Privacy Policy City99 – Your Personal Data Protection

1Introduction

City99 ("we", "Platform") takes our responsibility to protect the personal data of every member who uses our services seriously. This Privacy Policy clearly and transparently explains how we collect, use, store, protect, and in certain circumstances, share your personal information.

This document applies to all users who access the city99 platform through our official website at city99.bio or via the city99 mobile app. By registering or continuing to use our services, you confirm that you have read and agreed to the terms set out in this Privacy Policy.

This Privacy Policy should be read together with Terms and Conditions and Responsible Gaming Guidelines City99 as part of the overall agreement between you and our platform.

2Personal Data We Collect

City99 collects your personal data through several methods — directly from you during registration, through your use of the platform, and automatically via industry-standard tracking technologies. The following are the categories of data we collect:

We do not collect any categories of sensitive data such as health information, religious beliefs or political views unless specifically required by applicable law.

3How We Use Your Data

All data we collect is used for clear and legitimate purposes. The following outlines the primary purposes for which city99 uses your personal data:

• Account Management: Creates, verifies and maintains your city99 account, including the KYC process to ensure platform security.
• Transaction Processing: Processes your deposits, withdrawals and any financial transactions on the platform quickly and securely.
• Service Delivery: Enables you to access all games, promotions and city99 platform features that you are eligible to use.
• Security & Fraud Prevention: Detects and prevents any fraudulent activity, money laundering or platform abuse that may compromise your security and that of other members.
• Customer Support: Responds to enquiries, resolves complaints and provides the technical assistance you need.
• Platform Improvement: Analyses aggregated and anonymised usage patterns to improve user experience, platform performance and the range of games offered.
• Legal Compliance: Fulfils compliance and reporting obligations to the relevant authorities as required by Malaysian law.
• Marketing Communications: Sends promotional information, bonus offers and the latest city99 news — only to members who have consented to receive such communications.

4Data Sharing & Disclosure

City99 does not sell or transfer your personal data to third parties for their own commercial purposes. However, there are limited situations where we need to share your data with certain parties to enable us to deliver our services properly:

• Payment Service Provider: Required financial information is shared exclusively with our licensed payment processors and partner banks solely to facilitate your deposit and withdrawal transactions.
• Game Provider: Technical data and required betting history are shared with licensed game providers to ensure a smooth gaming experience and the resolution of any game disputes.
• Identity Verification Provider: Information required for the KYC process is shared with trusted third-party identity verification services that comply with strict security standards.
• Authorities & Regulatory Bodies: City99 will disclose personal data to the relevant authorities when required by law, court order, or for the purposes of crime prevention.
• Business Transfer: In the event of any merger, acquisition, or asset sale, member personal data may be transferred to the successor entity subject to appropriate notice being given to members.

In all of the above situations, City99 ensures that the party receiving the data is bound by confidentiality and data protection obligations equal to or stricter than the standards we adhere to.

5Data Security

City99 continuously invests in the latest security infrastructure to ensure your personal data is protected from unauthorised access, loss, misuse, or unlawful modification. The security measures we implement include:

• 256-bit SSL encryption for all data communications between your device and our servers
• Two-factor authentication (2FA) to protect access to your account
• Real-time cyber threat monitoring 24 hours a day, 7 days a week
• Enterprise-grade firewall and intrusion detection systems
• Strict internal access control procedures — only authorised staff may access member data
• Regular penetration testing conducted by independent security experts
• Regularly scheduled encrypted data backups to ensure service continuity

While city99 takes all reasonable precautions, no security system can be guaranteed 100% foolproof. We encourage members to play their part in protecting their accounts by using strong, unique passwords and never sharing their login credentials with anyone.

6Cookie Policy

City99 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website. The following are the types of cookies we use:

• Essential Cookies: Required for core platform operations including login session verification and account security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Helps us understand how members interact with the platform — which pages are visited most frequently, time spent, and any errors encountered — for improvement purposes.
• Functional Cookies: Saves your preferences such as language, display settings and saved login details to ensure a smoother experience each time you visit the platform.
• Analytics Cookies: Used to collect aggregated and anonymised usage data to help us understand usage trends and improve our services.

You can control and manage cookie settings through your browser preferences at any time. Please note that disabling certain cookies may affect the functionality and user experience of the City99 platform.

7Your Rights as a Data Subject

As a data subject under Malaysia's Personal Data Protection Act (PDPA), you have the following rights regarding your personal data held by city99:

• Access Rights: You have the right to request a copy of the personal data we hold about you at any time.
• Right to Rectification: If you find that any of your personal data is inaccurate or incomplete, you have the right to request an immediate correction.
• Right to Erasure: You may request the deletion of your personal data, subject to our data retention obligations under applicable law.
• Right to Restrict Processing: In certain circumstances, you may request that the processing of your data be restricted while your request is being investigated.
• Right to Object: You have the right to object to the processing of your data for direct marketing purposes at any time.
• Data Portability Rights: You may request to receive your personal data in a machine-readable format for transfer to another service provider.

8Data Retention

City99 retains your personal data for as long as necessary to fulfil the purposes stated in this Privacy Policy, or as required by applicable Malaysian law.

• Active Account Data: Retained for as long as your account remains active and for a reasonable period after account closure to resolve any outstanding disputes.
• Financial Transaction Records: Retained for a minimum of seven (7) years from the transaction date as required by Malaysian taxation and financial law.
• KYC Records: Retained for a minimum of five (5) years after the termination of the business relationship as required by anti-money laundering legislation.
• Communication Logs: Retained for two (2) years for quality control and complaints resolution purposes.

When data is no longer needed, City99 will ensure it is securely deleted or anonymised using approved procedures.

9International Data Transfers

In the course of its operations, City99 may need to transfer your personal data to servers or service providers located outside Malaysia. When such transfers occur, we ensure that a level of data protection equivalent to Malaysia's PDPA is upheld through the following measures:

• Binding data processing agreements (Data Processing Agreement) with all international partners
• Use of approved standard contractual clauses to protect transferred data
• Selection of partners located in countries with a recognised equivalent or higher level of data protection

City99 will not transfer your personal data to jurisdictions that do not provide adequate data protection without appropriate additional safeguards.

10Child Protection

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

If we discover that a child's personal data has been collected without our knowledge due to inaccurate information provided during registration, we will take immediate action to delete that data and close the relevant account.

11How to Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please contact the city99 team through the following channels:

• Live Chat: Available 24/7 via the live chat icon at the bottom-right corner of the city99 platform
• Support Email: [email protected] (response within 1–2 business days)
• FAQ Section: Visit FAQ page for answers to common questions about privacy and data security

For formal complaints relating to data protection, you also have the right to submit a complaint to Malaysia's Department of Personal Data Protection (JPDP) as the relevant regulatory authority.

12Changes to This Privacy Policy

City99 reserves the right to modify this Privacy Policy from time to time to reflect changes in our practices, the latest legal requirements, or improvements we make to the platform.

Any material changes to this Privacy Policy will be communicated to members via a prominent notice on the platform or by registered email at least 14 days before the changes take effect. This gives you sufficient time to review the updates and make an informed decision about your continued use of the city99 platform.

Your continued use of the city99 platform after any Privacy Policy changes take effect will be deemed as your acceptance of the updated terms. If you do not agree with the changes made, you have the right to close your account by contacting our support team.