Privacy Policy

This Privacy Policy ("Policy") is issued by 91win ("Company", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at https://91win.cam. This Policy applies to all personal data collected from registered members, visitors, and prospective users of the 91win Platform ("Platform"), including Malaysian players who access our services via desktop or mobile devices.

We are committed to processing personal data in a manner that is transparent, fair, and consistent with internationally recognised data protection principles. This Policy has been prepared to explain clearly: what personal data we collect; the purposes for which we process it; how long we retain it; who we may share it with; and what rights you have as the individual to whom that data relates.

By registering for an account, making a deposit, or otherwise using the 91win Platform, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read in conjunction with our Terms & Conditions and Responsible Gambling Policy.

The following terms are used throughout this Privacy Policy:

• "Personal Data" — Any information that identifies or could reasonably identify a natural person, directly or indirectly (e.g., name, IC number, email address, IP address, device identifiers).
• "Data Subject" — The individual to whom Personal Data relates; in most cases, a registered Member of the 91win Platform.
• "Processing" — Any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" — 91win, as the entity that determines the purposes and means of Processing Personal Data collected through the Platform.
• "Data Processor" — A third party that processes Personal Data on behalf of 91win in accordance with our documented instructions (e.g., payment service providers, KYC verification vendors).
• "KYC" — Know Your Customer; the identity verification process required to activate full account functionality.
• "Cookies" — Small text files stored on your device by a web browser that record session and preference data.
• "MYR" / "RM" — Malaysian Ringgit, the functional currency of the 91win Platform for Malaysian Members.

91win collects only the personal data that is necessary for the stated purposes outlined in Section 5. The categories of personal data we collect are as follows:

91win collects personal data through the following methods:

• Direct Submission: Information you provide during account registration, KYC verification, deposit and withdrawal forms, customer support interactions, and communications with our team.
• Automated Technologies: Technical and usage data collected automatically when you interact with the Platform, through cookies, web beacons, server logs, and analytics tools.
• Third-Party Sources: Identity and fraud-screening data received from our licensed KYC verification partners; transaction data received from Malaysian payment processors (including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, RHB, and Hong Leong Bank); and adverse media or sanctions-screening results from compliance data vendors.
• Publicly Available Sources: Where permitted by applicable law, 91win may supplement your records with information from publicly accessible registers or publicly available social media profiles for fraud prevention or AML compliance purposes.

91win processes your personal data for the following documented purposes. We will not use your personal data for any purpose that is incompatible with those listed below without your prior consent or as required by applicable law:

• Account Management: Creating, maintaining, and securing your 91win Member account, including verifying your identity and age (21+) at registration and prior to withdrawals.
• Transaction Processing: Processing deposits and withdrawals in MYR via verified Malaysian payment channels, reconciling your account balance, and issuing correct bonus credits.
• Regulatory Compliance: Meeting our anti-money laundering (AML), counter-financing of terrorism (CFT), and Know Your Customer (KYC) obligations under our licensing jurisdiction's requirements.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, bonus abuse, and suspicious transactions.
• Responsible Gambling: Monitoring account usage to identify potential problem gambling behaviour, applying deposit limits and self-exclusion tools where requested, and meeting responsible gaming programme obligations.
• Customer Support: Responding to your enquiries, resolving complaints, and maintaining records of support interactions.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the Platform's features, performance, and user experience.
• Marketing Communications: Sending you promotional offers, bonus notifications, and updates about new features — but only where you have opted in to receive such communications. You may withdraw consent at any time through your account settings.
• Legal Compliance: Complying with valid legal obligations, court orders, or requests from competent regulatory or law enforcement authorities.

For each processing purpose described in Section 5, 91win relies on one or more of the following legal bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions agreed to when you register your account (e.g., account management, transaction processing).
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including AML, KYC, and licence conditions (e.g., KYC document collection, regulatory reporting).
• Legitimate Interests: Processing that serves 91win's legitimate business interests where those interests are not overridden by your fundamental rights and freedoms (e.g., fraud prevention, Platform security, analytics).
• Consent: Processing that relies on your freely given, specific, informed, and unambiguous consent (e.g., marketing communications, optional analytics). You may withdraw consent at any time without affecting the lawfulness of prior processing.

91win does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only with the categories of recipients listed below, and only to the extent strictly necessary for each stated purpose:

• Payment Service Providers: Malaysian payment processors (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX), domestic banks (Maybank, CIMB, Public Bank, RHB, Hong Leong Bank), and international payment networks — for the processing of deposits and withdrawals in MYR.
• KYC & Identity Verification Vendors: Licensed third-party identity verification services that process your KYC documents and biometric data on our behalf under strict data processing agreements.
• Fraud Prevention & AML Partners: Compliance technology providers and sanctions-screening services used to fulfil our regulatory obligations in preventing financial crime.
• Game Content Providers: Third-party game studios and live casino operators who may receive session and wager data necessary to deliver and audit game content on the Platform.
• IT Infrastructure Providers: Hosting, cloud storage, and cybersecurity service providers who may process limited technical data to maintain Platform availability and security.
• Regulatory Authorities & Law Enforcement: Where required by law, court order, or regulatory direction — including our licensing authority and, where legally required, relevant Malaysian authorities.
• Professional Advisors: Legal counsel, auditors, and accountants subject to professional confidentiality obligations, where necessary for business operations.

All third-party Data Processors engaged by 91win are required to process personal data only in accordance with 91win's documented instructions and to maintain security measures equivalent to those described in Section 9.

91win retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required for regulatory compliance:

• KYC and identity verification records: Minimum 5 years from account closure, as required by AML regulations.
• Financial transaction records (deposits, withdrawals, bet history): Minimum 5 years from the date of the transaction.
• Customer support communications: 3 years from the date of last interaction or complaint resolution.
• Marketing consent records: Until consent is withdrawn plus 1 year for compliance audit purposes.
• Technical and usage data (logs): 13 months from collection, unless retained longer for ongoing security investigations.
• Self-exclusion records: Duration of exclusion period plus 5 years following expiry, to prevent re-registration during active exclusion.

Upon expiry of applicable retention periods, personal data will be securely deleted or anonymised in a manner that prevents re-identification.

91win implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 91win Platform.
• Encryption of sensitive data at rest, including payment data and KYC documents.
• Role-based access controls, limiting internal access to personal data to authorised personnel only, on a strict need-to-know basis.
• Multi-factor authentication (MFA) for internal systems and, optionally, for Member accounts.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• Incident response procedures to detect, report, and respond to personal data breaches within required timeframes.
• Segregation of player funds from operational funds in dedicated accounts.

91win uses cookies and similar tracking technologies on the Platform. Cookies are small data files stored on your device that help us operate the Platform efficiently, remember your preferences, and analyse usage patterns.

The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled and include session management, authentication, and security tokens. No personal data is shared from these cookies with third parties.
• Functional Cookies: Remember your account preferences, language settings, and region (e.g., Malaysia) so you do not need to re-enter them on each visit.
• Analytical Cookies: Used to understand how Members interact with the Platform — which pages are visited, how long sessions last, and which features are used. This data is collected in aggregated, anonymised form to guide Platform improvements.
• Security Cookies: Used to detect fraudulent activity, identify suspicious login patterns, and enforce our one-account-per-player policy.

You may control or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 91win Platform. Analytical cookies may be opted out of through your account privacy preferences.

Subject to applicable law and certain limitations described below, you have the following rights with respect to your personal data processed by 91win. To exercise any of these rights, please contact us using the details in Section 15.

We will respond to all verifiable data rights requests within 30 calendar days of receipt. Complex requests may require an extension, in which case we will notify you within the initial 30-day period.

The 91win Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21. Age verification is enforced at the point of account registration through our KYC process.

If 91win becomes aware that personal data has been collected from an individual under the age of 21 without verified parental consent, we will take immediate steps to delete that data from our systems and close the associated account. If you believe that a minor has registered an account on our Platform, please contact us immediately at [email protected].

As an internationally licensed gaming platform, some of your personal data may be transferred to, stored in, or processed in countries outside of Malaysia. These countries may include our licensing jurisdiction and the countries in which our technology partners and game content providers operate.

Where such transfers occur, 91win ensures that adequate safeguards are in place to protect your personal data to a standard consistent with the principles of this Privacy Policy. Safeguards include contractual data processing agreements incorporating internationally recognised standard data protection clauses, and due diligence assessments of recipient country adequacy.

By using the 91win Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside of Malaysia where necessary for the purposes described in this Policy.

91win reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. When we make material changes, we will notify registered Members by email (using the address on file for your account) and/or by posting a prominent notice on the Platform, along with a revised "Last Updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. The current version of this Policy will always be accessible at https://91win.cam/privacy-policy. Your continued use of the Platform following the effective date of any amended Policy constitutes your acceptance of the revised terms.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 91win, please contact our Data Protection team using the following details:

When submitting a data rights request, please include your registered 91win username or email address and a clear description of your request. For account deletion or data erasure requests, identity verification will be required prior to processing.

For questions about our Terms & Conditions or Responsible Gambling practices, please visit those dedicated pages or contact our support team directly.