Privacy Policy luna99 — Your Data Security

1. Introduction & Scope of This Policy

Luna99 ("us", "Platform", or "luna99.fun") is deeply committed to protecting your privacy. This Privacy Policy applies to all users of our platform, including website visitors, registered users, and active members.

The scope of this policy covers all information we collect through luna99.fun, our mobile app, and any related services we provide. This policy clearly describes the types of data we collect, the purpose of collection, how it is stored, and your rights as a data owner.

If you disagree with any part of this policy, you are requested not to use our platform. If you have any questions or concerns, please contact us using the information provided at the end of this document.

2. Information We Collect

We collect various types of information depending on how you interact with the luna99 platform. Generally, the information collected falls into two main categories:

A. Information You Provide Directly

• Registration information: Full name, email address, phone number, date of birth, and username.
• Identity verification documents (KYC): National ID (MyKad), passport, driver's license, selfie with document, and proof of address.
• Financial information: Bank account number, digital wallet details (Touch 'n Go, GrabPay, Boost), and crypto wallet address (USDT).
• Communication information: Any messages, complaints, or enquiries you submit to our support team.
• Account preferences: Language settings, responsible gaming limits, and notification preferences you have registered.

B. Information Collected Automatically

• Technical data: IP address, web browser type, operating system, device model, and screen resolution.
• Usage data: Pages visited, time spent on the platform, games played, and bets placed.
• Location data: General geographic location based on IP address (not precise GPS location).
• Cookies and similar tracking technologies: Session data, preferences, and analytics information to enhance your user experience.
• Transaction logs: Records of all deposits, withdrawals, and wagering activity in your account.

3. Purposes of Data Use

The information we collect is used solely for lawful purposes related to the operation of the luna99 platform. We do not use your data for any purpose outside the scope stated below:

4. Use of Cookies & Tracking Technologies

The luna99 platform uses cookies and similar tracking technologies to enhance your experience, maintain login sessions, and analyse how users interact with our platform. Cookies are small text files stored on your device.

Types of Cookies We Use

• Essential cookies: Required for core platform functions such as login authentication and session security. These cookies cannot be disabled.
• Preference cookies: Saves your language settings, display theme, and personal preferences for a better experience.
• Analytics cookies: Helps us understand how users interact with the platform so we can make continuous improvements. This data is collected in aggregate and anonymized form.
• Security cookies: Used to detect suspicious activity, prevent fraud, and protect your account from unauthorised access.

You can control or delete cookies through your web browser settings. However, disabling essential cookies may affect platform functionality. For more information, refer to your web browser's documentation.

5. Data Sharing & Disclosure to Third Parties

Luna99 does not sell or rent your personal data. However, in certain limited situations, we may share your information with trusted third parties:

• Payment service providers: Transaction information is shared with payment processors (FPX, Touch 'n Go, GrabPay, Boost, and crypto processors) solely to facilitate transaction completion.
• Technology service providers: Technical infrastructure, cloud hosting, and analytics companies that help us operate the platform, subject to strict confidentiality agreements.
• Legal authority: We are required to disclose certain information upon receiving a lawful request from government authorities or law enforcement agencies in accordance with proper legal procedures.
• Regulatory body: In the context of gambling licence compliance and anti-money laundering, certain information may be required to be shared with the relevant regulatory authorities.
• Business transfers: In the event of a merger, acquisition, or sale of business assets, user data may be transferred as part of those business assets, with prior notice given to users.

6. Data Retention Period

Luna99 retains your personal data for as long as necessary to fulfil the purposes stated in this policy, or as required by law. Specific retention periods are as follows:

• Active account data: Retained for the duration your account is active and for an additional 7 years after account closure for AML and tax compliance purposes.
• Financial transaction records: Retained for a minimum of 7 years in accordance with anti-money laundering legal requirements.
• KYC Documents: Retained for 5 years after the business relationship ends or as required by law.
• Support communication logs: Retained for 2 years for quality control and dispute resolution purposes.
• Analytics data: Retained in anonymised form for a maximum of 2 years before being permanently deleted.

Once the retention period expires, your data will be securely deleted or anonymised in accordance with approved data deletion procedures. You may request early deletion of specific data subject to applicable legal requirements.

7. Data Security & Protection Measures

We implement comprehensive technical and organizational measures to protect your personal data from unauthorized access, loss, alteration, or unlawful disclosure:

• 256-bit SSL/TLS Encryption for all data communications between your browser and our servers.
• Data encryption at rest uses AES-256 for all sensitive data stored in our databases.
• Two-factor authentication (2FA) available and encouraged for all user accounts.
• Role-based access control — only staff with specific authorisation may access user data, and every access is audit-logged.
• Regular penetration testing by independent security experts to identify and patch system vulnerabilities.
• 24/7 security monitoring uses a sophisticated automated intrusion detection system.
• Security awareness training mandatory for all staff who handle user data.
• Incident response plan that has been tested and is ready to be activated in the event of any security breach.

While we take all reasonable steps to protect your data, no system is entirely free from risk. We encourage you to play your part in keeping your account secure by using a strong password, enabling 2FA, and never sharing your login credentials with anyone.

8. Your Rights as a Data Subject

As a luna99 platform user and data subject under applicable data protection laws, you have the following rights regarding your personal data:

To exercise any of the above rights, contact us via live chat or email at [email protected]. We will process your request within 30 calendar days. For complex cases, this period may be extended up to 60 days, with prior notification to you.

9. Cross-Border Data Transfers

In the course of our global operations, your personal data may be transferred to and stored on servers located outside Malaysia. All cross-border data transfers are carried out in compliance with applicable legal requirements and with a level of protection equivalent to that provided under this policy.

We ensure all international data transfers are safeguarded by appropriate mechanisms such as data processing agreements that comply with international standards, standard contractual clauses, or protection mechanisms recognized by the relevant authorities.

10. Children's Privacy

The luna99 platform is intended exclusively for adults aged 18 years and above. We do not knowingly collect, store, or process personal data from individuals under the age of 18. If we become aware that a child's data has been collected without valid parental or guardian consent, we will promptly delete that data and close the associated account.

If you believe that someone under the age of 18 has registered on our platform, please contact us immediately at [email protected] so that we can take appropriate action.

11. Links to Third-Party Websites

The luna99 platform may contain links to third-party websites or services for informational convenience. This Privacy Policy does not apply to those third-party websites or services. We are not responsible for the privacy practices of external websites and encourage you to read the privacy policy of each website you visit separately.

12. Changes to This Privacy Policy

Luna99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, new legal requirements, or platform improvements. Any significant changes will be communicated to you via:

• In-app or on-site notifications on luna99.
• Email to your registered address (for changes that materially affect your privacy rights).
• Pop-up notice upon login requiring your acknowledgment.

Date "Last Updated" at the top of this document will be updated whenever changes are made. Continued use of the luna99 platform after changes are published constitutes your acceptance of the updated policy. We encourage you to review this page periodically.

13. Contact Us

If you have any questions, concerns, or wish to exercise your privacy rights, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week via the luna99 platform.
• Response Time: We aim to respond to all privacy-related inquiries within 5 business days.

For complaints that cannot be resolved directly, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. We are committed to cooperating fully with any such investigation.