99 Privacy Policy

PTK99 ("PTK99", "we", "us", "our") operates the online gaming platform accessible atptk99.cam ("Platform", "Website", "Service"). We are committed to protecting the personal data and privacy of every individual who uses our Platform, including all registered players in Malaysia and elsewhere.

This Privacy Policy ("Policy") describes in detail how PTK99 collects, stores, processes, shares, and safeguards personal data in connection with the provision of our gaming services. It also sets out the rights available to you as a data subject and explains how you may exercise those rights.

This Policy applies to all personal data processed by PTK99 in connection with your use of ptk99.cam — whether you are a registered Account holder, a visitor to our website, or someone who contacts our support team. It should be read alongside our Terms & Conditions, which govern the overall contractual relationship between you and PTK99.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Account" means the individual member account created and maintained by a Player on the PTK99 Platform.
• "Data Controller" means PTK99, being the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third party engaged by PTK99 to process personal data on PTK99's behalf, under documented instructions.
• "Data Subject" means the identified or identifiable natural person to whom personal data relates — in this context, primarily our Players and website visitors.
• "KYC" means Know Your Customer — the regulatory identity verification process PTK99 applies to all Account holders.
• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, MyKad or passport number, payment details, IP address, and device identifiers.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transfer, deletion, and destruction.
• "Sensitive Data" means personal data that warants heightened protection due to its nature, including financial information, identity documents, and data relating to problem gambling self-assessments.

PTK99 collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect are set out in the table below:

PTK99 does not collect or process special categories of sensitive personal data (such as racial origin, religious beliefs, health data, or biometric data) except where required to fulfil specific regulatory obligations and with your explicit consent.

PTK99 collects personal data through the following primary channels:

• Direct submission by you: When you register an Account, complete KYC verification, make a deposit or withdrawal request, contact our support team (via live chat or email), or respond to a promotional communication, you provide personal data directly to PTK99.
• Automated technical collection: When you access the PTK99 Platform, our servers and systems automatically collect technical data including your IP address, device identifiers, browser information, and approximate location. This collection is necessary for the secure operation of the Platform.
• Cookies and similar technologies: PTK99 uses cookies and related tracking technologies to maintain session state, enhance Platform functionality, and analyse usage patterns. Please refer to Clause 9 (Cookies & Tracking) for full details.
• Third-party verification services: Where required for KYC purposes, PTK99 may receive identity or address verification data from regulated third-party identity verification providers. Any such provider is bound by appropriate data processing agreements.
• Payment processors: When you make deposits via Touch'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, or cryptocurrency networks, the relevant payment processor may share transaction confirmation data with PTK99. PTK99 does not receive or store full card numbers or full payment credentials.

PTK99 processes your personal data only for legitimate, clearly defined purposes. The principal purposes for which we process personal data are as follows:

1. Account creation and management: To create, maintain, and administer your PTK99 Account, including authenticating your identity on each login and managing your Account preferences.
2. KYC and regulatory compliance: To verify your identity and age (minimum 21 years), satisfy anti-money laundering (AML) and counter-terrorism financing (CTF) obligations imposed by our gaming licence, and maintain mandatory regulatory records.
3. Gaming service provision: To deliver the games, sports betting markets, live dealer products, and other gaming features available on the Platform and to record gaming activity for audit purposes.
4. Payment processing: To process deposits and withdrawals via your registered Malaysian payment methods (e-wallets, bank transfers, cryptocurrency) and to maintain accurate financial records.
5. Fraud and security monitoring: To detect, investigate, and prevent fraud, money laundering, cheating, account takeovers, and other activities that could harm you, other players, or PTK99.
6. Responsible gambling programme: To administer deposit limits, session controls, self-exclusion programmes, and other responsible gambling tools, and to monitor player behaviour for signs of gambling harm.
7. Customer support: To respond to your enquiries, process complaints, and provide technical assistance through our live chat and email support channels.
8. Legal and regulatory obligations: To comply with applicable laws, respond to lawful requests from regulatory authorities, law enforcement agencies, or courts of competent jurisdiction, and to maintain records required under our gaming licence.
9. Platform improvement: To analyse aggregate, anonymised usage data for the purpose of improving Platform performance, security, and user experience.

PTK99 processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our contractual obligations to you under the Terms & Conditions — including account management, payment processing, and game provision — is carried out on the basis that it is necessary for the performance of our contract with you.
• Legal obligation: Processing required to comply with PTK99's obligations under its gaming licence, AML regulations, KYC requirements, and applicable law is carried out on the basis of legal obligation.
• Legitimate interests: Processing for fraud prevention, Platform security, responsible gambling monitoring, and aggregated analytics is carried out on the basis of PTK99's legitimate interests, balanced against your privacy rights. We conduct proportionality assessments to ensure this balance is maintained.
• Consent: Where PTK99 sends you optional marketing communications or uses non-essential cookies, we do so on the basis of your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

PTK99 does not sell, rent, or trade your personal data to any third party. We share personal data only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose:

• Payment service providers: We share transaction-relevant data with payment processors facilitating your deposits and withdrawals (e.g., Touch 'n Go eWallet operator, Boost, GrabPay, DuitNow/FPX participating banks including Maybank, CIMB, Public Bank, Hong Leong Bank, and cryptocurrency network infrastructure). Each provider is bound by its own applicable data protection obligations.
• Identity verification providers: For KYC purposes, PTK99 engages regulated identity verification service providers who process identity document data on our behalf under appropriate data processing agreements.
• Gaming software suppliers: Game studios and live dealer platform operators that supply games to PTK99 may receive limited technical and gaming activity data necessary to operate their games within our Platform.
• Regulatory authorities: PTK99 is obligated to share certain data with its licensing regulator and, where required by law, with relevant financial intelligence units or law enforcement authorities. Such disclosures are made under legal compulsion and are limited to the minimum necessary.
• Professional advisors: PTK99 may share limited personal data with legal counsel, auditors, or compliance consultants where necessary for the provision of professional services, under obligations of confidentiality.
• Group companies: Where PTK99 forms part of a corporate group, personal data may be shared with affiliated entities within that group for internal administrative, compliance, and operational purposes, subject to equivalent data protection standards.

PTK99 retains personal data for as long as is necessary to fulfil the purposes described in this Policy and to comply with our regulatory obligations. The following general retention guidelines apply:

• Account and KYC data: Retained for the duration of your active Account relationship with PTK99 and for a period offive (5) years following Account closure, in compliance with anti-money laundering record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in line with regulatory requirements applicable to gaming operators.
• Gaming activity data: Retained for the duration of the Account relationship and for three (3) years following closure, to support dispute resolution and regulatory audit obligations.
• Customer support communications: Retained for two (2) years from the date of each interaction, or longer where a complaint or legal claim is pending.
• Technical data and access logs: Retained for a maximum of twelve (12) months, unless a longer period is required for ongoing security investigations.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where anonymisation is performed, the resulting data may be retained indefinitely for statistical and analytical purposes without privacy risk.

PTK99 uses cookies — small text files stored on your device — and similar tracking technologies to operate and improve the Platform. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for the Platform to function. These cookies maintain your login session, remember your language and currency preferences, and ensure secure access to your Account. They cannot be disabled without impairing core Platform functionality.
• Functional cookies: Enhance the user experience by remembering your preferences and personalisation settings between sessions (e.g., preferred game lobby view, notification preferences).
• Analytical cookies: Allow PTK99 to measure aggregate Platform usage patterns — including page visits, session durations, and feature interactions — to inform Platform improvements. Data collected via analytical cookies is aggregated and does not identify individual users.
• Security cookies: Assist PTK99 in detecting and preventing fraudulent activity, account takeover attempts, and other security threats by flaging anomalous session behaviour.

You may control cookie preferences through your browser settings. Blocking strictly necessary cookies will impair your ability to use the Platform. For other cookie categories, you may opt out without affecting core functionality, though some personalisation features may not work as intended.

PTK99 implements technical and organisational measures proportionate to the risks associated with the personal data we process. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the PTK99 Platform;
• Password hashing using industry-standard one-way algorithms — PTK99 employees cannot read your password in plain text;
• Access controls restricting Platform system access to authorised personnel on a need-to-know basis;
• Two-factor authentication (2FA) available to all Account holders, and mandatory for administrative access;
• Regular security audits and penetration testing conducted by qualified third-party security firms;
• Segregated data storage separating player personal data from operational systems;
• Incident response procedures enabling PTK99 to detect, investigate, and respond to personal data breaches in a timely manner.

In the event of a personal data breach that presents a material risk to your rights and freedoms, PTK99 will notify you and relevant regulatory authorities in accordance with applicable law and our licence obligations, without undue delay.

As a data subject whose personal data is processed by PTK99, you hold the following rights. These rights are subject to applicable legal limitations and PTK99's regulatory obligations, which may in some cases take precedence:

• Right of access: You may request a copy of the personal data PTK99 holds about you, along with information about how it is being processed. PTK99 will respond to verified access requests within thirty (30) days.
• Right to rectification: If you believe that personal data PTK99 holds about you is inaccurate or incomplete, you may request that it be corrected. Many data fields can be updated directly within your Account settings.
• Right to erasure ("right to be forgotten"): In certain circumstances, you may request that PTK99 delete your personal data. This right is subject to exceptions — in particular, we are legally required to retain certain data for regulatory compliance purposes even after Account closure.
• Right to restriction of processing: You may request that PTK99 restrict the processing of your personal data in specific circumstances, such as where you contest the accuracy of the data or have objected to processing.
• Right to data portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing carried out on the basis of legitimate interests. PTK99 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• 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 prior to withdrawal.

To exercise any of the above rights, please contact our support team. We will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days. Identity verification may be required before we can process your request.

As an internationally licensed operator, PTK99 may transfer personal data to countries outside Malaysia in connection with the services of payment processors, identity verification providers, game studios, and hosting infrastructure. Such international transfers are carried out on the following bases:

• Transfers to countries deemed to provide an adequate level of data protection;
• Transfers governed by appropriate contractual safeguards (such as standard data protection clauses) that contractually oblige the recipient to maintain equivalent standards of protection;
• Transfers that are necessary for the performance of our contract with you (e.g., processing a cryptocurrency withdrawal via a blockchain network).

Where personal data is transferred internationally, PTK99 takes steps to ensure that the receiving party maintains appropriate technical and organisational security measures equivalent to those applied within the PTK99 Platform.

The PTK99 Platform is strictly intended for individuals who are at least 21 years of age. PTK99 does not knowingly collect personal data from any under the age of 21.

Age verification is a mandatory component of the KYC process. Any Account found to be held by a person under 21 years of age will be immediately suspended and all associated data will be processed in accordance with our regulatory obligations before being deleted.

PTK99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our business operations, or data processing practices.

Material changes to this Policy will be communicated to registered Account holders via a notice displayed prominently on the Platform and, where practicable, by direct notification to your registered email address prior to the change taking effect.

The date of the most recent revision is displayed at the top of this Policy. We encourage you to review this Policy periodically. Your continued use of the Platform following publication of an updated Policy constitutes your acceptance of the revised terms.

If you wish to exercise any of your data subject rights, have a question about how PTK99 handles your personal data, or wish to raise a complaint regarding our data processing activities, please contact us through the following channels:

• Email: [email protected] — Please include "Privacy Request" or "Data Complaint" in the subject line. We aim to acknowledge all privacy-related queries within two (2) business days and provide a full response within thirty (30) days.
• Live Chat: Available24 hours a day, 7 days a week from your PTK99 Account dashboard. For immediate privacy concerns, live chat is the fastest channel to reach our team.
• Support Hours: 8:00 AM – 2:00 AM MYT. Our English-language support team serves players across Malaysia, including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam.

If you are not satisfied with PTK99's response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority in your jurisdiction, or to the dispute resolution body designated under our gaming licence framework.