Privacy Policy — turbo99

This Privacy Policy ("Policy") is issued by turbo99 ("the Platform", "we", "us", or "our") and applies to all personal data collected from users ("you", "the Player", or "the User") through the turbo99 website at https://turbo99.cam, including all sub-pages, features, and associated services made available therein.

turbo99 is committed to processing personal data in a transparent, fair, and lawful manner, in accordance with applicable data protection legislation and the standards required under our international operating licence. This Policy sets out what personal data we collect, the purposes for which it is processed, the legal bases upon which we rely, and how we protect that data.

By registering an Account on turbo99 or by continuing to use the Platform after being presented with this Policy, you acknowledge that you have read and understood its contents. This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy.

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

turbo99 collects personal data across several categories depending on the nature of your interaction with the Platform. The categories and examples of data collected are set out below:

turbo99 collects personal data through the following means:

• Direct submission: Data you provide when creating an Account, completing KYC verification, making a deposit or withdrawal request, contacting support, or completing any form on the Platform.
• Automated technical collection: Data collected automatically when you access the Platform, including IP addresses, device identifiers, session data, and browser information gathered via server logs and cookies (see Section 10).
• Third-party data processors: Identity and document verification data returned by our KYC service providers following verification checks you initiate. Transaction confirmation data returned by payment processors including Touch 'n Go, Boost, GrabPay, DuitNow, FPX, and participating Malaysian banks.
• Fraud prevention and AML screening: Data returned from screening services used to check for sanctions list matches, politically exposed person (PEP) status, and adverse media.

turbo99 processes your personal data for the following specific purposes:

• Account creation and management: To register your Account, authenticate your identity, maintain your account settings, and manage your gaming preferences.
• Age and identity verification (KYC): To confirm that you meet the minimum age requirement of 21 years and to verify your identity in accordance with our licensing obligations before processing withdrawals.
• Payment processing: To process MYR deposits and withdrawals via your chosen payment method, to reconcile transactions, and to maintain financial records.
• Regulatory and AML compliance: To monitor transactions and account activity for money laundering, fraud, and sanctions risks as required under our international licensing obligations and applicable AML regulations.
• Responsible gambling programme: To administer deposit limits, self-exclusion requests, and player protection tools, and to identify patterns of play that may indicate gambling harm requiring intervention.
• Customer support: To respond to enquiries, resolve complaints, and manage account disputes.
• Platform improvement: To analyse usage patterns (in aggregated and anonymised form where possible) to improve the Platform's functionality, performance, and user experience.
• Marketing communications: To send you promotional offers, bonuses, and news about turbo99 where you have provided consent or where we have a legitimate interest — subject to your right to opt out at any time.
• Security: To detect, investigate, and prevent fraud, account takeover, bot activity, and other prohibited conduct as defined in our Terms and Conditions.

turbo99 relies on the following legal bases to process your personal data, depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between you and turbo99 — including Account registration, payment processing, KYC verification, and customer support.
• Legal obligation: Processing required to comply with applicable legal and regulatory obligations, including AML obligations, licensing conditions, and lawful requests from regulatory authorities.
• Legitimate interests: Processing necessary for turbo99's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, responsible gambling monitoring, and marketing to existing account holders.
• Consent: Where we rely on your consent — for example, for certain marketing communications — you may withdraw consent at any time by contacting support or updating your Account preferences. Withdrawal of consent does not affect the lawfulness of processing prior to the withdrawal.

turbo99 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the following strictly defined circumstances:

• Payment processors: Data shared with Malaysian payment partners — including Touch 'n Go eWallet operators, DuitNow/FPX infrastructure providers, and participating banks such as Maybank, CIMB, Public Bank, Hong Leong, and RHB — solely to process your deposit and withdrawal transactions.
• KYC and identity verification providers: Identity document data and biometric liveness-check data shared with licensed third-party verification services for the sole purpose of confirming your identity and age.
• Fraud prevention and AML screening services: Transactional and identity data shared with screening providers to fulfil our regulatory obligations under our international licence conditions.
• Regulatory and law enforcement authorities: Personal data disclosed in response to a valid legal order, regulatory request, or law enforcement obligation in the jurisdiction where turbo99 holds its operating licence.
• Group and affiliated entities: Personal data may be shared with affiliated companies within the turbo99 corporate group for internal administrative and compliance purposes, subject to equivalent data protection standards.

All third-party Data Processors are required to handle your personal data in accordance with contractual obligations that reflect the standards of this Privacy Policy and applicable data protection law.

turbo99 operates under an international licence and its technical infrastructure, data processors, and service providers may be located in jurisdictions outside Malaysia. Personal data collected from Malaysian players may therefore be transferred to and processed in countries other than Malaysia.

Where such transfers occur, turbo99 takes steps to ensure that your personal data receives an adequate level of protection consistent with the standards described in this Policy. This includes entering into data processing agreements with applicable contractual protections where required.

turbo99 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements.

• Active accounts: Personal data is retained for the full duration of your Account's active status.
• Closed accounts: Following Account closure — whether voluntary or by Platform action — personal data (including financial records, KYC documentation, and transaction history) is retained for a minimum of five (5) years to satisfy AML, regulatory, and licensing obligations.
• Marketing data: Where consent was provided for marketing communications, related data is retained until consent is withdrawn or until the end of the statutory retention period, whichever is later.
• Support communications: Chat transcripts and email correspondence are retained for a period of three (3) years following the resolution of the relevant query.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

turbo99 uses cookies and similar tracking technologies on the Platform to support essential functionality, analyse usage, and in some cases to deliver relevant marketing communications. The types of cookies we use are described below:

You may configure your browser to refuse or delete cookies. Note that disabling strictly necessary cookies will impair core Platform functionality, including the ability to log in or process payments. turbo99 does not respond to browser "Do Not Track" signals at this time.

Subject to applicable law and any overriding legal obligations (including our AML and licensing retention requirements), you hold the following rights in relation to your personal data held by turbo99:

To exercise any of the above rights, please contact our support team as described in Section 16. We will respond to verifiable requests within 30 days. We may need to verify your identity before acting on a request. Some requests may be subject to a fee where manifestly unfounded or excessive.

turbo99 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption applied to all data in transit between your browser and turbo99's servers.
• Encryption at rest for sensitive stored data including KYC documentation, financial records, and authentication credentials.
• Two-factor authentication (2FA) available to all Account holders as an optional additional layer of login security.
• Access control policies restricting internal access to personal data on a strict need-to-know basis, with role-based permissions and audit logging of data access events.
• Regular security assessments including penetration testing and vulnerability scanning of Platform infrastructure.
• Incident response procedures enabling detection and notification of personal data breaches in accordance with applicable regulatory obligations.

While turbo99 takes all reasonable precautions to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, and you use the Platform at your own risk in this regard. If you become aware of any security vulnerability or unauthorised access to your Account, please notify us immediately via live chat or at [email protected].

turbo99 does not knowingly collect personal data from any person under the age of 21. The Platform is strictly intended for adults aged 21 and above, consistent with the minimum age requirements applicable under our international operating licence.

Any Account found to belong to a person under 21 years of age will be immediately closed upon discovery, all associated funds including winnings will be forfeited, and the personal data associated with the Account will be deleted from active records subject to any mandatory retention obligations under AML regulations.

The turbo99 Platform does not contain links to external third-party websites as a matter of policy. In the event that links to third-party content are made available in specific contexts (such as within game interfaces provided by third-party studio operators), turbo99 has no control over and accepts no responsibility for the privacy practices of those third parties.

We encourage you to review the privacy policy of any third-party operator whose services you access in connection with, but separately from, the turbo99 Platform.

turbo99 reserves the right to update or amend this Privacy Policy at any time. Material changes to the Policy will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before the effective date, where reasonably practicable.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. The "Last Updated" date at the top of this page reflects when the most recent revision was made. We encourage you to review this Policy periodically to stay informed of how turbo99 processes your personal data.

For any questions, concerns, or formal requests relating to this Privacy Policy or the processing of your personal data by turbo99, please contact us through the following channels:

• Live Chat: Available 24/7 via the chat icon on the Platform. Please mention "Privacy" or "Data Request" in your opening message.
• Email: [email protected] — for formal written data subject requests, please include your full name, Account username, and a description of your request. We will acknowledge receipt within 48 hours and respond in full within 30 days.

turbo99 takes all privacy concerns seriously. If you are dissatisfied with our response to your query or request, you may escalate your complaint to the data protection supervisory authority in the jurisdiction where turbo99 holds its operating licence.