Huc99 Privacy Policy — Personal Data Protection for Malaysian Members

This Privacy Policy ("Policy") describes the practices of huc99 ("Platform", "we", "huc99") regarding the collection, use, disclosure and protection of personal information of all registered members and users of the platform in Malaysia.

Huc99 operates in full compliance with Malaysia's Personal Data Protection Act 2010 (PDPA), the primary legislation governing personal data protection in Malaysia. We are committed to ensuring that all personal information entrusted to us is handled with care, the highest level of security, and strictly for legitimate purposes.

This policy applies to all information you provide during the account registration process, while using huc99's services, while conducting financial transactions including deposits via Touch 'n Go eWallet, GrabPay, DuitNow or FPX, and while interacting with our customer support team.

Huc99 collects the personal information necessary to provide platform services safely and effectively. The types of information we collect are as follows:

Identity Information:

• Full name as stated on your Malaysian identity card or passport
• Date of birth to verify that you are at least 18 years of age
• Identity card number (MyKad) or passport number
• Photo or copy of identity document (collected during the KYC process if required)

Contact Information:

• Active email address
• Malaysian mobile phone number
• Residential address (where required for verification)

Financial Information:

• Details of your selected payment method (Touch 'n Go, GrabPay, DuitNow, FPX, and others)
• Deposit and withdrawal transaction history in MYR
• Bank statement or proof of source of funds (if requested for AML review)

Platform Usage Information:

• IP address and general geographic location
• Device type, operating system and web browser used
• Login records including time and date
• History of gaming and betting activity on the huc99 platform
• Interaction data with platform features such as Live Casino, EPL and Malaysia Super League Sports Betting, and e-sports

Huc99 uses your personal information for the following lawful and clearly stated purposes:

• Account Management: Creating and maintaining your huc99 account, verifying your identity, and ensuring account security.
• Transaction Processing: Processing deposits and withdrawals via your chosen Malaysian payment method, ensuring all MYR transactions are handled accurately and securely.
• KYC/AML Compliance: To fulfil identity verification (Know Your Customer) and anti-money laundering (AML) requirements mandated by law.
• Service Provision: Providing access to all areas of the huc99 platform, including Sports Betting, Live Casino, slots, and e-sports, in line with your account level.
• Customer Support: To help resolve enquiries, complaints, and requests submitted to huc99's customer support team.
• Personalisation: Personalising your platform experience, including promotional recommendations and relevant content based on your usage history.
• Communications: Sending account-related notifications, transaction updates, promotions, and important platform announcements.
• Platform Security: To detect and prevent fraud, account misuse and activities that violate huc99's terms of use.
• Product Improvement: Analysing aggregated usage patterns to improve the huc99 platform, features and services.

Huc99 does not use your data to make automated decisions that have a legal or significant effect on you without appropriate human review.

Under Malaysia's PDPA 2010, huc99 processes your personal data on the following lawful bases:

• Consent: You provide your consent to data processing when you register a huc99 account and accept the terms of use and this Privacy Policy. You may withdraw this consent at any time, though doing so may affect our ability to provide certain services.
• Contract Performance: The processing of most of your data is necessary to provide the services you have requested — for example, we cannot process a withdrawal to your Touch 'n Go account without knowing your account details.
• Legal Obligation: In certain cases, huc99 is required by Malaysian law to collect and retain specific information — primarily for AML/KYC compliance purposes and for reporting to the relevant authorities when required.
• Legitimate Interests: huc99 may process certain data based on our legitimate interests in operating a safe and responsible business — such as fraud detection and ensuring platform security — provided those interests do not override your fundamental privacy rights.

Huc99 does not sell, rent, or trade members' personal information to any third party for marketing purposes. However, in the course of operating the platform, we may share your data with the following categories of third parties for limited and specific purposes:

• Payment Service Providers: To process deposits and withdrawals, the relevant transaction information must be shared with the payment gateways used — including Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow and FPX network providers such as Maybank2u and CIMB Clicks. All these providers maintain their own privacy and security policies that comply with industry standards.
• Game Providers: Live casino, slots, and e-sports game providers that partner with huc99 may receive certain session information necessary to deliver a seamless gaming experience.
• IT Service Providers: Companies providing technical infrastructure, cloud services, and system support for huc99 may have access to data as part of their technical responsibilities, under strict confidentiality agreements.
• Authorities: huc99 may be required to disclose personal information to Malaysian authorities or regulatory bodies if mandated by a court order, applicable legislation or valid legal process.

All third parties who receive your data are bound by data processing agreements ensuring they use the data only for permitted purposes and maintain security standards equivalent to those of huc99.

Huc99 continually invests in security infrastructure to ensure your personal data is protected against unauthorised access, disclosure, alteration or destruction. Among the security measures we have in place:

• Data Encryption in Transit: All communications between your device and huc99's servers are protected by TLS/SSL protocols with 256-bit encryption strength — the same standard used by Malaysia's leading financial institutions.
• Stored Data Encryption: Sensitive information, including payment details and passwords, is stored in encrypted or hashed form on huc99 servers. Your password is never stored in plain text.
• Two-Factor Authentication (2FA): huc99 provides and encourages the use of two-factor authentication on all accounts to add an extra layer of security beyond passwords alone.
• Internal Access Controls: Access to member personal data within huc99's internal systems is restricted to staff who require it for their specific job functions only, based on the principle of least privilege.
• Continuous Security Monitoring: huc99 systems are continuously monitored to detect anomalies, unauthorised access attempts and other security threats.
• Regular Security Audits: huc99 conducts regular internal and independent security audits to identify and address any potential vulnerabilities.
• Incident Response Plan: In the event of a data breach, huc99 has clear procedures in place to detect, contain and notify affected members in accordance with applicable legal requirements.

Huc99 retains your personal information for as long as it is needed for the purposes stated in this Privacy Policy, or as required by applicable law. General data retention guidelines are as follows:

• Active Account Data: For as long as your huc99 account remains active, we retain all information necessary to manage your account and provide services to you.
• Financial Transaction Records: MYR deposit and withdrawal transaction records are retained for a minimum of seven (7) years in accordance with accounting law requirements and applicable AML compliance obligations in Malaysia.
• Identity Verification Data (KYC): Identity verification documents and information are retained for a minimum of five (5) years after account closure, in accordance with applicable regulatory requirements.
• Security Logs: Access logs and security activity records are retained for as long as necessary for threat detection and investigation purposes, typically between one and three years.
• Marketing Data (with consent): If you have consented to receive marketing communications, the relevant data is retained until you withdraw that consent.

Once the retention period expires, huc99 will securely delete or anonymise your personal data in accordance with established internal procedures, unless applicable law requires a longer retention period.

Huc99 uses cookies and similar web technologies to enhance the user experience and ensure the platform functions properly. The following explains how we use these technologies:

Cookies We Use:

• Essential Cookies (Required): These cookies are required for core huc99 platform functions such as login authentication, session management and security. The platform cannot function properly without them.
• Functional Cookies: Saving your preferences such as language, display settings, and other configurations so you do not need to reset them each time you visit huc99.
• Performance/Analytics Cookies: Collecting information about how you use the huc99 platform — such as which pages you visit most frequently and how long you spend in each section — to help us understand and improve the user experience. This data is collected in aggregate and is not used to identify you personally.

Most web browsers allow you to manage cookies through your browser settings. You may choose to block all cookies, though this may affect the functionality and user experience of the huc99 platform. Cookies required for security and login authentication cannot be disabled without impacting your ability to use the platform.

Under Malaysia's PDPA 2010 and huc99's policy, you have the following rights regarding your personal data:

• Right to Access: You have the right to request a copy of the personal information we hold about you. huc99 will provide access within a reasonable timeframe, typically within 14 business days from the date a complete request is received.
• Right to Rectification: If the personal information we hold about you is inaccurate or incomplete, you have the right to request a correction. You can update certain information directly through your huc99 account settings.
• Right to Withdraw Consent: You may withdraw consent previously given for specific data processing activities at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to the withdrawal.
• Right to Object to Processing: Under certain circumstances, you have the right to object to the processing of your data carried out on the basis of our legitimate interests.
• Right to Request Erasure: Under limited circumstances and in accordance with applicable law, you may request the deletion of your personal data. Please note that such requests may not be fully fulfilled if we have a legal obligation to retain that data.
• Right to Lodge a Complaint: If you believe your privacy rights have been violated, you have the right to lodge a complaint with Malaysia's Personal Data Protection Commissioner or to contact huc99 directly for resolution.

To submit any request relating to your privacy rights, please contact huc99's Privacy Officer by email at support@huc99-khelo.com or via in-platform live chat. Please include your account number and a clear description of your request to help us process it more efficiently.

If you have any questions, concerns, or requests relating to this Privacy Policy or how huc99 handles your personal data, please reach out to us through the following channels:

• Email: support@huc99-khelo.com — for detailed enquiries requiring documentation or written follow-up
• Live Chat: Available on the huc99 platform — for the fastest response, typically within 2 minutes
• WhatsApp: VIP Gold members and above may contact their Personal VIP Manager directly

All huc99 support channels operate 24 hours a day, 7 days a week, including Malaysian public holidays. Our Malay-speaking support team will assist you within a reasonable timeframe. For requests related to data access or data correction, response times are typically within 14 business days from the date a complete request is received.