Privacy Policy lembu99 – Personal Data Protection for Malaysian Members

Lembu99 is an online sports betting and casino platform operating for users in Malaysia. We understand that your personal data is a trust placed in our care, not merely technical information. This Privacy Policy applies to all information we collect through the lembu99 platform — including the website, mobile interface, email communications, and any interactions with our support team.

This policy explains clearly and in plain language: what data we collect, why we collect it, how we use it, who can access it, how long it is retained, and what your rights are as the data owner. We believe transparency is the foundation of trust, and member trust is lembu99's most valuable asset.

This policy takes effect from January 2026 and supersedes all previous versions. It should be read together with Terms & Conditions lembu99, which constitutes the entire agreement between you and the platform.

Lembu99 collects your personal data in two main categories — data you provide directly to us, and data collected automatically through your use of the platform.

Data you provide directly:

• Full name as shown on your Malaysian identity card (MyKad) or passport.
• An active Malaysian mobile number registered at the time of account creation.
• The email address used for platform communications and account verification.
• Date of birth — to verify that the minimum age requirement of 21 years is met.
• National identity card number (MyKad) or passport — for the KYC (Know Your Customer) process.
• Malaysian residential address — required for certain processing and AML compliance.
• Registered payment method details — Touch 'n Go account name, GrabPay, DuitNow, or FPX account number.

Automatically collected data:

• The IP address of your device when accessing the lembu99 platform.
• Device information — device type, operating system, browser type and version.
• Activity logs — pages visited, session duration, and actions taken within the platform.
• Aggregated usage data — betting patterns, game categories accessed, and frequency of use.
• Coarse-level location data based on IP address — used solely for access location verification.

Lembu99 collects your personal data through the following methods, all of which occur either with your knowledge or automatically as part of the platform's technical functionality:

• Account registration form — information you provide when first registering a lembu99 account.
• KYC (Know Your Customer) Process — identity verification documents you upload to complete the account verification process.
• Financial transactions — records of deposits and withdrawals processed through your chosen payment method.
• Customer support communications — enquiries, complaints, or communications you send to the lembu99 support team via live chat or email.
• Cookie and tracking technologies — data collected automatically as you browse the platform (further details in Section 8).
• Update account information — any changes you make yourself to your profile or account settings.

Lembu99 does not purchase data lists from any third party, does not use data obtained from public sources such as social media without your consent, and does not collect data beyond what is stated in this policy.

Lembu99 uses your personal data only for lawful purposes that are necessary for platform operations and regulatory compliance. Below are the specific purposes for which each type of data is used:

Lembu99 will not use your personal data for any purpose other than those stated above without first obtaining your renewed consent. If you have consented to receive marketing communications — such as the latest promotions, enhanced odds, or VIP offers — you may withdraw that consent at any time through your account settings or by contacting the lembu99 support team.

Lembu99 does not sell members' personal data to any party. However, to enable the platform to operate properly and comply with legal requirements, certain data may be shared with the following third parties within very limited boundaries:

• Malaysian payment processors — Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX (Maybank2u, CIMB Clicks) receive only the minimum transaction information required to process your deposits and withdrawals. This information is governed by each provider's own privacy policy.
• Cloud and infrastructure service providers — the lembu99 platform operates on infrastructure provided by accredited cloud providers. These providers comply with the highest security standards and are bound by strict data processing agreements.
• Analytics service providers — aggregated and anonymised usage data is shared to help us understand usage patterns and improve the platform experience. These providers do not receive any personally identifiable information.
• Regulatory authorities and law enforcement agencies — lembu99 is legally required to disclose certain data to the relevant authorities upon receiving a valid request made in accordance with proper legal procedures. We will notify you of any such disclosure where permitted by law.

Lembu99 continually invests in security infrastructure to ensure the personal data of all members remains protected at all times. The technical and organisational measures we implement include:

• Data encryption in transit — all communications between your device and lembu99's servers are secured by TLS 1.3 with 256-bit SSL encryption, ensuring data cannot be intercepted.
• Data encryption at rest — sensitive data such as passwords are stored using irreversible one-way hashing algorithms. Your password is never stored in plain text on any lembu99 system.
• Layered access controls — access to member data within lembu99's internal systems is restricted to staff who require it to perform their duties, with a full audit log maintained for every access.
• Two-factor authentication (2FA) — available for all member accounts and strongly recommended to be enabled, adding an extra layer of security to your account login.
• 24/7 security monitoring — an automated monitoring system operates around the clock to detect suspicious activity such as login attempts from new locations, unusual transaction patterns, or potential unauthorised access.
• Regular penetration testing — lembu99 conducts regular security audits and penetration testing to identify and address vulnerabilities before they can be exploited.

While lembu99 takes all reasonable steps to protect your data, you also play an important role in your own account security. Please ensure your password is unique and strong, never share it with anyone, and enable 2FA in your account settings.

Lembu99 retains your personal data for as long as it is needed for the purposes stated in this policy, or as required by legal and regulatory obligations. Below are general data retention guidelines:

• Active account data — retained for as long as your account remains active on the lembu99 platform.
• Financial transaction records — retained for a minimum of 7 years from the transaction date, in compliance with anti-money laundering (AML) legislation and financial audit requirements.
• KYC records and identity verification — retained for a minimum of 5 years following account closure.
• Customer support communication logs — retained for 2 years from the date of the interaction.
• Aggregate analytics data — retained for 2 years in a non-personally identifiable form.

Once the retention period expires, or when you request deletion of data eligible for removal, lembu99 will securely delete or anonymise the relevant data using methods that ensure it cannot be recovered. Please note that some data may not be immediately deletable if it is still required to fulfil legal obligations or to resolve ongoing disputes.

The lembu99 platform uses cookies and similar tracking technologies to enhance the user experience and help us understand how the platform is used. Below are the types of cookies we use:

• Essential cookies (mandatory) — required for core platform functions such as login session verification, bet slip management, and security. These cookies cannot be disabled without affecting platform functionality.
• Preference cookies — stores your preferences such as language selection and display settings to improve your browsing experience. Can be deleted through your browser settings.
• Analytics cookies — collects aggregated usage data to help us understand which parts of the platform are most frequently used and identify opportunities for improvement. This data does not identify you personally.
• Session cookies — deleted automatically when you close your browser. Used to maintain an active session while you are using the platform.

You can manage your cookie preferences through your web browser settings at any time. Please note that disabling certain cookies may affect the functionality of the lembu99 platform. For more information on managing cookies in popular browsers, refer to your respective browser's help section.

As a lembu99 member and owner of your personal data, you have the following rights, which you may exercise at any time by contacting our support team:

The lembu99 platform is a service intended exclusively for individuals aged 21 and above. lembu99 does not knowingly collect, process, or store personal data belonging to any individual under the age of 21.

If you are a parent or guardian who believes your minor child has registered an account with lembu99, please contact us immediately at support@lembu99.click. We will review and close the account in question and delete all related data as soon as possible following verification.

Lembu99 may update this Privacy Policy from time to time to reflect changes in our data practices, technology, or new legal requirements. When we make material changes to this policy, we will:

• Posting a clear notice within the lembu99 platform at least 14 days before the changes take effect.
• Sending notification emails to all registered members outlining the key changes made.
• Updating the "Last Updated" date at the top of this document to reflect the latest version.
• Maintaining an archive of previous privacy policy versions, which members may request for reference.

Your continued use of the lembu99 platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you disagree with any changes, you have the right to close your account before they take effect by contacting the lembu99 support team.

If you have any questions, concerns, or requests regarding this Privacy Policy or how lembu99 handles your personal data, our team is ready to assist through the following channels:

• In-platform live chat — available 24 hours a day, 7 days a week, including Malaysian public holidays. Average response time under 5 minutes.
• Email — send privacy-specific enquiries to support@lembu99.click. We aim to respond within 24 business hours.

For formal requests to exercise your personal data rights (access, correction, deletion, etc.), please clearly state the type of request and include sufficient information for us to verify your identity before processing. This is a necessary security measure to ensure your data is not disclosed to unauthorised parties.