Flay99 Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how Flay99 ("we", "us", "our", or "the Platform") collects, processes, stores, and protects the personal data of individuals who access or use the services available at https://flay99.cam and any associated sub-domains or mobile applications (collectively, "the Platform").

Flay99 operates as an online casino and sports betting platform with a primary focus on Malaysian users. Our services are offered to eligible players aged 21 and above in supported jurisdictions. As part of delivering our services — which include account management, MYR banking transactions, identity verification, bonus administration, and customer support — we necessarily process certain personal data belonging to our users.

We are committed to handling that data responsibly, transparently, and in accordance with applicable data protection principles. This Policy is intended to give you a clear and honest account of our data practices so that you can make informed decisions about your use of our platform.

Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

Personal Data We Collect

Flay99 collects personal data in the categories listed below. We only collect data that is necessary and proportionate to the purposes described in Section 5 of this Policy.

3.1 Identity & Registration Data

• Full legal name as per government-issued identification
• Date of birth (for age verification — minimum 21 years)
• Nationality and country of residence
• Government-issued identification number (where required for KYC)
• Username and encrypted password

3.2 Contact Data

• Email address
• Mobile telephone number
• Residential or mailing address (city, state, postcode) — including Malaysian addresses in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and other locations

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records (amounts, timestamps, payment methods)
• Bank account or e-wallet identifiers used in connection with MYR transactions
• Wagering activity records, game history, and account balance history

3.4 KYC Verification Documents

• Copies of government-issued photo identification (MyKad, passport, or equivalent)
• Proof of address documentation
• Proof of payment method (where required)

3.5 Technical & Device Data

• IP address and geolocation data derived from IP
• Browser type, version, and operating system
• Device identifiers and mobile device type
• Session logs, login timestamps, and access records

3.6 Communication Data

• Records of live chat support interactions
• Email correspondence with our support team
• Any complaints, disputes, or feedback submitted by you

3.7 Responsible Gambling Data

• Deposit limit settings, session time preferences, and cooling-off or self-exclusion requests
• Any responsible gambling assessments or self-declared risk profiles

How We Collect Your Data

Flay99 collects personal data through the following channels:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit, contacting support, or completing any form on the Platform.
• Automated technical collection: Data collected automatically as you interact with the Platform — including session cookies, IP logging, and device fingerprinting for fraud prevention purposes.
• Payment processors: Transaction confirmation data received from Malaysian payment operators including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect — relating to deposits and withdrawals you initiate.
• KYC verification partners: Identity and document verification results from third-party KYC service providers engaged by Flay99 for the purposes of age and identity confirmation.
• Public sources: In limited circumstances, publicly available records may be consulted for the purposes of fraud prevention or AML compliance screening.

Purposes of Data Processing

Flay99 processes your personal data for the following specific purposes:

Legal Basis for Processing

Flay99 processes personal data on the following legal bases, as applicable to the specific processing activity:

• Contractual necessity: Processing required to perform our obligations under the agreement formed when you register an account and accept our Terms & Conditions — including account administration, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations — including KYC identity verification, AML transaction monitoring, and regulatory record-keeping requirements.
• Legitimate interests: Processing necessary for Flay99's legitimate business interests where those interests are not overridden by your data protection rights — including fraud prevention, platform security, and anonymised analytics for service improvement.
• Consent: Processing based on your explicit consent — including the sending of promotional marketing communications and the use of non-essential cookies. You may withdraw consent at any time by contacting our support team or adjusting your account preferences.

Data Sharing & Third Parties

Flay99 does not sell, rent, or otherwise commercially transfer your personal data to third parties. We do, however, share data with certain categories of trusted service providers and authorised third parties in the specific circumstances described below:

7.1 Payment Service Providers. To process your MYR deposits and withdrawals, we share necessary transaction data with your chosen payment operator — which may include DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank, or Hong Leong Connect. Each provider operates its own privacy practices and you should review their respective policies for information on how they handle your data.

7.2 KYC & Identity Verification Partners. We engage specialist third-party KYC providers to perform identity and age verification. These providers process your submitted documentation solely for verification purposes under binding data processing agreements with Flay99.

7.3 Cloud Infrastructure & Hosting. The Flay99 Platform operates on cloud infrastructure provided by third-party hosting partners. These providers store and process data on our behalf under strict contractual data protection terms and are not permitted to use your data for their own independent purposes.

7.4 Regulatory & Legal Authorities. We may disclose personal data to regulatory authorities, law enforcement agencies, or other competent public bodies where we are required to do so by applicable law, court order, or other legal process — including for AML and CTF reporting obligations.

7.5 Professional Advisors. In limited circumstances, personal data may be shared with our legal counsel, auditors, or other professional advisors where strictly necessary for the provision of their professional services and subject to confidentiality obligations.

Payment Data & Financial Information

8.1 Scope of Payment Data. When you make a deposit or withdrawal via any of Flay99's supported Malaysian payment channels, we receive transaction confirmation data — including the transaction reference number, amount in MYR, timestamp, and the payment method identifier associated with your account. Full bank account numbers, card numbers (where applicable), and e-wallet PINs are never stored on Flay99 servers.

8.2 Third-Party Payment Processing. All payment transactions are handled directly through the relevant payment operator's secure infrastructure. Flay99 does not directly process or store full payment card or bank account details. Transaction data we receive is used solely for account crediting, withdrawal processing, transaction reconciliation, and fraud prevention purposes.

8.3 AML Monitoring. In fulfilment of our anti-money laundering obligations, Flay99 monitors transaction patterns, deposit volumes, and withdrawal activity for indicators of suspicious financial behaviour. Transaction records may be retained for the period required by applicable AML regulations.

Cookies & Tracking Technologies

Flay99 uses cookies and similar technologies on the Platform for the following purposes:

You can manage your cookie preferences through your browser settings. Disabling essential cookies will impair your ability to log in and use core platform features. Non-essential cookies (analytics and functional) can be disabled without affecting your ability to play or transact.

Data Retention

Flay99 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required to meet our legal, regulatory, and contractual obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of your Account relationship with Flay99, plus any mandatory post-closure retention period required by applicable law.
• Transaction Records: Financial transaction records, including MYR deposit and withdrawal history, are retained for a minimum of five (5) years from the date of the transaction in compliance with AML regulatory requirements.
• KYC Documentation: Identity verification documents are retained for a minimum of five (5) years from the date of account closure or the last transaction date, whichever is later.
• Communication Records: Support chat logs and email correspondence are retained for a period of two (2) years from the date of the interaction, unless they relate to an ongoing dispute or compliance matter.
• Technical Logs: Server access logs and session data are retained for twelve (12) months for security and fraud prevention purposes, after which they are deleted or anonymised.

Upon expiry of the applicable retention period, personal data is securely deleted or rendered permanently anonymous in accordance with our internal data destruction procedures.

Data Security

Flay99 implements a layered approach to data security, combining technical, organisational, and procedural controls to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure.

11.1 Technical Measures. These include: 256-bit SSL/TLS encryption for all data in transit between your device and our servers; encryption of sensitive data at rest within our database infrastructure; multi-factor authentication options for account access; automated intrusion detection and monitoring systems; and regular vulnerability assessments and penetration testing of Platform infrastructure.

11.2 Organisational Measures. Access to personal data within Flay99's operations is strictly limited to staff members who require it to perform their specific functions. All staff handling personal data are subject to confidentiality obligations and receive regular data protection awareness training.

11.3 Incident Response. In the event of a personal data breach that poses a risk to affected individuals, Flay99 will take prompt remedial action and, where required by applicable law, notify affected users and relevant authorities within the required timeframe.

Your Data Rights

Subject to applicable law, you have the following rights in relation to the personal data Flay99 holds about you. To exercise any of these rights, please contact our support team via live chat or email, and we will respond within a reasonable timeframe, ordinarily within 30 calendar days.

Children & Minors

The Flay99 Platform is strictly intended for use by adults aged 21 years and above. We do not knowingly collect personal data from any person under the age of 21, and we employ age verification measures during the account registration and KYC processes specifically to prevent underage access.

If we become aware that personal data has been collected from an individual under the age of 21 without the appropriate verification, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on Flay99, please contact us immediately via our support team.

Amendments to This Policy

Flay99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing activities, applicable laws, or platform features. The date of the most recent revision is displayed at the top of this page.

Where changes are material — that is, where they significantly affect how we process your personal data or alter your rights — we will notify registered users by posting a prominent notice on the Platform and, where appropriate, by sending a notification to the email address registered on your account, at least seven (7) calendar days before the changes take effect.

Your continued use of the Platform following the publication of any amendment to this Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to remain informed of how we handle your data.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which Flay99 handles your personal data, please do not hesitate to contact us through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly on the Flay99 Platform. This is our fastest response channel and is staffed by English-speaking agents across all Malaysian time zones.
• Email: [email protected] — responses are typically provided within 1 hour during peak support hours (8AM to 2AM Malaysian Time, MYT).

We aim to address all privacy-related enquiries promptly and transparently. Whether you are reaching us from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, or elsewhere in Malaysia, our team is available to assist you.