Privacy Policy —
How Crowm99 Protects
Your Personal Data

This Privacy Policy (hereinafter "Policy") is issued by Crowm99 (hereinafter "Crowm99", "we", "us", or "the Platform") and applies to all users (hereinafter "Player", "User", or "you") who access or register an account on the Crowm99 website at https://crowm99.cam and all associated digital services.

Crowm99 is an online casino and sports betting platform serving players across Malaysia, including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam. In providing these services, we necessarily process certain personal data about our Players. This Policy sets out, in full and without omission, what data we collect, why we collect it, how it is processed, with whom it may be shared, and the rights available to you in respect of your data.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which form part of the overall agreement governing your use of the platform.

For the purposes of this Privacy Policy, the following terms shall carry the meanings assigned to them below:

• "Personal Data" means any information that identifies or is capable of identifying a natural person, either directly or in combination with other data held by Crowm99.
• "Processing" means any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, transfer, and deletion.
• "Data Controller" means Crowm99, 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 Crowm99 under a documented data processing agreement.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "Cookies" means small text files stored on your device by the Crowm99 website that enable certain platform functions and analytics.
• "KYC" means Know Your Customer — the identity verification and due diligence process required by applicable regulations before certain account functions are enabled.
• "AML" means Anti-Money Laundering — regulatory requirements that obligate Crowm99 to collect and retain certain financial data and report suspicious activity to relevant authorities.

Crowm99 collects the following categories of personal data from Players:

Crowm99 collects your personal data through the following channels and mechanisms:

• Direct Provision: Data you provide directly when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or responding to surveys or promotions.
• Automated Technical Collection: Data collected automatically when you access and use the platform, including IP address, device identifiers, browser information, session logs, and interaction data, via server logs, cookies, and similar tracking technologies.
• Payment Processors: Confirmation data and transaction references received from licensed Malaysian payment partners (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong) when you make deposits or withdrawals.
• Fraud Prevention and AML Checks: Data received from third-party identity verification and fraud screening services used to complete KYC and AML compliance checks, where applicable.

Crowm99 processes your personal data for the following specific and documented purposes:

• Account Creation and Management: To create, verify, and maintain your player account on the Crowm99 platform, and to authenticate your identity when you log in.
• Payment Processing: To facilitate deposits into and withdrawals from your account via your chosen Malaysian payment method (MYR-denominated), and to maintain accurate transaction records.
• KYC and Identity Verification: To verify your identity, age (minimum 21 years), and residential address as required by our operating standards and applicable regulations.
• AML and Fraud Prevention: To detect, investigate, and prevent money laundering, fraud, unauthorised access, and other financial crimes, and to report suspicious activity to relevant authorities where legally required.
• Customer Support: To respond to your queries, complaints, and requests, and to maintain a record of our communications for dispute resolution purposes.
• Responsible Gambling: To monitor your gaming activity in connection with our responsible gambling programme, including applying deposit limits, session controls, and self-exclusion requests where applicable.
• Platform Security: To monitor platform access for unauthorised activity, protect against cyber threats, and maintain the integrity of our systems and data.
• Service Improvement: To analyse aggregated and anonymised usage data for the purpose of improving platform performance, game selection, user experience, and payment infrastructure.
• Promotional Communications: To send you relevant promotional offers and updates by email or in-platform notification, where you have opted in to receive such communications. You may withdraw consent at any time by contacting support.
• Legal and Regulatory Compliance: To meet obligations under applicable data protection, AML, and gaming regulatory frameworks.

Crowm99 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is necessary to perform the contract between you and Crowm99 (i.e., providing the platform services you have registered to access). This covers account management, payment processing, and customer support.
• Legal Obligation: Processing required to comply with applicable legal obligations, including KYC identity verification, AML transaction monitoring, and regulatory reporting.
• Legitimate Interests: Processing carried out in pursuit of Crowm99's legitimate business interests — such as fraud prevention, platform security, service improvement, and responsible gambling monitoring — where those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given consent, such as sending you promotional communications via email. You may withdraw consent at any time without affecting the lawfulness of any prior processing.

Crowm99 does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We may share your personal data in the following limited and documented circumstances only:

• Licensed Payment Partners: Your financial data is shared with Malaysian-licensed payment service providers (including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and Hong Leong) solely for the purpose of processing your deposits and withdrawals. All such partners are required to handle your data in accordance with applicable financial regulations.
• Identity Verification Providers: Where necessary to complete KYC and AML checks, your identity documents and related data may be shared with approved third-party identity verification service providers under strict data processing agreements.
• Fraud Prevention Services: To protect the platform and its players, certain technical data (such as IP addresses and device identifiers) may be processed by fraud detection services operating under Crowm99's direction.
• Regulatory and Legal Authorities: Crowm99 may disclose personal data to regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or regulatory directive. We will notify affected Players of such disclosures to the extent permitted by law.
• Business Succession: In the event of a merger, acquisition, or sale of Crowm99's business or assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

Crowm99 uses cookies and similar tracking technologies on its platform. Cookies are small text files placed on your device that enable certain website functions. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function. These enable account login sessions, security functions, and payment processing workflows. These cannot be disabled without impairing platform function.
• Performance and Analytics Cookies: Used to collect anonymised data about how Players interact with the platform — which pages are visited, session duration, and navigation paths. This data is used solely for platform improvement and does not identify individual users.
• Functional Cookies: Enable personalised platform features such as language preferences, remembered login details, and layout customisation. These improve your experience but are not essential.
• Security Cookies: Support fraud detection and platform integrity monitoring by identifying unusual access patterns or anomalous technical behaviour.

You may control cookie preferences through your browser settings. Disabling strictly necessary cookies may result in reduced platform functionality. Crowm99 does not use third-party advertising or behavioural tracking cookies.

Crowm99 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention principles apply:

• Active Accounts: Personal data associated with active player accounts is retained for the duration of the account's active status and for a period of five (5) years following account closure, in compliance with standard financial and AML record-keeping requirements.
• Financial and Transaction Records: Transaction data, deposit records, and withdrawal histories are retained for a minimum of seven (7) years from the date of the transaction to satisfy financial regulatory obligations.
• KYC Documents: Identity and address verification documents are retained for five (5) years following account closure or the completion of the relevant verification process, whichever is later.
• Customer Support Records: Communications exchanged with the Crowm99 support team are retained for three (3) years from the date of the communication, for dispute resolution and service quality purposes.
• Marketing Preferences: Records of your marketing consent or opt-out status are retained for the duration of your account and for two (2) years following account closure.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with Crowm99's data disposal procedures. We conduct periodic data retention audits to ensure compliance with this Policy.

Crowm99 takes the security of your personal data seriously and implements a comprehensive set of technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and the Crowm99 platform is encrypted using TLS 1.2 or higher (256-bit SSL). All payment transactions are subject to the same encryption standard.
• Encryption at Rest: Sensitive personal data stored in Crowm99's systems is encrypted at rest using industry-standard AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All personnel with access to personal data are required to maintain confidentiality and are subject to regular security training.
• Two-Factor Authentication: Crowm99 supports and encourages two-factor authentication (2FA) for all player accounts to provide an additional layer of account security.
• Security Audits: Crowm99 conducts periodic security assessments and vulnerability reviews to identify and remediate any potential weaknesses in our data infrastructure.
• Incident Response: In the event of a data security incident that poses a risk to your personal data, Crowm99 will notify affected Players and relevant authorities promptly in accordance with applicable obligations.

Subject to applicable law, you have the following rights in respect of your personal data held by Crowm99. These rights may be exercised by contacting our support team at any time.

• Right of Access: You have the right to request a copy of the personal data Crowm99 holds about you, together with information about how that data is processed.
• Right of Rectification: If any personal data held about you is inaccurate or incomplete, you have the right to request that it be corrected or completed.
• Right of Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to Crowm99's legal retention obligations.
• Right to Restrict Processing: You may request that Crowm99 restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data you have disputed is under review.
• Right to Data Portability: Where processing is based on your consent or a contractual obligation, you may request a copy of your personal data in a structured, machine-readable format.
• Right to Object: Where processing is based on legitimate interests, you have the right to object. Crowm99 will assess your objection and cease processing unless it can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you may withdraw that consent at any time by contacting support or using the unsubscribe function in any marketing email.

Crowm99 strictly prohibits the use of its platform by any individual under the age of 21 years. The platform is designed and intended exclusively for adult players aged 21 and above.

We do not knowingly collect, process, or retain personal data from individuals under the age of 21. If Crowm99 discovers or is notified that a player account has been registered by a minor, the account will be immediately suspended, all funds will be frozen pending investigation, and any data associated with the minor's account will be securely deleted in accordance with this Policy.

Parents and guardians who believe that a minor in their care may have accessed or registered on the Crowm99 platform should contact our support team immediately at [email protected] (plain text — not a clickable link). We will investigate and act promptly.

Crowm99's primary data processing operations are conducted within the region and, where applicable, with service providers located in jurisdictions that maintain adequate data protection standards. In cases where personal data is transferred outside of Malaysia, Crowm99 ensures that:

• The receiving jurisdiction has been determined to offer an adequate level of data protection, or
• Appropriate safeguards are in place — such as contractual data transfer agreements incorporating standard data protection clauses — to protect the personal data transferred, or
• The transfer is necessary for the performance of the contract between you and Crowm99 (e.g., processing a payment routed through an international payment network).

Crowm99 does not transfer personal data to jurisdictions that do not offer adequate data protection without implementing appropriate safeguards. If you require information about the specific safeguards applied to any cross-border transfer of your data, please contact our support team.

Crowm99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. Where material changes are made to this Policy, Crowm99 will:

• Update the "Last Updated" date at the top of this page.
• Notify registered Players of significant changes via email notification or a prominent notice displayed on the platform for a reasonable period following the update.
• Where required by law, seek renewed consent from Players for any new processing activities that require it.

Your continued use of the Crowm99 platform following notification of any update to this Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you must cease using the platform and contact support to arrange account closure and the return of any available balance.

The current version of this Privacy Policy is always accessible at https://crowm99.cam/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Crowm99, please contact us through the following channels:

We aim to acknowledge all privacy-related enquiries within five (5) business days and to provide a substantive response within thirty (30) days. For complex requests, we will notify you if additional time is required.

For responsible gambling concerns or self-exclusion requests, please visit our dedicated Responsible Gambling page. For general platform questions, please visit our FAQ.