Privacy Policy

1 Introduction

This Privacy Policy (hereinafter "this Policy") is issued by momo99 (hereinafter "momo99", "we", "us", or "the Company"), the operator of the online gaming platform accessible at momo99.lat (the "Platform"). This Policy describes how momo99 collects, uses, stores, shares, and otherwise processes personal data relating to individuals who access or use our Platform and associated services (collectively, the "Services").

momo99 is committed to protecting the privacy and personal data of all users, including players registered from across Malaysia — Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and beyond. We operate to a standard of data protection commensurate with that expected by Malaysian users of reputable digital financial services platforms.

This Policy should be read in conjunction with our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference.

2 Definitions

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

• "Data Controller" means momo99, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" means any third party that processes personal data on behalf of momo99 under a binding data processing agreement.
• "Data Subject" means any identified or identifiable natural person whose personal data is processed — in the context of this Policy, primarily registered users of the Platform.
• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, financial data, device identifiers, and usage data.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transfer, and deletion.
• "Sensitive Data" means personal data requiring heightened protection, including financial records, identity documents, and data relating to responsible gambling status.
• "Third Party" means any entity other than momo99 or the Data Subject.

3 Data We Collect

momo99 collects personal data across several categories, described below. We collect only what is necessary and proportionate to the purpose for which it is collected.

3.1 Identity and Account Data

• Full legal name as it appears on official identification;
• Date of birth (for age verification — users must be 21 or above);
• Username and encrypted account password;
• Government-issued identification details (e.g., Malaysian MyKad number, passport number) submitted during KYC;
• Residential address and proof of address documentation.

3.2 Contact Data

• Email address;
• Malaysian mobile phone number;
• Preferred language for communications.

3.3 Financial and Transaction Data

• Payment method details (e.g., bank account numbers associated with Maybank, CIMB, Public Bank, Hong Leong, RHB; e-wallet identifiers for Touch 'n Go eWallet, Boost, GrabPay);
• Transaction history, including deposit amounts, withdrawal amounts, and dates;
• Cryptocurrency wallet addresses where applicable (USDT TRC20, BTC);
• Source of funds documentation where required for enhanced due diligence.

3.4 Usage and Behavioural Data

• Game history, betting patterns, and session durations;
• Platform navigation logs, pages visited, and features accessed;
• Device information including IP address, browser type, operating system, and device identifiers;
• Geolocation data at the country or city level (e.g., Kuala Lumpur, Penang).

3.5 Responsible Gambling Data

• Self-imposed deposit limits, loss limits, and session reminders;
• Self-exclusion status and duration;
• Communications with our responsible gambling support team.

3.6 Communications Data

• Content and metadata of communications with our customer support team via live chat or email;
• Marketing preferences and opt-in or opt-out records.

4 How We Collect Data

momo99 collects personal data through the following means:

• Direct provision by you — when you register an account, complete KYC, make a deposit or withdrawal, contact support, or participate in promotions;
• Automated collection — through cookies, session trackers, server logs, and analytics tools as you interact with the Platform;
• Third-party sources — from payment processors (e.g., DuitNow / FPX gateway providers), identity verification services, and fraud prevention partners where necessary to fulfil our obligations;
• Publicly available sources — where necessary for fraud investigation or legal compliance purposes.

5 Purposes of Data Processing

momo99 processes personal data for the following specific and legitimate purposes:

Purpose	Data Used
Account registration and management	Identity, contact, and authentication data
Age and identity verification (KYC)	Identity documents, date of birth, address
Payment processing and fraud prevention	Financial data, transaction history, device identifiers
Provision of gaming and betting services	Account data, usage and behavioural data
Customer support	Account data, communications data
Responsible gambling tools and monitoring	Responsible gambling data, usage data
Legal and regulatory compliance	All categories as required
Marketing communications (with consent)	Contact data, marketing preferences
Platform security and abuse prevention	Device data, IP address, behavioural patterns
Analytics and platform improvement	Aggregated and anonymised usage data

6 Legal Basis for Processing

momo99 processes personal data only where a valid legal basis exists. The following legal bases apply to our processing activities:

• Contractual necessity — processing required to perform the contract between you and momo99 (e.g., account registration, payment processing, provision of gaming services);
• Legal obligation — processing required to comply with applicable legal and regulatory requirements, including KYC and anti-money-laundering obligations;
• Legitimate interests — processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests;
• Consent — processing for marketing communications and non-essential cookies, where your explicit consent has been obtained and may be withdrawn at any time.

7 Third-Party Disclosure

momo99 does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your data with the following categories of third parties only to the extent necessary and permitted:

• Payment service providers — including operators of DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, RHB, Touch 'n Go eWallet, Boost, and GrabPay, solely for the purposes of processing your deposits and withdrawals;
• Identity verification providers — third-party KYC service providers who assist us in verifying your identity and age in accordance with our legal obligations;
• Technology and infrastructure providers — cloud hosting, data storage, and security service providers who process data on our behalf under binding data processing agreements;
• Fraud prevention and risk management services — to identify, prevent, and investigate fraudulent activity;
• Legal and regulatory authorities — where disclosure is required by applicable law, court order, or regulatory direction;
• Professional advisors — legal counsel, auditors, and compliance advisors under obligations of confidentiality.

8 Cookies & Tracking Technologies

momo99 uses cookies and similar technologies to operate and improve the Platform. A cookie is a small text file stored on your device. We use the following categories of cookies:

• Strictly necessary cookies — essential for the Platform to function. These include session management, login state, and security tokens. These cookies cannot be disabled without impairing platform functionality.
• Functional cookies — remember your preferences such as language, account settings, and device type to personalise your experience.
• Analytics cookies — collect aggregated, anonymised data on how users interact with the Platform (e.g., pages visited, time on site) to help us improve service quality. No individual user is identifiable from this data.
• Security cookies — detect unusual or suspicious login behaviour and protect against session hijacking and cross-site request forgery.

You may manage cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from using the Platform, but may affect certain personalisation features. momo99 does not use third-party advertising or behavioural tracking cookies.

9 Data Retention

momo99 retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data — retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with anti-money-laundering regulatory requirements;
• Transaction and financial data — retained for a minimum of seven (7) years from the date of the transaction, consistent with applicable financial record-keeping obligations;
• KYC documentation — retained for the period required by the applicable regulatory framework governing our operations, typically five (5) to seven (7) years;
• Customer support communications — retained for three (3) years from the date of the interaction;
• Marketing preference records — retained until you withdraw consent or request deletion, whichever is earlier;
• Analytics data — retained in aggregated, anonymised form indefinitely; individual session logs deleted after twelve (12) months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

10 Data Security

momo99 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. Key measures include:

• TLS 1.3 encryption for all data transmitted between your device and our servers;
• AES-256 encryption for personal data stored at rest;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication for all staff accessing production systems;
• Regular penetration testing and independent security audits;
• Intrusion detection and real-time anomaly monitoring systems;
• Formal incident response and data breach notification procedures.

Whilst momo99 employs industry-standard security measures, no digital system is entirely immune to risk. You are also responsible for maintaining the security of your account credentials. If you suspect that your account has been compromised, contact us immediately at [email protected].

11 Your Data Rights

As a Data Subject, you hold the following rights with respect to your personal data processed by momo99:

• Right of Access — you may request a copy of the personal data we hold about you, along with information about how it is processed;
• Right of Rectification — you may request correction of any inaccurate or incomplete personal data;
• Right of Erasure — you may request deletion of your personal data, subject to our legal obligations to retain certain records;
• Right to Restrict Processing — you may request that we limit the processing of your data in certain circumstances;
• Right to Data Portability — you may request that we provide your personal data in a structured, machine-readable format;
• Right to Object — you may object to processing based on legitimate interests or for direct marketing purposes;
• Right to Withdraw Consent — where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please submit a written request to [email protected]. We will respond within 30 calendar days of receipt of your request. We may require you to verify your identity before processing your request.

12 International Data Transfers

momo99 operates globally and may transfer personal data to countries outside of Malaysia for the purposes of platform hosting, payment processing, and service delivery. Where such transfers occur, momo99 ensures that appropriate safeguards are in place to protect your data, including:

• Data processing agreements containing standard contractual clauses providing equivalent data protection;
• Transfers to countries or entities that maintain an adequate level of data protection as recognised by applicable standards;
• Technical safeguards including encryption in transit and at rest.

By using the Platform and consenting to this Policy, you acknowledge that your personal data may be processed in countries outside Malaysia. In all cases, your data is subject to the protections described in this Policy regardless of where processing occurs.

13 Children's Privacy

momo99 does not knowingly collect personal data from any person under the age of 21 years. The Platform is strictly intended for adults aged 21 and above. We apply age verification checks during the registration process as part of our KYC procedures.

If momo99 becomes aware that personal data has been collected from a person below the age of 21 without appropriate parental consent or in violation of our eligibility requirements, we will take immediate steps to delete that data and close the associated account. If you believe an underage individual has registered on our Platform, please contact us at [email protected] immediately.

14 Amendments to this Policy

momo99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other operational factors. Material changes will be communicated to registered users via email and/or a prominent notice displayed on the Platform prior to the change taking effect.

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

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by momo99, please contact our Data Protection team using the details below. We aim to respond to all privacy-related enquiries within 30 calendar days.

For information on your rights regarding responsible gambling data and self-exclusion records, please also refer to our Responsible Gambling page. For the full terms governing your use of the Platform, please refer to our Terms & Conditions.