FCM99 Privacy Policy – Our Commitment to Protecting the Personal Data of Malaysian Players

FCM99 ("we", "platform", "fcm99") is an online betting platform operating exclusively for the Malaysian market. In delivering our services — from member account management and deposit processing via local methods such as Touch 'n Go eWallet and DuitNow, to slots and live casino games, Malaysia Super League football and e-sports betting, and our VIP Rewards programme — we need to collect and process certain personal data from our members.

This Privacy Policy is designed to explain clearly and transparently to every fcm99 member: what types of personal data we collect, why we need it, how we use it, who (if anyone) we share it with, how long we retain it, and what rights you have in relation to that data.

FCM99 operates in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA). We have appointed an internal Data Privacy Officer responsible for ensuring that all our data management practices meet applicable legal requirements and industry best standards.

FCM99 only collects data necessary for legitimate purposes in the operation of the platform. The following are the categories of data we collect:

Data You Provide Directly:

• Identity Information: Full name as per Malaysian identity card, date of birth, identity card number (when required for KYC verification).
• Contact Information: Malaysian mobile number, email address, and residential address (where required for verification purposes).
• Financial Information: Malaysian bank account numbers or e-wallet details (TNG eWallet, GrabPay, DuitNow, Boost, ShopeePay) used for deposits and withdrawals. We do not store credit or debit card information directly.
• Verification Documents: A copy of your Malaysian identity card, a selfie with your identity card, and any other documents required as part of the KYC process.

Automatically Collected Data:

• Platform Usage Data: Betting activity, transaction records, games played, session duration, and general platform usage behaviour.
• Technical Data: IP address, device type, operating system, browser type, screen resolution, and language settings.
• Cookie Data: Information collected through cookies and similar tracking technologies as described in Section 6.
• Communication Data: Records of live chat conversations, emails, and customer support communications, retained for training, service improvement, and complaints documentation purposes.

We use your personal data solely for legitimate purposes directly related to the provision of fcm99 platform services. The following outlines the primary purposes for which your data is used:

• Account Management: Creating and maintaining your fcm99 account, verifying your identity, and enabling access to all platform features including slots, Live Casino, football betting, and e-sports.
• Financial Transaction Processing: Processing deposits via Touch 'n Go eWallet, DuitNow, GrabPay, Boost, ShopeePay, and FPX, as well as handling withdrawal requests to your Malaysian bank account or e-wallet securely and efficiently.
• Identity Verification (KYC): Complying with legal requirements and anti-money laundering (AML) regulations by verifying a member's identity before processing their first withdrawal.
• Platform Security: To detect and prevent fraudulent activity, unauthorised access, duplicate account creation, and any misuse of the fcm99 platform.
• Customer Support: Enables the fcm99 customer support team to understand the context of your issue and provide accurate, effective assistance in Bahasa Melayu.
• Service Communications: Sending important account-related notifications such as transaction confirmations, security alerts, policy updates, and relevant promotional information (with your consent).
• Platform Improvement: Analyzes aggregated (non-individual) usage data to understand platform usage patterns and continuously improve the overall fcm99 user experience.
• Legal Compliance: To fulfil the reporting and record-keeping obligations prescribed by applicable Malaysian law.

FCM99 does not use your personal data for automated decision-making that materially affects your rights without human involvement, unless explicitly stated and with your consent.

FCM99 does not sell, rent, or transfer your personal data to third parties for their marketing purposes. However, there are limited situations where we need to share data with certain parties in order to provide our services to you:

• Payment Service Providers: Transaction data that must be shared with e-wallet providers (TNG, GrabPay, DuitNow, and others) and Malaysian financial institutions to process your deposits and withdrawals. These providers are governed by their own privacy policies and security standards.
• Game Providers: Technical details of gaming sessions may be shared with game software providers (such as slots and Live Casino providers) that partner with fcm99, solely for the purpose of delivering those games to you.
• Technology Service Providers: Companies that provide technical infrastructure, cloud computing services, security analytics, and technical support services that enable the fcm99 platform to operate. All such providers are bound by strict data processing agreements.
• Relevant Authorities: FCM99 will disclose personal data where required by Malaysian law, court order, or a lawful request from a law enforcement agency. We will notify you of any such disclosure where we are permitted to do so by law.

FCM99 implements multiple layers of technical and organisational security measures to protect your personal data against unauthorised access, use, disclosure, alteration, or destruction:

• Data Encryption in Transit: All communication between your device and fcm99's servers is secured with TLS/SSL protocol using 256-bit encryption — the same industry standard used by Malaysian online banking.
• Encryption of Stored Data: Sensitive data stored in our databases, including passwords and financial information, is encrypted using robust hashing and encryption algorithms.
• Internal Access Controls: Access to members' personal data is restricted to fcm99 personnel with a legitimate business need, enforced through strict role-based access controls (RBAC).
• 24/7 Security Monitoring: Automated monitoring systems operate around the clock to detect suspicious activity, intrusion attempts, or anomalies in data access patterns.
• Regular Security Audits: FCM99 conducts regular security assessments and penetration testing to identify and address potential vulnerabilities before they can be exploited.
• Staff Training: All fcm99 staff who handle personal data undergo regular data protection training and cybersecurity awareness programmes.

While we take all reasonable precautions, no digital security system can be guaranteed 100% secure. We encourage you to take protective measures on your end as well — such as using a strong, unique password for your fcm99 account, enabling two-factor authentication where available, and never sharing your login details with anyone.

The fcm99 platform uses cookies and similar technologies to enhance your experience, ensure the platform functions correctly, and understand how the platform is used in general. Cookies are small text files stored on your device when you visit our website.

Types of Cookies We Use:

• Essential Cookies: Required for the core functions of the fcm99 platform, such as maintaining your login session, saving language preferences, and ensuring security features operate correctly. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collecting information on how you use the platform — pages visited, time spent, and any errors encountered — to help us improve fcm99's performance and user experience.
• Functional Cookies: Saves your personal preferences — such as display settings, game choices, or language — to provide a more personalised experience on your next visit.
• Analytics Cookies: Helping us understand aggregated, anonymised platform usage patterns to make better data-driven decisions on platform improvements.

You can manage or disable cookies through your browser settings. However, disabling certain cookies may affect the functionality or your overall experience on the fcm99 platform. For guidance on managing cookies in your browser, please refer to your browser's help documentation.

Under Malaysia's Personal Data Protection Act 2010 and sound data protection principles, you as an fcm99 member have the following rights regarding your personal data:

• Right of Access: You have the right to request and receive a copy of the personal data fcm99 holds about you. We will provide this information in a readable format within 30 days of receiving a valid request.
• Right to Rectification: If you find that the personal data fcm99 holds about you is inaccurate, incomplete, or out of date, you have the right to request a correction. We encourage you to update your account information directly through your account settings where available.
• Right to Erasure: Under certain circumstances — for example, if the data is no longer needed for its original purpose or you withdraw your consent — you may request that fcm99 delete your personal data. Please note that deletion requests may not be fully fulfilled if we have a legal obligation to retain the data.
• Right to Restriction of Processing: You may request that we restrict the processing of your personal data in certain situations, such as while we are investigating your objection to the accuracy of your data.
• Right to Data Portability: You have the right to receive your personal data in a structured, machine-readable format to facilitate transfer to another service provider where applicable.
• Right to Object: You may object to the processing of your personal data for specific purposes, such as direct marketing communications.

To exercise any of the rights above, contact our Data Privacy Officer by email at support@fcm99.click with the subject line "Privacy Rights Request", along with your account number and request details. We will verify your identity before processing your request and will respond within 30 days.

In the course of operating the fcm99 platform, your personal data may be processed or stored on servers located outside Malaysia — for example, by cloud service providers or international game providers we work with.

In such situations, fcm99 ensures that any cross-border data transfer is carried out in compliance with the requirements of Malaysia's Personal Data Protection Act 2010, namely:

• Data transfers are only carried out to countries or regions that provide an adequate or equivalent level of data protection as required under Malaysian standards.
• Legally binding Data Processing Agreements are signed with all third-party providers that receive fcm99 members' personal data.
• Appropriate technical and organisational measures are in place to ensure your data remains protected during transfer and while in the possession of those providers.

You may contact us for more information about the measures taken to protect your data in the context of international transfers.

FCM99 does not retain your personal data for longer than is necessary for the purposes for which it was collected, or beyond what is required under applicable Malaysian law. The following are data retention guidelines by category:

• Active Account Data: For the duration of your active fcm99 account, plus the period prescribed by law following account closure.
• Financial Transaction Records: Minimum 7 years from the date of transaction, in line with Malaysia's accounting and anti-money laundering legal requirements.
• KYC Verification Documents: Throughout the active business relationship and for at least 5 years after account closure, in accordance with compliance requirements.
• Customer Support Communication Records: 3 years from the date of interaction for dispute resolution and service improvement purposes.
• Technical Data & Logs: 12 months for standard access logs and up to 3 years for security logs related to investigated incidents.

When your personal data is no longer required for any legitimate purpose, we will securely delete it using methods that prevent recovery, or anonymise it completely so that it can no longer be linked back to you as an individual.

Fcm99 services are strictly for individuals aged 18 and above. FCM99 does not knowingly collect, store, or process the personal data of anyone under the age of 18.

Should we find that we have inadvertently collected personal data from an individual under the age of 18, we will take immediate steps to:

• Promptly closing the associated account.
• Deleting all personal data associated with that individual from our systems.
• Notifying the relevant authorities where required by law.

If you are a parent or guardian and have reason to believe that a child under your care has registered for or used the fcm99 platform, please contact us immediately at support@fcm99.click so that we can take the appropriate action without delay.

FCM99 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or improvements to the way we protect your data. The "Updated" date shown at the top of this page indicates when this Privacy Policy was last revised.

For material changes — that is, changes that significantly alter how we collect, use, or protect your data — we will notify you through:

• An email to the address registered to your fcm99 account, at least 14 days before the changes take effect.
• In-platform notifications from fcm99 when you log in.
• Updates to this Privacy Policy page with clear change notices.

If you do not agree with any material changes to this Privacy Policy, you have the right to close your account before those changes take effect by contacting our support team. Continued use of the fcm99 platform after the changes take effect will be considered acceptance of the updated policy.

If you have any questions, concerns, or complaints about how fcm99 handles your personal data, or if you wish to exercise any of your privacy rights as outlined in Section 7, you may contact our Data Privacy Officer through the following channels:

• Privacy Email: support@fcm99.click — please use the subject line "Data Privacy Enquiry" or "Privacy Rights Request" to help us address your query more quickly and accurately.
• Live Chat: Available 24 hours a day within the fcm99 platform for general privacy enquiries. For formal privacy rights requests, email is the preferred channel to ensure proper record-keeping.
• Telegram: fcm99's official Telegram channel for initial communication and general enquiries.

We are committed to responding to all privacy-related enquiries within 5 business days and to resolving valid privacy rights requests within 30 calendar days from the date a complete request is received. If you are not satisfied with how we have handled your privacy complaint, you have the right to refer the matter to the Department of Personal Data Protection Malaysia or the relevant regulatory authority.