Privacy Policy — TCL99
At TCL99, your privacy is not a box we tick — it is a commitment we take seriously. This Privacy Policy sets out in full and precise terms what personal data we collect from Malaysian members, why we collect it, how it is processed and protected, and what rights you hold over your own information.
Our Privacy Principles at a Glance
Before reading the full policy, here is a summary of how TCL99 approaches data protection for all Malaysian members.
Data Minimisation
We collect only the personal information strictly necessary to operate your account, process transactions in MYR, and comply with our legal obligations. Nothing more, nothing less.
256-Bit Encryption
All data transmitted between your device and TCL99's servers is protected with industry-standard TLS 1.3 encryption. Sensitive records are encrypted at rest using AES-256.
No Data Selling
TCL99 does not sell, rent, or trade your personal information to any third party for marketing or commercial profiling purposes — ever. Your data is not a product.
Your Rights, Respected
You have the right to access, correct, download, or request deletion of your personal data at any time. TCL99 will respond to all valid data rights requests within 30 days.
Controlled Third-Party Sharing
Where we share data with third parties — such as payment processors like DuitNow, FPX, or Maybank — those parties are bound by strict data processing agreements with equivalent security standards.
Defined Retention Periods
We keep your personal data only as long as required for the purposes described in this Policy or as mandated by applicable legal and regulatory obligations. Data is securely deleted when no longer needed.
- 1. Introduction
- 2. Definitions
- 3. Data We Collect
- 4. How We Collect Data
- 5. Purposes of Processing
- 6. Legal Basis for Processing
- 7. Data Sharing & Disclosure
- 8. Data Retention
- 9. Data Security
- 10. Cookies & Tracking
- 11. Your Data Rights
- 12. Minors & Age Restriction
- 13. International Transfers
- 14. Changes to This Policy
- 15. Contact Us
1 Introduction
This Privacy Policy ("Policy") is issued by TCL99 ("TCL99", "we", "us", "our") and applies to all individuals ("Member", "User", "you", "your") who access, register with, or otherwise interact with the TCL99 platform available at tcl99.cam.
This Policy explains in detail how TCL99 collects, uses, stores, discloses, and protects personal data in the course of providing online casino, sports betting, live casino, and related services to Malaysian users. It also sets out your rights in relation to your personal data and how you may exercise those rights.
By creating a TCL99 account or continuing to use the platform, you acknowledge that you have read and understood this Policy and consent to the data processing practices described herein, to the extent that such consent is required by applicable law. This Policy should be read in conjunction with our Terms & Conditions.
This Policy is written and maintained in English only. TCL99 operates as an English-language platform for Malaysian users. Where any inconsistency arises between translated versions and the English text, the English version shall be authoritative.
2 Definitions
For the purposes of this Policy, the following terms shall carry the meanings assigned below:
- "Personal Data"
- Any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial information, and online identifiers.
- "Data Controller"
- TCL99, which determines the purposes and means of processing your personal data in connection with the platform's services.
- "Data Processor"
- Any third party that processes personal data on behalf of TCL99 under a contractual arrangement, including payment service providers, identity verification services, and IT infrastructure operators.
- "Processing"
- Any operation performed on personal data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, transmission, erasure, or destruction.
- "KYC"
- Know Your Customer — the process by which TCL99 verifies the identity, age, and eligibility of a Member, in compliance with anti-money laundering and responsible gambling obligations.
- "Cookies"
- Small text files stored on your device by your browser when you access the TCL99 platform, used to recognise returning visitors, maintain session state, and analyse usage patterns.
3 Personal Data We Collect
TCL99 collects the following categories of personal data in the ordinary course of providing its services to Members:
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full name, date of birth, nationality, MyKad / passport number | Registration and KYC verification |
| Contact Data | Email address, mobile number, residential address (including city — e.g., Kuala Lumpur, Penang, Johor Bahru) | Registration and account updates |
| Financial Data | Bank account details, e-wallet account identifiers (e.g., Touch 'n Go, DuitNow), transaction history in MYR | Deposit and withdrawal processing |
| Technical Data | IP address, browser type and version, device identifiers, operating system, time zone | Automatically upon platform access |
| Usage Data | Game history, betting patterns, session duration, pages visited, feature interactions | During active platform use |
| Communications Data | Live chat transcripts, support email content, complaint records | Customer support interactions |
| Verification Documents | Copies of government-issued ID, proof of address, payment method screenshots | KYC compliance and fraud prevention |
TCL99 does not collect special categories of sensitive personal data (such as racial or ethnic origin, health data, or biometric data) unless expressly required by a legal or regulatory obligation, and only with appropriate safeguards in place.
4 How We Collect Your Data
TCL99 collects personal data through the following channels and mechanisms:
- Direct Submission: Information you voluntarily provide when creating an account, completing KYC verification, making a deposit or withdrawal, or contacting our support team.
- Automated Technologies: Technical and usage data collected automatically when you access the platform, including through cookies, web beacons, server logs, and similar tracking technologies.
- Payment Processors: Financial transaction data received from payment service providers including DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, Touch 'n Go eWallet, Boost, and GrabPay, in connection with deposit and withdrawal processing.
- Identity Verification Providers: Data received from third-party KYC and fraud prevention service providers in the course of verifying your identity and eligibility.
- Public Sources: Where legally permissible, publicly available information may be used to supplement Member records for fraud prevention and compliance purposes.
5 Purposes of Data Processing
TCL99 processes your personal data only for specified, explicit, and legitimate purposes. The primary purposes for which your data is used are as follows:
- Account Administration: To create, maintain, and manage your TCL99 member account, including authentication and security measures.
- Service Delivery: To provide access to online casino games, live dealer tables, sports betting markets, and all other platform features.
- Financial Transactions: To process MYR deposits and withdrawals through your chosen payment method, maintain accurate financial records, and prevent payment fraud.
- KYC & AML Compliance: To verify your identity and age, comply with anti-money laundering obligations, and screen against applicable sanctions lists.
- Responsible Gambling: To monitor usage patterns, enforce self-exclusion requests, apply deposit and loss limits, and identify potential signs of problem gambling behaviour.
- Customer Support: To handle enquiries, resolve complaints, and communicate with you regarding your account in English via live chat and email.
- Platform Security: To detect, investigate, and prevent fraudulent transactions, cheating, collusion, unauthorised access, and other prohibited activities.
- Legal Obligations: To comply with applicable laws, regulatory requirements, court orders, and law enforcement requests where TCL99 is legally obligated to do so.
- Platform Improvement: To analyse aggregated, anonymised usage data for the purposes of improving platform performance, game selection, and user experience.
- Direct Communications: Where you have opted in, to send you promotional communications regarding bonuses, new games, and platform updates via your registered email address.
6 Legal Basis for Processing
TCL99 processes your personal data only where it has a lawful basis to do so. The applicable legal bases are:
- Contractual Necessity: Processing required to fulfil TCL99's obligations under the Member agreement — including account management, payment processing, and service delivery.
- Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, tax reporting obligations, and regulatory directives applicable to online gaming operators.
- Legitimate Interests: Processing undertaken in the pursuit of TCL99's legitimate business interests, including fraud prevention, platform security, and improving service quality, where those interests are not overridden by your privacy rights.
- Consent: Processing of personal data for direct marketing communications, where your prior, freely given, and specific consent has been obtained. You may withdraw consent at any time by contacting our support team.
7 Data Sharing & Disclosure
TCL99 does not sell or trade your personal data to third parties for their own commercial purposes. We may, however, share your data with the following categories of recipients under strictly controlled conditions:
- Payment Service Providers: Processing entities including DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, Touch 'n Go eWallet, Boost, and GrabPay — solely for the purpose of completing your financial transactions.
- Identity Verification Services: Third-party KYC providers engaged to verify Member identity documents and screen against fraud and sanctions databases.
- IT Infrastructure Partners: Cloud hosting, data storage, and cybersecurity providers who process data on TCL99's behalf under binding data processing agreements with equivalent security standards.
- Game Studio Providers: Where technically necessary, limited technical identifiers may be shared with game content providers to deliver game functionality and audit game outcomes. No sensitive personal data is shared for this purpose.
- Legal and Regulatory Authorities: Competent authorities, law enforcement agencies, courts, or regulators where TCL99 is legally required or lawfully permitted to disclose your information.
- Group Entities: Where applicable, TCL99 may share data with affiliated entities within the same corporate group for internal administrative and compliance purposes, subject to equivalent data protection obligations.
Data Processing Agreements: All third parties with whom TCL99 shares personal data are required to execute formal data processing agreements that impose obligations no less stringent than those described in this Policy. TCL99 does not authorise any third party to use your personal data for their own marketing purposes.
8 Data Retention
TCL99 retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, having regard to legal, regulatory, and operational requirements. The following general retention principles apply:
- Active Account Data: Retained for the duration of the Member relationship and for a minimum period of five (5) years following account closure, in line with standard anti-money laundering record-keeping requirements.
- Transaction Records: Financial transaction records in MYR, including deposit and withdrawal history, are retained for a minimum of seven (7) years from the date of the transaction, consistent with financial regulatory requirements applicable to online gaming operators.
- KYC Documents: Identity verification documents are retained for a minimum of five (5) years following the end of the customer relationship, or such longer period as required by applicable law.
- Customer Support Records: Live chat transcripts and support correspondence are retained for three (3) years for quality assurance and dispute resolution purposes.
- Marketing Consent Records: Records of your marketing consent or opt-out are retained for the duration of the Member relationship plus an additional three (3) years as evidence of compliance.
Upon expiry of the applicable retention period, personal data is securely destroyed or anonymised so that it can no longer be linked to any identifiable individual.
9 Data Security
TCL99 implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include, but are not limited to:
- Transport Layer Security (TLS 1.3) for all data transmitted between your device and TCL99 servers
- AES-256 encryption for sensitive data stored at rest, including financial records and identity documents
- Two-factor authentication (2FA) available for all Member accounts
- Role-based access controls limiting employee access to personal data on a strict need-to-know basis
- Regular penetration testing and security audits conducted by independent cybersecurity specialists
- Real-time fraud monitoring systems that identify and flag suspicious account activity
- Incident response procedures for detecting, reporting, and managing personal data breaches
While TCL99 takes all reasonably practicable steps to protect your personal data, no online platform can guarantee absolute security. You are also responsible for maintaining the confidentiality of your account credentials. If you suspect that your account has been compromised, please contact our support team immediately via live chat or email.
10 Cookies & Tracking Technologies
TCL99 uses cookies and similar tracking technologies on its platform. These are small data files placed on your device that enable certain platform functions and allow us to understand how Members interact with the site. The categories of cookies TCL99 uses are:
- Strictly Necessary Cookies: Required for core platform functionality, including maintaining your login session, processing transactions, and ensuring platform security. These cookies cannot be disabled without impairing your ability to use the platform.
- Functional Cookies: Used to remember your preferences, such as language settings and display configurations, to enhance your experience across sessions.
- Analytical Cookies: Enable TCL99 to analyse how Members use the platform — including which games are most frequently played and how navigation flows are used — in order to improve platform performance. All analytical data is processed in aggregated, anonymised form.
- Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.
You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of parts of the TCL99 platform.
11 Your Data Rights
Subject to applicable law, you have the following rights in relation to the personal data TCL99 holds about you. To exercise any of these rights, please contact our support team using the details provided in Section 15.
Right of Access
You may request a copy of the personal data TCL99 holds about you, together with information about how and why it is being processed.
Right to Rectification
You may request correction of any inaccurate or incomplete personal data held about you. Account holders may update basic details directly via account settings.
Right to Erasure
In certain circumstances, you may request the deletion of your personal data. Note that legal and regulatory retention obligations may limit the scope of erasure requests.
Right to Restrict Processing
You may request that TCL99 temporarily suspend the processing of your personal data in specific circumstances, such as while a data accuracy dispute is being resolved.
Right to Data Portability
You may request your personal data in a structured, commonly used, machine-readable format for transfer to another service provider, where technically feasible.
Right to Object
You may object to processing based on legitimate interests or for direct marketing purposes. Where you object to marketing, we will cease processing immediately.
TCL99 aims to respond to all data rights requests within 30 calendar days of receipt. Where a request is complex or numerous, this period may be extended by a further 60 days, in which case we will notify you of the extension and the reason for it.
12 Minors & Age Restriction
TCL99 is strictly an adult platform. Our services are available exclusively to persons aged 21 years or older. TCL99 does not knowingly collect, store, or process personal data relating to individuals below this age threshold.
If we become aware that personal data has been submitted by or on behalf of a person under the age of 21, that account will be closed immediately, all associated data will be deleted or anonymised, and any funds will be handled in accordance with our responsible gambling and legal compliance procedures. If you have reason to believe that a minor has registered an account on TCL99, please notify us immediately via our support team.
13 International Data Transfers
In the course of providing its services, TCL99 may transfer personal data to data processors or infrastructure providers located outside of Malaysia. Where such transfers occur, TCL99 ensures that appropriate safeguards are in place to protect the transferred data, including:
- Execution of standard contractual clauses or equivalent data transfer mechanisms recognised under applicable data protection law
- Contractual obligations binding the recipient to maintain security standards consistent with this Policy
- Transfers to jurisdictions that have been assessed as providing an adequate level of data protection
You may request further information regarding the safeguards applicable to any specific international transfer of your data by contacting our support team.
14 Changes to This Privacy Policy
TCL99 reserves the right to amend or update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. Where material changes are made, TCL99 will provide notice to registered Members via their registered email address or through a prominent notice on the platform prior to the changes taking effect.
The "Last updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the TCL99 platform following any update to this Policy constitutes your acceptance of the revised terms, to the extent permitted by applicable law. We encourage you to review this Policy periodically.
15 Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or TCL99's data processing practices, please contact our Data & Privacy team through any of the following channels:
- Email: [email protected] — please include "Privacy Request" in the subject line for prompt routing to the relevant team.
- Live Chat: Available 24 hours a day, 7 days a week, directly through the TCL99 platform. Average first response time is under 90 seconds. Our support team operates primarily on Malaysian Time (MYT, UTC+8).
- Formal Written Requests: For formal data subject requests, including access, rectification, and erasure requests, please contact us in writing via email with sufficient detail to verify your identity and the specific data concerned.
TCL99 will acknowledge all privacy-related enquiries within 48 hours of receipt and will endeavour to provide a substantive response within 30 calendar days, as required by applicable data protection standards.
Your Privacy is Protected — Play with Confidence
TCL99 is built on the principles of transparency, security, and respect for your personal data. Every Malaysian member can trust that their information is handled with the utmost care.