ClubMY APK Privacy Policy – Personal Data Protection for Malaysian Members

This Privacy Policy explains how ClubMY APK ("clubmy apk", "we", "the platform") collects, uses, stores, and protects your personal information when you use our services — including our website, Android (APK) and iOS mobile applications, and all related services we offer to members in Malaysia.

We wrote this policy in plain language because we believe you deserve to know exactly what happens with your personal data. If you have any questions after reading this document, the clubmy apk support team is available via live chat 24/7.

1Introduction & Scope of This Policy

This Privacy Policy applies to all personal information collected by clubmy apk from individuals who register as members, visit our platform, or interact with any of our services. It also applies to individuals who are in the process of registering but have not yet completed the registration.

Clubmy apk operates as an online entertainment platform offering live casino games (Blackjack, Baccarat, Roulette, Poker), slots, Sports Betting (Malaysia Super League and EPL football, Badminton, e-sports), and other games to adult users in Malaysia. In running these operations, we need to collect and process certain personal data for legitimate and necessary purposes.

By using the clubmy apk platform, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the platform and contact us to request deletion of your account and data.

2Types of Personal Data We Collect

Clubmy apk collects various types of personal data depending on how you interact with our platform. The categories of data we collect are as follows:

• Identity Information: Full name as it appears on official identification documents (Malaysian identity card or passport), date of birth, gender, and nationality.
• Contact Information: An active Malaysian mobile number, email address, and residential address if required for KYC verification.
• Financial Information: Bank account or e-wallet details used for deposits and withdrawals (including DuitNow, Touch 'n Go eWallet, FPX, GrabPay, Boost and ShopeePay), deposit and withdrawal transaction history, and current account balance.
• Gaming Information: Gaming history, game types played, bet amounts, wins and losses, and session duration.
• Technical Information: IP address, device type, operating system, web browser used, login data, and platform activity logs.
• Verification Documents: A digital copy of your Malaysian identity card, passport, bank statement, or other documents required for KYC and identity verification.
• Communication Information: Records of conversations with the clubmy apk support team via live chat or email, including the content of complaints and enquiries.

3How We Collect Your Personal Data

Clubmy apk collects your personal data through a number of different channels throughout your interactions with our platform:

• Directly from You: During new account registration, during the KYC process, when you submit a complaint or enquiry to support, and when you fill in any form within the clubmy apk platform.
• Automatically: When you access the clubmy apk platform, our systems automatically record technical information such as your IP address, device type, web browser, and session data. This is industry-standard practice and is carried out for security and service improvement purposes.
• Via Cookies and Similar Technologies: The clubmy apk platform uses cookies and similar tracking technologies to enhance the user experience, remember your preferences, and analyse usage patterns. Further details are set out in Section 8.
• Via Authorised Third Parties: In certain cases, such as during enhanced identity verification, clubmy apk may receive information from third-party KYC service providers we have engaged to support a safer and more efficient verification process.

4How We Use Your Personal Data

Clubmy apk uses the personal data it collects for purposes that are lawful and necessary in the context of operating an online casino platform in Malaysia. The primary purposes are:

• Account Management: To create, verify, and manage your clubmy apk member account, including secure login processes and password management.
• Service Provision: To enable you to access and use all games and services available on clubmy apk, including the processing of deposits and withdrawals.
• Identity Verification (KYC): To verify your identity in compliance with Anti-Money Laundering (AML) legal requirements and to ensure adherence to the 21-year age restriction.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, in-game collusion, and violations of clubmy apk's terms of use.
• Customer Support: To process and respond to enquiries, complaints, and requests for assistance submitted to the clubmy apk support team.
• Communications: To send you important information regarding your account, changes to our terms of service, security updates, and (with your consent) clubmy apk promotions and bonus offers.
• Responsible Gaming: To monitor gameplay patterns in order to identify members who may need responsible gambling support and to enforce limits set by members themselves.
• Legal Compliance: To fulfil legal obligations under Malaysia's Personal Data Protection Act 2010 (PDPA), AML requirements, and any directives received from the relevant authorities.
• Platform Improvements: To analyse usage patterns on an aggregate (not individual) basis in order to improve the design, performance, and features of the clubmy apk platform.

5Data Sharing with Third Parties

Clubmy apk does not sell, rent, or trade member personal data to any third party for commercial purposes. However, there are limited situations where we need to share data with certain parties to carry out legitimate operations:

• Payment Service Providers: Payment processors handling DuitNow, Touch 'n Go eWallet, FPX (Maybank2u, CIMB Clicks), GrabPay, Boost, and ShopeePay transactions receive only the minimum transaction information required to process your payment. These providers are bound by strict confidentiality agreements with clubmy apk.
• KYC Service Provider: Third-party identity verification companies we engage to assist with the verification process for new clubmy apk members. They only receive the data necessary for verification purposes and are not permitted to use it for any other purpose.
• Game Providers: Live game studios and game software providers working with clubmy apk may receive the session data necessary to deliver their services. No full identity information is shared unless there is a demonstrable technical requirement.
• Legal Authorities: clubmy apk will disclose personal data to Malaysian law enforcement authorities, regulatory bodies, or courts if required by law or a valid court order. We will inform you of any such disclosure where the law permits us to do so.

6Data Security Measures

Clubmy apk invests seriously in security infrastructure to protect the personal data of all members. The security measures we have in place include:

• Transmission Encryption: All communications between your device and clubmy apk's servers are secured with TLS 1.3 protocol and 256-bit SSL encryption — the same standard used by world-class financial institutions.
• Storage Encryption: Sensitive personal data stored in the clubmy apk database is encrypted at rest using strong encryption algorithms. Member passwords are never stored in plain text — they are hashed using a one-way, irreversible hashing method.
• Access Controls: A role-based access control (RBAC) system ensures that only staff who require access to specific data in order to perform their duties are able to do so. All access is logged and audited on a regular basis.
• Two-Factor Authentication: clubmy apk's internal systems require multi-factor authentication for all staff access. We also offer 2FA to members for additional account security.
• 24/7 Security Monitoring: Continuous security monitoring detects and responds to threats or anomalies in real time, around the clock, every day of the year.
• Regular Security Testing: clubmy apk conducts regular penetration testing and security audits carried out by independent security experts to identify and address vulnerabilities before they can be exploited.

While we take all reasonable steps to protect your data, no system can be guaranteed 100% secure against all cyber threats. We encourage members to take their own protective measures as well, such as using strong passwords, enabling 2FA, and not sharing login credentials.

7Data Retention Period

Clubmy apk does not retain your personal data longer than necessary. Retention periods depend on the type of data and applicable legal requirements:

• Active Account Data: Retained for as long as your clubmy apk account remains active, plus any additional period required by law following account closure.
• Financial Transaction Records: Retained for a minimum of seven (7) years from the transaction date, in accordance with Malaysia's Anti-Money Laundering Act and applicable accounting requirements.
• Gaming Activity Logs: Retained for five (5) years for the purposes of dispute resolution, auditing, and compliance.
• Support Communication Records: Retained for three (3) years from the date of last interaction.
• KYC Documents: Retained for seven (7) years following account closure, in accordance with Malaysia's AML requirements.
• Technical Log Data: Retained for 90 days for security and debugging purposes, then automatically deleted.

Once the required retention period has expired, clubmy apk will securely and irreversibly delete or anonymise the relevant data, unless a legal or regulatory obligation prevents such deletion.

8Cookies & Tracking Technologies

The clubmy apk platform uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions correctly. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functionality such as login, session verification, and security. These cookies cannot be disabled without significantly affecting the functionality of the clubmy apk platform.
• Performance Cookies: Collecting information about how you use the platform — which pages you visit most frequently, how long you spend on them, and any errors that may occur. This data is used to improve clubmy apk's performance and is gathered in aggregate form without identifying you individually.
• Functional Cookies: Stores your preferences — such as language, display settings, and other options — to improve your experience on the clubmy apk platform across future sessions.

You can manage or disable cookies through your web browser settings. However, disabling certain cookies may affect the functionality of the clubmy apk platform. Please refer to your browser's help documentation for further guidance on managing cookies.

9Your Rights Regarding Personal Data

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and clubmy apk's internal policies, you have the following rights with respect to your personal data:

• Right of Access: You have the right to request and receive a copy of the personal data we hold about you. Such requests will be processed within 14 business days.
• Right to Rectification: If you find that any information we hold about you is inaccurate or out of date, you have the right to request a correction. You may also update certain details directly through your clubmy apk account profile page.
• Right to Erasure: Under certain circumstances, you have the right to request deletion of your personal data from clubmy apk's systems. Please note that some data may need to be retained for periods required by Malaysian law.
• Right to Object to Processing: You have the right to object to the processing of your personal data for direct marketing purposes. You may opt out of clubmy apk marketing communications at any time via the unsubscribe link in any email or by contacting us directly.
• Right to Restrict Processing: In certain circumstances — such as when you dispute the accuracy of your data or object to its processing — you may request that we restrict how we use your data while the matter is being resolved.
• Right to Data Portability: You have the right to receive the personal data you have provided to us in a machine-readable format for the purpose of transferring it to another service provider, where applicable.

To exercise any of the rights above, please contact the clubmy apk data protection team by email at support@clubmyapk.com or via the in-platform live chat. Please provide sufficient identification to allow us to verify your identity before processing your request.

10Special Protection for Minors

The clubmy apk platform is intended for adults aged 21 and above only. We do not knowingly collect or process personal data from individuals under the age of 21. Our age verification system is designed to prevent underage registration.

Should clubmy apk discover that personal data belonging to a minor has been collected inadvertently, we will take immediate action to delete that data and close the account in question. Parents or guardians who suspect their child has registered an account with clubmy apk are encouraged to contact us promptly at support@clubmyapk.com so that appropriate action can be taken.

11Data Transfers Outside Malaysia

In the course of operating the clubmy apk platform, your personal data may be processed or stored outside Malaysia — for example, through cloud computing service providers or international game providers we work with.

In all such cases, clubmy apk ensures that:

• Data transfers only take place to countries or entities that provide a level of data protection equivalent to or greater than what is required under Malaysia's PDPA.
• A comprehensive, legally binding data processing agreement exists between clubmy apk and all recipient parties outside Malaysia.
• Data transfers are limited to the minimum necessary for the stated service purpose and may not be used by the recipient for any other purpose.

12Changes to This Privacy Policy

Clubmy apk reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, the technologies we use, applicable legal requirements, or other legitimate operational reasons.

When we make material changes to this Privacy Policy, we will notify you through:

• A prominent in-platform notification displayed when you next log in after the changes take effect.
• An email sent to the address you registered with clubmy apk, at least 7 days before any significant changes take effect.
• The "Last Updated" date at the top of this document will be updated for all changes, regardless of their magnitude.

We encourage you to review this Privacy Policy periodically. Continued use of the clubmy apk platform after any changes take effect will be considered acceptance of the updated terms.

13Contact Us About Data Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or the way clubmy apk handles your personal data, please contact us through:

• Live Chat: The fastest option — available 24/7 via the chat icon within the clubmy apk platform. Average response time is under 3 minutes.
• Email: support@clubmyapk.com — for formal data rights requests, please include "Data Privacy Request" in your email subject line. We respond within 2 business days.

This Privacy Policy is governed by and interpreted in accordance with the laws of Malaysia, in particular the Personal Data Protection Act 2010 (PDPA) and the regulations made thereunder. Any disputes arising in connection with this Privacy Policy shall be resolved through the mechanisms provided under applicable Malaysian law.