Privacy Policy

This Privacy Policy (hereinafter "Policy") is issued by S9Asia (hereinafter "S9Asia", "we", "us", or "our") and applies to all personal data collected, processed, stored, or transmitted in connection with your use of the S9Asia platform accessible at https://s9asia.cam, including all associated services, features, games, and communications made available thereon.

S9Asia is committed to protecting the privacy and personal data of all registered players and visitors. We operate in compliance with applicable international data protection standards and take our obligations as a data controller seriously. Our data handling practices are designed around principles of transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

This Policy should be read alongside our Terms & Conditions, which govern your use of the platform more broadly. In cases of conflict between this Policy and the Terms & Conditions on data-related matters, this Policy shall prevail.

If you have any questions about this Policy or about how your personal data is handled, please refer to the Contact section at the end of this document or reach out to our support team directly.

For the purposes of this Policy, the following terms shall have the meanings assigned below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to a name, identification number, location data, online identifier, or factors specific to the physical, physiological, economic, cultural, or social identity of that person.
• "Processing" means any operation or set of operations performed on personal data, whether by automated means or otherwise, including collection, recording, organisation, structuring, storage, adaptation, retrieval, use, disclosure, dissemination, restriction, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data. For all data collected via S9Asia, the Data Controller is S9Asia.
• "Data Processor" means a natural or legal person who processes personal data on behalf of the Data Controller under contractual arrangement.
• "Data Subject" means the natural person to whom personal data relates — in this context, the registered Player or visitor to S9Asia.
• "Consent" means any freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the processing of personal data relating to them.
• "KYC" means Know Your Customer — the identity and age verification process required under applicable regulatory obligations.

S9Asia acts as the Data Controller for all personal data collected through the platform at https://s9asia.cam. As Data Controller, S9Asia determines the purposes for which personal data is collected and the manner in which it is processed.

S9Asia operates under international online gaming licensing. The platform is not incorporated under Malaysian domestic law, nor does it operate under any Malaysian government-issued licence. However, S9Asia acknowledges Malaysian players as a significant part of its registered user base and applies data handling practices in accordance with internationally recognised standards.

Where S9Asia engages third-party service providers to assist in platform operations — including payment processors, identity verification services, game providers, and customer support systems — those providers act as Data Processors under contractual data processing agreements. They are prohibited from using player data for any purpose other than the contracted service.

S9Asia collects personal data in a number of ways — through account registration, ongoing platform use, KYC verification, payment transactions, customer support interactions, and automated technical collection. The categories of data collected are described in the table below:

S9Asia processes personal data only where a valid lawful basis exists. The primary lawful bases relied upon are as follows:

• Contractual Necessity: Processing required to perform the contract with you — including operating your account, processing deposits and withdrawals via methods such as Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, and cryptocurrency — and to provide the gaming services you have registered to access.
• Legal Obligation: Processing necessary to comply with applicable legal requirements, including anti-money laundering (AML) obligations, Know Your Customer (KYC) verification mandates, fraud prevention requirements, and applicable gaming licensing conditions.
• Legitimate Interests: Processing where S9Asia has a legitimate interest that is not overridden by your rights and interests, including platform security, fraud detection, responsible gambling monitoring, and internal analytics for service improvement.
• Consent: Processing based on your freely given, specific, informed consent — principally for direct marketing communications and for optional personalisation features. Consent may be withdrawn at any time without prejudice to prior processing.

S9Asia uses personal data for the following purposes, each underpinned by a lawful basis identified in Section 5:

6.1 Account Management

To create, maintain, and administer your registered account; to authenticate your identity upon login; to process account settings changes; to communicate important account-related notifications; and to manage account closure or suspension where applicable.

6.2 Payment Processing

To process deposits and withdrawals via your chosen payment method; to verify that payment accounts belong to you; to maintain transaction records for accounting and dispute resolution purposes; and to satisfy AML obligations in relation to fund movements.

6.3 KYC Compliance & Fraud Prevention

To verify your identity and age (minimum 21 years) before processing your first withdrawal or at any other time required under our compliance obligations; to detect, investigate, and prevent fraudulent, abusive, or otherwise unlawful activity on the platform; and to implement transaction monitoring systems required by applicable AML frameworks.

6.4 Service Delivery & Improvement

To deliver and operate the gaming services you have accessed; to diagnose and resolve technical issues; to monitor platform performance and stability; to develop and test new features; and to personalise your experience where you have consented to personalisation.

6.5 Responsible Gambling

To implement and monitor the responsible gambling tools you have configured (deposit limits, session reminders, self-exclusion); to identify patterns of usage that may indicate problem gambling and take appropriate action; and to provide information about support resources including Talian Kasih (15999) and other Malaysia-based support organisations where relevant.

6.6 Customer Support

To respond to your enquiries, complaints, and support requests; to maintain records of customer support interactions for quality assurance and audit purposes; and to escalate technical issues to the relevant operational teams.

6.7 Marketing (Consent-Dependent)

Where you have opted in to receive marketing communications, to send you information about S9Asia promotions, bonus offers, new game launches, and other relevant updates via email or platform notification. You may withdraw this consent at any time through your account settings or by contacting support.

S9Asia does not sell, rent, or trade your personal data to any third party for their independent commercial use. Personal data is shared only in the following circumstances and only to the extent necessary:

• Payment Processors: Financial data is shared with the payment service providers necessary to execute your transactions — including e-wallet operators (Touch 'n Go, Boost, GrabPay), banking FPX gateways, DuitNow network participants, and cryptocurrency processing services. These providers act as Data Processors under binding data processing agreements.
• Identity Verification Providers: Identity and verification data is shared with third-party KYC and AML screening service providers who assist in confirming your identity and assessing fraud risk. These providers are contractually restricted to processing data only for the stated verification purpose.
• Game Technology Providers: Certain usage data (such as game session data and bet history) may be shared with the technology providers whose games are integrated on the S9Asia platform, for purposes of game operation, dispute resolution, and RNG audit compliance.
• Customer Support Platforms: Support interaction data may be processed through third-party customer support software. All such providers are subject to data processing agreements and are prohibited from using support data for any purpose beyond service delivery.
• Legal & Regulatory Disclosure: S9Asia may be required to disclose personal data to regulatory bodies, law enforcement authorities, or courts in response to a lawful order, legal process, or regulatory enquiry. We will notify affected players of such disclosures where we are legally permitted to do so.
• Corporate Transactions: In the event of a merger, acquisition, or restructuring of S9Asia's business, personal data held by S9Asia may be transferred to the acquiring entity. Players will be notified of any such transfer and of any material changes to data handling practices that may result.

S9Asia operates internationally, and personal data collected from players in Malaysia and other jurisdictions may be transferred to, stored, or processed in countries outside Malaysia. Such countries may have data protection laws that differ from those in Malaysia.

Where personal data is transferred internationally, S9Asia takes appropriate safeguards to ensure that such transfers are conducted lawfully and that an adequate level of protection is maintained. These safeguards include contractual clauses obligating receiving parties to process data in a manner consistent with the standards set out in this Policy, and — where applicable — technical measures such as encryption of data in transit.

S9Asia retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, audit, or compliance obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of the account's active status and for a period of at least five (5) years following account closure, to satisfy AML record-keeping requirements and facilitate dispute resolution.
• Transaction Records: Financial transaction data is retained for a minimum of five (5) years following the date of the relevant transaction, in accordance with standard AML and financial record-keeping obligations.
• KYC Documentation: Identity verification documents are retained for a minimum of five (5) years following account closure or the last relevant transaction, whichever is later.
• Support Communications: Customer support interaction records are retained for a minimum of two (2) years for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Records of marketing consent (and withdrawal of consent) are retained for the duration of the account relationship and for three (3) years thereafter.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification. Where data is anonymised rather than deleted, it may be retained indefinitely for aggregated analytics and reporting purposes.

S9Asia implements and maintains a comprehensive set of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the S9Asia platform
• Encryption of sensitive data at rest within our database infrastructure
• Access controls restricting internal access to personal data on a need-to-know basis, with role-based permissions and audit logging
• Two-factor authentication (2FA) available to all registered players and enforced for all administrative access
• Regular penetration testing and security audits conducted by independent security specialists
• Intrusion detection and monitoring systems operating continuously across our infrastructure
• A documented incident response plan governing the identification, containment, and reporting of data security incidents

While S9Asia takes all reasonable precautions, no online system can provide an absolute guarantee of security. You are responsible for maintaining the confidentiality of your account credentials and for notifying S9Asia immediately if you suspect any unauthorised access to your account.

S9Asia uses cookies and similar tracking technologies (including web beacons and local storage) to operate the platform, maintain session continuity, analyse usage patterns, and — where consented — deliver personalised content and relevant promotional communications.

11.1 Categories of Cookies Used

• Strictly Necessary Cookies: Essential to the core operation of the platform, including maintaining your authenticated session, preventing cross-site request forgery, and enabling security features. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred display options, and responsible gambling tool configurations. Disabling these may affect your user experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate and interact with the platform. Used to identify usability issues and guide product improvements. These are activated only where consent has been obtained.
• Marketing Cookies: Used to track the effectiveness of promotional campaigns and to deliver relevant communications where you have opted into marketing. Activated only on the basis of your explicit consent.

11.2 Managing Cookies

You may manage your cookie preferences through your browser settings or through the cookie preference centre available on the S9Asia platform. Please note that disabling strictly necessary cookies may prevent you from accessing certain features of the platform. Your cookie preferences can be updated at any time.

As a Data Subject, you hold a number of rights in relation to the personal data S9Asia holds about you. These rights are described below. To exercise any of these rights, please contact our support team using the details in Section 16. S9Asia will respond to valid requests within thirty (30) calendar days, or notify you if additional time is required.

S9Asia may send you communications about promotions, bonuses, new games, and other S9Asia services where you have expressly opted in to receive such communications at registration or subsequently through your account settings.

Marketing communications will not be sent to players who have not provided explicit consent, who have withdrawn consent, or who are subject to an active self-exclusion restriction. Where a player activates self-exclusion, all marketing communications will cease immediately.

You may opt out of marketing communications at any time by updating your preferences in account settings or by submitting a request to our support team. Opt-out requests will be processed within five (5) business days. Operational communications (such as account notifications, security alerts, and transaction confirmations) will continue regardless of marketing preferences, as these are necessary for the provision of services.

S9Asia does not knowingly collect or process personal data from any person under the age of 21. Our platform is strictly restricted to adults aged 21 and above. All account registrations are subject to age verification through the KYC process.

If S9Asia becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete such data and close the associated account. If you have reason to believe that a minor has registered on S9Asia using false information, please notify our support team immediately at [email protected].

S9Asia reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, operational practices, or our data processing activities. The date of the most recent revision is displayed prominently on this page.

Where amendments are material — meaning they substantively affect your rights or the way in which your personal data is processed — S9Asia will notify registered players via email or platform notification at least seven (7) calendar days before the changes take effect. Non-material amendments (such as corrections to typographical errors or minor clarifications that do not change the substance of any provision) may take effect immediately upon publication.

Your continued use of S9Asia following notification of any amendment constitutes your acknowledgment and acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using the platform and request account closure prior to the effective date of the amendment.

If you wish to exercise any of your data rights, raise a concern about S9Asia's data practices, request a copy of this Policy in an alternative format, or ask any question about how your personal data is handled, please contact our dedicated support team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week — including all Malaysian public holidays. Access the live chat widget directly on the S9Asia platform for the fastest response.
• Email: [email protected] — all data rights requests submitted by email will receive an acknowledgment within two (2) business days and a substantive response within thirty (30) calendar days.

When submitting a data rights request, please include sufficient information to identify your account (such as your registered email address and full name) and clearly state the nature of your request. Identity verification may be required before your request is processed.