Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by fly99 ("fly99", "we", "us", "our") and applies to all personal data collected and processed in connection with your use of the fly99 online casino and sports betting platform accessible at https://fly99.casa (the "Platform") and any associated services.

fly99 is committed to processing personal data responsibly, transparently, and in compliance with applicable data protection laws. This Policy explains the categories of personal data we collect, the purposes for which we process that data, the legal bases on which we rely, and the rights available to you in relation to your personal data.

By creating an Account and using the Platform, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read together with our Terms & Conditions, which govern your use of the Platform generally. If you do not agree to the practices described in this Policy, you must cease using the Platform immediately.

2. Definitions

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

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, either directly or in combination with other available data.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, storage, retrieval, use, disclosure, or deletion.
• "Data Controller" means fly99, the entity that determines the purposes and means of Processing Personal Data obtained through the Platform.
• "Data Subject" means the identified or identifiable natural person to whom Personal Data relates — in the context of this Policy, a registered Player of fly99.
• "Consent" means any freely given, specific, informed, and unambiguous indication of your agreement to the Processing of your Personal Data for a stated purpose.
• "KYC" means Know Your Customer — the identity and address verification procedures required under applicable anti-money laundering (AML) regulations.
• "Third Party" means any natural or legal person other than fly99 and the Player to whom Personal Data is disclosed or transferred.
• "Cookies" means small text files placed on your device by the Platform for the purposes of session management, analytics, and personalisation.

3. Personal Data We Collect

fly99 collects the following categories of Personal Data from Players and prospective Players:

3.1 Identity & Contact Data

• Full legal name and preferred display name
• Date of birth and gender
• Residential address (including city, postcode, and country)
• Email address and mobile telephone number
• Government-issued identification document details (e.g., Malaysian National Identity Card / MyKad number, passport number) — collected as part of KYC verification

3.2 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts in MYR, timestamps, and payment reference numbers
• Payment method identifiers (e.g., Touch 'n Go eWallet account ID, Boost wallet identifier, bank account numbers used with Maybank, CIMB, Public Bank, or other FPX-participating banks)
• Cryptocurrency wallet addresses used for BTC, ETH, USDT, or BNB deposits
• Account balance history and transaction logs

3.3 Gaming & Betting Activity Data

• Wager history, game sessions, and betting market selections (including Liga Super Malaysia, EPL, and other sports markets)
• Casino game play records, bet amounts, and outcomes
• Responsible gambling settings, including any self-imposed deposit limits, session limits, or self-exclusion periods

3.4 Technical & Usage Data

• IP address and approximate geographic location derived therefrom
• Device type, operating system, browser type and version
• Login timestamps, session durations, and navigation patterns within the Platform
• Cookie identifiers and similar tracking technology data (see Section 8)

3.5 Communications Data

• Records of your correspondence with our customer support team via live chat, email, or other channels
• Feedback, complaints, and survey responses submitted to fly99

4. How We Collect Your Data

fly99 collects Personal Data through the following means:

• Account Registration: You provide identity, contact, and other information when you create an Account on the Platform.
• KYC Verification: You submit identity documents and other verification materials in response to our KYC requests.
• Payment Transactions: Transaction data is generated automatically when you make a deposit or withdrawal using supported payment methods.
• Platform Interaction: Technical and usage data is collected automatically through cookies, server logs, and analytics tools as you navigate and use the Platform.
• Customer Support: Data is collected when you contact our support team by any channel.
• Third-Party Verification Providers: We may receive identity verification data from third-party KYC and fraud prevention service providers engaged to assist with our compliance obligations.

5. Data Processing & Legal Basis

fly99 processes Personal Data on the following legal bases:

Processing Purpose	Legal Basis
Account registration and management	Performance of a contract with you
Processing deposits and withdrawals	Performance of a contract with you
KYC / identity verification	Legal obligation (AML / counter-terrorism financing regulations)
Fraud detection and prevention	Legitimate interests of fly99
Responsible gambling monitoring and intervention	Legitimate interests / legal obligation
Customer support communications	Performance of a contract / legitimate interests
Promotional and marketing communications	Consent (where required) / legitimate interests
Platform analytics and improvement	Legitimate interests of fly99
Compliance with regulatory and legal obligations	Legal obligation

6. How We Use Your Personal Data

fly99 uses collected Personal Data for the following purposes:

• To create, administer, and maintain your Account on the Platform
• To process MYR-denominated deposits and withdrawals via Touch 'n Go eWallet, DuitNow, FPX, and other supported methods
• To conduct KYC verification and comply with anti-money laundering (AML) and counter-terrorism financing obligations
• To detect, investigate, and prevent fraudulent activity, account takeover, and other security incidents
• To monitor gaming activity for responsible gambling purposes and to enforce self-exclusion requests
• To send transactional communications (account confirmations, withdrawal notifications, security alerts)
• To send promotional communications about fly99 offers, bonuses, and seasonal promotions (including Hari Raya specials and VIP programme updates), where you have opted in to receive such communications
• To personalise your experience on the Platform, including game recommendations and promotional offers
• To conduct analytics and improve the Platform's functionality, performance, and user experience
• To comply with applicable legal and regulatory requirements, including licence conditions, court orders, and requests from regulatory authorities

7. Data Sharing & Third-Party Disclosure

fly99 does not sell your Personal Data to third parties. We may disclose Personal Data to the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Processors: Payment service providers and financial institutions facilitating deposits and withdrawals (including those connected to Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and major Malaysian banks) receive transaction data necessary to process payments.
• KYC & Fraud Prevention Providers: Third-party identity verification and fraud detection services that assist fly99 in meeting its AML and regulatory compliance obligations.
• Technology Service Providers: Cloud hosting providers, platform infrastructure vendors, and software service providers who process data on fly99's behalf under contractual data processing agreements.
• Regulatory & Law Enforcement Authorities: Where required or permitted by law, we may disclose Personal Data to gaming regulators, financial intelligence units, courts, or other government authorities.
• Game Content Providers: Game providers and their auditors may receive anonymised or pseudonymised data related to game outcomes and fairness verification, strictly without identifying you to third parties.

All third parties engaged by fly99 are subject to contractual obligations requiring them to maintain the confidentiality and security of Personal Data and to process it only for the stated purpose and in compliance with applicable data protection law.

8. Cookies & Tracking Technologies

fly99 uses cookies and similar technologies on the Platform for the following purposes:

• Strictly Necessary Cookies: Required for core Platform functionality, including maintaining your login session and remembering Account preferences. These cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how Players interact with the Platform — page views, session lengths, navigation paths — to help us improve the user experience.
• Functional Cookies: Allow the Platform to remember your preferences, such as language settings, preferred payment method, and display options.
• Marketing Cookies: Used, where you have consented, to deliver personalised promotional content on the Platform based on your activity and interests.

You may manage your cookie preferences through your browser settings. Blocking certain categories of cookies may affect the functionality of the Platform.

9. Data Retention

fly99 retains Personal Data for as long as necessary to fulfil the purposes described in this Policy and to comply with applicable legal, regulatory, and contractual obligations. The following indicative retention periods apply:

• Account Data: Retained for the duration of your Account and for a minimum of 5 years following Account closure, in accordance with AML record-keeping requirements.
• Transaction & Financial Records: Retained for a minimum of 7 years from the date of the transaction to comply with financial reporting and AML obligations.
• KYC Documents: Retained for a minimum of 5 years from the date of verification or Account closure, whichever is later.
• Customer Support Records: Retained for 3 years from the date of the interaction, unless retention for a longer period is required for dispute resolution or legal proceedings.
• Marketing Data: Retained until you withdraw consent or object to processing, after which it will be deleted or anonymised within 30 days.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised, unless further retention is required by law or legitimate business necessity.

10. Data Security

fly99 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption applied to all data transmitted between your device and the Platform
• Encrypted storage of sensitive data, including financial credentials and identity documents
• Role-based access controls ensuring that only authorised personnel can access Personal Data in the performance of their job functions
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure
• Two-factor authentication (2FA) options available to Players for additional Account security
• Documented data breach response procedures, including regulatory notification obligations where applicable

Notwithstanding the above, no data transmission over the internet or storage system can be guaranteed to be completely secure. fly99 cannot warrant the absolute security of Personal Data, and accepts no liability for breaches that arise outside of its reasonable control. Players are encouraged to use strong, unique passwords and to enable 2FA on their Accounts.

11. International Data Transfers

fly99's primary infrastructure is hosted within secure data centres. In the course of providing the Platform and engaging third-party service providers, Personal Data may be transferred to and processed in countries other than Malaysia. Where such transfers occur, fly99 takes steps to ensure that appropriate safeguards are in place to protect your Personal Data in accordance with applicable data protection standards, including through the use of contractual data protection clauses with third-party processors.

12. Your Rights as a Data Subject

Subject to applicable data protection law, you have the following rights in relation to your Personal Data held by fly99:

To exercise any of the rights listed above, please submit a written request to our support team (contact details in Section 15). fly99 will respond to all Data Subject rights requests within 30 calendar days of receipt. Where a request is complex or numerous, we may extend this period by up to a further 60 days, in which case we will notify you of the extension and the reasons for it.

fly99 will not charge a fee for handling rights requests unless the request is manifestly unfounded, repetitive, or excessive, in which case a reasonable administrative fee may apply.

13. Minors & Age Restriction

The fly99 Platform is strictly restricted to individuals aged 21 years and above. fly99 does not knowingly collect Personal Data from persons under the age of 21. If we become aware that Personal Data has been collected from a minor, we will take immediate steps to delete that data and close the associated Account.

If you have reason to believe that a minor has submitted Personal Data to fly99 without parental or guardian consent, please contact us immediately using the details set out in Section 15 so that we can investigate and take appropriate action.

14. Policy Amendments

fly99 reserves the right to amend this Privacy Policy at any time. Where we make material changes to the Policy, we will provide advance notice by posting a prominent notice on the Platform and, where we hold your email address, by sending a notification to your registered email address. The date at the top of this Policy reflects the most recent revision.

Your continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the amended terms. If you do not agree to the amended Policy, you must stop using the Platform and may close your Account in accordance with the fly99 Terms & Conditions.

15. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or fly99's data processing practices, or if you wish to exercise your data subject rights, please contact our Data Protection team:

We aim to acknowledge all privacy-related enquiries within 48 hours and to provide a substantive response within 30 calendar days of receipt.