This Privacy Policy applies to all personal data collected through the 91win88 Platform at https://91win88.org, including during account registration, KYC verification, deposit and withdrawal processing, gameplay, and customer support interactions. By using 91win88, you consent to the data practices described in this Policy.
1. Introduction
91win88 ("we", "us", "our") operates the online gaming platform at https://91win88.org and associated subdomains and mobile interfaces (collectively, the "Platform"). We act as the data controller for personal data collected through the Platform, meaning we determine the purposes and means by which your personal data is processed.
We understand that privacy is important to our players, particularly in the context of an online gaming platform where financial and identity data are involved. This Policy is written in plain language to the greatest extent possible — while maintaining the legal precision required of a privacy disclosure document — so that Malaysian players can clearly understand what data 91win88 holds about them and why.
If you have any questions about this Policy or wish to exercise your data rights, please contact us as described in Section 14 of this Policy.
2. Personal Data We Collect
91win88 collects personal data through several channels. The categories of data we collect, and the circumstances under which collection occurs, are set out in the table below.
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full name, date of birth, nationality, MyKad / passport number | Account registration; KYC verification |
| Contact Data | Email address, Malaysian mobile number, residential address | Account registration; KYC; support interactions |
| Financial Data | Bank account details, e-wallet identifiers (TnG, Boost, GrabPay), transaction history, deposit and withdrawal records | Deposit / withdrawal processing; AML compliance |
| KYC Documents | Scanned copies of MyKad, passport, utility bills, source of funds declarations | KYC verification process |
| Technical Data | IP address, device type, browser type and version, operating system, session tokens | Automatically on Platform access |
| Gameplay Data | Bet history, game session logs, wagering patterns, win/loss records | During gameplay; continuously during account lifetime |
| Communication Data | Live chat transcripts, support ticket content, email correspondence | Customer support interactions |
| Preference Data | Responsible gaming settings, deposit limits, self-exclusion status, marketing opt-in/out | Account Settings configuration |
We do not collect sensitive personal data beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data.
3. How We Use Your Personal Data
91win88 processes your personal data for the following purposes:
- Account Administration: Creating and managing your 91win88 account, verifying your identity, and maintaining accurate account records.
- Service Delivery: Enabling access to casino games, sports betting, and all other Platform features; processing deposits and withdrawals to and from Malaysian payment channels.
- KYC and Regulatory Compliance: Verifying your age (21+) and identity as required by our licensing framework; conducting AML checks on financial transactions; complying with requests from regulatory or law enforcement authorities where legally required.
- Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent account activity, unauthorised access, and abuse of Platform systems.
- Responsible Gaming: Monitoring gameplay patterns to identify potential indicators of problem gambling behaviour; administering deposit limits, session reminders, and self-exclusion requests; maintaining records of self-excluded players to prevent re-registration.
- Customer Support: Responding to your enquiries, resolving disputes, and maintaining records of support interactions.
- Platform Improvement: Analysing aggregated, anonymised usage data to improve Platform performance, game selection, and user experience.
- Marketing (with consent): Sending promotional offers, bonus notifications, and product updates to players who have opted in to marketing communications. You may withdraw this consent at any time.
4. Legal Basis for Processing
91win88 processes your personal data on the following legal bases:
- Contractual Necessity: Processing necessary for the performance of your account agreement with 91win88, including account creation, gameplay, and payment processing.
- Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC, AML, and record-keeping requirements imposed by our licensing framework.
- Legitimate Interests: Processing for fraud prevention, Platform security, responsible gaming monitoring, and internal analytics, where these interests are not overridden by your privacy rights.
- Consent: Processing for marketing communications and non-essential cookies, where you have given explicit, withdrawable consent.
5. Data Sharing and Disclosure
91win88 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipient, strictly on a need-to-know basis and subject to appropriate data protection safeguards:
- Payment Processors: Touch n Go eWallet, Boost, GrabPay, Maybank, CIMB, and cryptocurrency settlement providers, to the extent necessary to process your deposits and withdrawals.
- Game Software Providers: Live dealer studio partners and slot game providers require transaction and gameplay data to operate the games you play and to resolve game disputes.
- KYC Verification Services: Third-party identity verification providers who assist in processing KYC documents and conducting AML screening.
- IT Infrastructure Providers: Cloud hosting, content delivery, and cybersecurity service providers operating under strict data processing agreements.
- Regulatory and Law Enforcement Authorities: Where we are legally required to disclose data to comply with applicable laws, court orders, or regulatory requests.
All third-party service providers engaged by 91win88 are contractually required to process your personal data only for the specified purpose, to maintain appropriate technical and organisational security measures, and to not further disclose your data to unauthorised parties.
6. Cookies and Tracking Technologies
The 91win88 Platform uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies we use are:
| Cookie Type | Purpose | Consent Required |
|---|---|---|
| Strictly Necessary | Session management, authentication tokens, security controls — essential for Platform operation | No |
| Functional | Remembering language preferences, game settings, and responsible gaming configurations | No |
| Analytics | Aggregated, anonymised usage data to understand how players navigate the Platform and identify performance issues | Yes |
| Marketing | Tracking promotional campaign performance to attribute registrations and deposits to specific channels | Yes |
You may manage your cookie preferences at any time through your browser settings. Disabling strictly necessary cookies will impair the functionality of your 91win88 session, including your ability to remain logged in.
7. Data Retention
91win88 retains your personal data for as long as your account remains active and for a period thereafter as required by applicable legal and regulatory obligations. The following general retention periods apply:
- Account and KYC Data: Retained for the duration of the account relationship plus a minimum of five (5) years following account closure, to comply with AML record-keeping requirements.
- Financial Transaction Records: Retained for a minimum of seven (7) years following the date of the transaction.
- Gameplay Logs: Retained for three (3) years following the relevant gaming session, or longer where required for dispute resolution or regulatory investigation.
- Self-Exclusion Records: Retained indefinitely to prevent re-registration during or after an exclusion period.
- Marketing Data: Retained until you withdraw consent or for a maximum of two (2) years from last active engagement with marketing communications, whichever is sooner.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to an identifiable individual.
8. Data Security
91win88 implements technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our key security controls include:
- TLS 1.3 encryption for all data in transit between your browser and the 91win88 Platform;
- AES-256 encryption for sensitive data at rest, including KYC documents and financial records;
- Bcrypt hashing with per-account salting for all stored passwords;
- Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
- Regular penetration testing and vulnerability assessments by independent security specialists;
- Intrusion detection systems and real-time security monitoring;
- Formal data breach response procedures with defined notification timelines.
While 91win88 employs industry-standard security measures, no online platform can guarantee absolute security. You play an important role in protecting your account by using a strong, unique password and enabling two-factor authentication via Account Settings.
9. Your Data Rights
As a 91win88 player, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us as described in Section 14.
Right of Access
You have the right to request a copy of the personal data 91win88 holds about you. We will provide a structured, commonly used, and machine-readable response within 30 days of a verified request.
Right to Rectification
If any personal data held by 91win88 is inaccurate or incomplete, you have the right to request correction. Identity data corrections may require re-submission of KYC documentation.
Right to Erasure
You may request deletion of your personal data. Note that this right is subject to our legal and regulatory obligations — we are required to retain certain financial and identity records for prescribed periods and cannot delete those prior to expiry of the mandatory retention period.
Right to Restrict Processing
You may request that we restrict processing of your data in certain circumstances, such as while a data accuracy dispute is under review.
Right to Data Portability
Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that your data be provided in a portable, machine-readable format.
Right to Withdraw Consent
Where processing is based on your consent (e.g., marketing communications, non-essential cookies), you may withdraw that consent at any time via Account Settings or by contacting support. Withdrawal does not affect the lawfulness of processing before withdrawal.
10. Minors
The 91win88 Platform is strictly prohibited to persons under the age of 21. We do not knowingly collect personal data from persons under 21. All registered accounts are required to complete KYC identity verification, which includes age verification, before withdrawal functionality is enabled.
If 91win88 becomes aware that personal data has been collected from a person under 21, that account will be immediately terminated, all deposits will be returned to the payment source, and all associated personal data will be securely deleted to the extent not required for regulatory reporting purposes. 21+
11. Third-Party Links
The 91win88 Platform may contain links to third-party sites or services — including payment processor portals and game provider interfaces — which operate under their own privacy policies. 91win88 is not responsible for the privacy practices of third-party sites and recommends that you review the applicable privacy policy before providing personal data to any third-party service.
12. Marketing Communications
91win88 will send you marketing communications — including bonus offers, promotional updates, and new product notifications — only where you have given explicit consent during registration or via Account Settings. Each marketing communication we send includes a clear, functional unsubscribe mechanism.
We do not send unsolicited marketing communications by SMS, WhatsApp, or telephone. If you receive a message claiming to be from 91win88 offering a promotion via a channel you did not opt in to, treat it as potentially fraudulent and contact us via the official support channel on the Platform.
13. Changes to This Privacy Policy
91win88 may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or Platform functionality. Material changes will be communicated to registered players by email and by a prominent notice on the Platform at least 14 days before taking effect. The effective date of the current version is displayed in the sidebar of this page.
Continued use of the Platform after the effective date of any revised Policy constitutes your acknowledgement of the changes. We encourage you to review this Policy periodically.
14. Contact Us
To exercise your data rights, submit a privacy-related query, or raise a concern about how 91win88 handles your personal data, please contact our data protection team:
91win88 Data Protection
Email: [email protected]
Subject line: Privacy Request – [Your Account Username]
Response time: Within 14 business days for data subject requests
Please note that to protect your privacy, we will need to verify your identity before processing any data subject request. You may be asked to confirm account details or provide a copy of identity documentation.