lembu99 Privacy Policy

This Privacy Policy applies to lembu99 ("we", "us", "our"), the operator of the online gaming platform accessible at lembu99.club. lembu99 is an international online gaming platform operating under an international gaming licence.

This Policy applies to all personal data collected from individuals who visit lembu99.club, register a Member account, place bets or wagers, contact our support team, or otherwise interact with lembu99's services ("you", "your", "Member"). It governs our practices across all access methods including desktop browsers, mobile browsers, and any future lembu99-branded applications.

By accessing lembu99.club or creating an account, you acknowledge that you have read, understood, and agreed to the collection and use of your personal data as described in this Policy. If you do not agree, please discontinue use of the platform immediately.

lembu99 collects personal data that is necessary and proportionate to the provision of its licensed gaming services and the fulfilment of applicable legal and regulatory obligations. The categories of data we may collect include:

1. Identity Data: Full legal name, date of birth, gender, and nationality as provided during registration or KYC verification.
2. Contact Data: Email address, mobile telephone number, and residential or correspondence address (e.g., Kuala Lumpur, Penang, Johor Bahru, or any location provided).
3. Identity Verification Documents: Government-issued photo identification (e.g., Malaysian MyKad or passport), proof of address documents, and source-of-funds documentation where required by compliance obligations.
4. Financial Data: Payment method details (e.g., registered Touch 'n Go eWallet account reference, FPX bank account identifiers), transaction history, deposit and withdrawal records.
5. Technical Data: IP address, device identifiers, browser type and version, operating system, session timestamps, and access logs.
6. Usage Data: Game activity records, betting history, wagering patterns, bonus usage, and account activity logs.
7. Communications Data: Records of live chat conversations, email correspondence, and support ticket contents.
8. Responsible Gaming Data: Self-imposed limits, self-exclusion requests, and any disclosures made in connection with responsible gaming support.

lembu99 does not knowingly collect personal data from individuals under the age of 21. If we become aware that data has been collected from a person under 21, that data will be deleted and the associated account closed.

lembu99 uses the personal data it collects for the following purposes:

1. To create, maintain, and administer your lembu99 Member account;
2. To verify your identity and age (21+) in accordance with our legal and regulatory obligations, including anti-money laundering ("AML") and know-your-customer ("KYC") requirements;
3. To process deposits, withdrawals, and all financial transactions in MYR;
4. To provide customer support via live chat and email;
5. To enforce our Terms & Conditions, including investigating suspected fraud, collusion, or prohibited conduct;
6. To administer bonuses, promotions, and loyalty programmes;
7. To send transactional communications (account notifications, security alerts, deposit confirmations, withdrawal receipts) — these are not optional as they are necessary for the provision of the service;
8. To send marketing communications where you have provided explicit consent, and to manage opt-out requests;
9. To monitor and improve platform performance, security, and game integrity;
10. To fulfil our responsible gaming obligations, including monitoring for signs of problem gambling behaviour and administering self-exclusion requests.

lembu99 processes your personal data on one or more of the following legal bases:

1. Contractual Necessity: Processing necessary to provide the gaming services you have requested and to fulfil our obligations under the Member Agreement;
2. Legal Obligation: Processing required to comply with applicable AML, KYC, licensing, and regulatory requirements imposed by our gaming licence authority;
3. Legitimate Interests: Processing necessary to prevent fraud, maintain platform security, and enforce our Terms & Conditions, where such interests are not overridden by your rights;
4. Consent: Processing for marketing communications, where you have provided freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time by contacting support.

lembu99.club uses cookies and similar tracking technologies to operate the platform, maintain your logged-in session, remember your preferences, and analyse site performance. The following categories of cookies are used:

1. Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens that keep you logged in to your lembu99 account. These cannot be disabled without breaking core platform functionality.
2. Functional Cookies: Remember your preferences (e.g., language, previously played games) to improve your experience.
3. Analytics Cookies: Collect aggregated, anonymised data about how Members interact with the platform to help us improve performance and content.

You may configure your browser to block or delete cookies; however, doing so may impair your ability to log in to your lembu99 account or access certain features. By continuing to use lembu99.club, you consent to our use of strictly necessary cookies.

lembu99 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients solely to the extent necessary:

1. Payment Processors: Including operators of Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and USDT TRC20 rails, to process deposits and withdrawals;
2. Identity Verification Services: Third-party KYC and AML compliance providers engaged to verify Member identity and age;
3. Game Providers: Software providers whose certified games are made available through the lembu99 platform, where game-level activity data is necessary for RNG certification and audit purposes;
4. Regulatory & Legal Authorities: Our gaming licence authority and, where legally required, law enforcement agencies, financial intelligence units, or courts;
5. Infrastructure & Security Providers: Cloud hosting, CDN, and cybersecurity service providers operating under appropriate data processing agreements.

All third-party recipients are contractually required to handle your data in accordance with applicable data protection standards and to use it only for the specified purpose.

lembu99 retains personal data for as long as is necessary for the purposes described in this Policy, and in any event for the minimum retention periods required by our gaming licence authority and applicable AML regulations. In practice, this means:

1. Account data and transaction records are retained for a minimum of five (5) years from the date of the last transaction or account closure, whichever is later;
2. KYC and identity verification documents are retained for the period required by our regulatory obligations, typically five (5) years from account closure;
3. Communications data is retained for two (2) years from the date of the communication unless a longer period is required for an ongoing dispute or investigation;
4. Marketing consent records are retained for the duration of your membership and for a further two (2) years after account closure.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised.

lembu99 implements industry-standard technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

1. 256-bit SSL/TLS encryption for all data transmitted between your device and lembu99's servers;
2. Salted cryptographic hashing of stored passwords — your raw password is never stored or accessible;
3. Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
4. Regular internal security reviews and penetration testing;
5. Two-factor authentication available for all Member accounts.

Despite these measures, no internet-based platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights, lembu99 will notify affected Members and, where required, the relevant supervisory authority, without undue delay.

Subject to applicable law and the limitations imposed by our regulatory obligations, you have the following rights in relation to your personal data held by lembu99:

1. Right of Access: You may request a copy of the personal data lembu99 holds about you;
2. Right to Rectification: You may request correction of inaccurate or incomplete personal data;
3. Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations;
4. Right to Restriction: You may request that we restrict processing of your data in certain circumstances;
5. Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes;
6. Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact the lembu99 support team via live chat or by email at [email protected]. We will respond to verified requests within thirty (30) days. Note that certain rights may be limited where the data is required for compliance with our legal obligations.

All data protection enquiries, requests to exercise your rights, and concerns about this Privacy Policy should be directed to the lembu99 Data Protection contact via live chat or at [email protected]. Please include "Privacy" in the subject line of any email enquiry.

lembu99 reserves the right to amend this Privacy Policy at any time. Material amendments will be communicated to active Members via account notification or email. The version of this Policy published on lembu99.club at the time of any relevant event is the governing version. We encourage you to review this Policy periodically.

This Policy was last reviewed and updated on 12 June 2026.