Privacy Policy

This Privacy Policy ("Policy") issued by JMD89 ("Company", "we", "us", "our"), the operator of the online gaming and sports betting platform athttps://jmd89.click ("Platform"). It describes how JMD89 collects, processes, stores, shares, and protects personal data belonging to registered players, prospective players, and visitors ("you", "your") in connection with your use of our Platform and related services.

JMD89 is committed to handling all personal data responsibly, transparently, and in accordance with internationally recognised data protection principles. We collect only the data that is necessary for the delivery of our services and the fulfilment of our legal obligations, and we do not sell your personal information to third parties for marketing purposes under any circumstances.

By creating an account, depositing funds, or otherwise using the JMD89 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not accept the terms of this Policy, you should cease using the Platform immediately.

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" — any information that identifies or can reasonably be used to identify a living individual, either alone or in combination with other data.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" — JMD89, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" — a third party that processes personal data on behalf of JMD89under a written contract and under our direction.
• "KYC Data" — identity and age verification documents collected in accordance with our Know Your Customer obligations.
• "Cookies" — small text files stored on your device by the Platform to enable functionality, analytics, and personalisation features.
• "PDPA" — the Personal Data Protection Act 2010 of Malaysia, governing the processing of personal data in commercial transactions.

JMD89 collects the following categories of personal data depending on the nature of your interaction with the Platform:

Full Name Date of Birth Email Address Contact Number Residential Address Username

Collected during registration and used to create and manage your player account.

MyKad / Passport Copy Proof of Address Payment Method Evidence Selfie / Liveness Check

Collected as part of our mandatory identity verification process before any withdrawal is processed. Required by our regulatory obligations.

Deposit Records Withdrawal Records Payment Method Type Transaction Timestamps MYR Amounts

Recorded for every financial transaction conducted through the Platform, including deposits via FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, and cryptocurrency channels.

Bet History Game Sessions Win / Loss Records Preferred Game Types Sports Betting Markets

Collected to operate the gaming services, personalise your experience, and fulfil our responsible gambling obligations.

IP Address Device Type Browser & OS Version Session Logs Geolocation (country/region)

Collected automatically when you access the Platform, used for security monitoring, fraud prevention, and platform optimisation.

Support Chat Transcripts Email Correspondence Complaint Records

Retained when you contact our customer support team, to provide assistance and maintain accurate service record.

JMD89 collects personal data through the following methods:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or update your account profile.
• Automatically — through cookies, web beacons, and server logs when you browse or use the Platform. This includes IP address, session duration, pages visited, and device information.
• From third-party payment providers — when you transact via FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, or connected bank accounts, transaction confirmation data is shared with us by the payment processor.
• From identity verification services — in certain cases, we work with licensed third-party KYC service providers to verify the authenticity of documents submitted by players.
• From fraud prevention systems — data from device fingerprinting and risk assessment tools helps us identify and prevent fraudulent account activity.

JMD89 processes your personal data for the following specific purposes:

• Account Management: To create, verify, and maintain your player account, including password management and account security.
• Service Delivery: To provide the gaming and sports betting services you have requested, including processing bets, crediting winnings, and facilitating withdrawals in MYR.
• Identity Verification & KYC: To verify your identity and age (minimum 21 years) in compliance with our regulatory obligations, and to prevent the use of the Platform by ineligible persons.
• Payment Processing: To process deposits and withdrawals through your chosen payment method and maintain accurate financial records.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity money laundering, multi-accounting, and other prohibited conduct on the Platform.
• Responsible Gambling: To monitor gaming patterns that may indicate problem gambling behaviour and to apply responsible gambling tools where appropriate.
• Customer Support: To respond to your queries, process complaints, and maintain records of communications for quality assurance purposes.
• Legal Compliance: To fulfil JMD89's obligations under applicable laws and regulations, including financial reporting, anti-money laundering (AML), and data retention requirements.
• Platform Improvement: To analyse usage patterns, diagnose technical issues, and improve the performance and functionality of the Platform for all users.
• Marketing Communications: To send you promotional offers and platform updates where you have given explicit consent. You may withdraw this consent at any time via your account settings or by contacting our support team.

JMD89 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to perform the contract between you and JMD89, i.e., providing the gaming services you have registered to access.
• Legal Obligation: Processing required to comply with applicable laws, including KYC/AML obligations, age verification, and regulatory reporting.
• Legitimate Interests: Processing necessary for JMD89's legitimate business interests, such as fraud prevention, platform security, and service improvement — provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

JMD89 does not share your personal data with third parties except in the following circumstances, and only to the extent necessary:

• Payment Processors: Your financial data is shared with payment service providers (including FPX operators, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, and participating Malaysian banks) solely to process your transactions.
• KYC & Identity Verification Partners: Your identity documents may be processed by licensed third-party identity verification services engaged by JMD89 for KYC compliance.
• Game Content Providers: Aggregated, pseudonymised gaming activity data may be shared with our licensed game content providers for technical support and auditing purposes.
• Fraud Prevention & Security Services: Device and session data may be processed by our third-party risk management and fraud detection partners.
• Legal & Regulatory Authorities: We will disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required by law or valid legal process, including in response to court orders issued in Malaysia or the jurisdiction of our operating licence.
• Corporate Transactions: In the event of a merger, acquisition, or sale of substantially all assets of JMD89, your personal data may be transferred to the successor entity, subject to this Policy continuing to apply.

All third-party data processors are bound by written data processing agreements requiring them to handle your data securely and only for the purposes specified by JMD89.

JMD89 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, taking into account our legal, regulatory, and business obligations. Specific retention periods are as follows:

• Account & KYC Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and financial record-keeping requirements.
• Transaction & Financial Records: Retained for a minimum of seven (7) years following the transaction date, as required by financial regulations applicable to our operating jurisdiction.
• Gaming & Betting Activity: Retained for the duration of your account and for three (3) years post-closure, to support responsible gambling monitoring and dispute resolution.
• Customer Support Communications: Retained for three (3) years from the date of the last interaction, to maintain a record for quality assurance and dispute resolution.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in manner that prevents re-identification.

JMD89 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and JMD89 servers is encrypted using industry-standard TLS protocols.
• AES-256 Data Encryption at Rest: Sensitive personal and financial data stored in our databases is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is strictly limited to authorised JMD89 personnel who require it for their specific job functions, using role-based access control (RBAC) systems.
• Two-Factor Authentication (2FA): Available on all player accounts and mandatory for all JMD89 staff accessing internal systems containing personal data.
• Regular Security Audits: Our infrastructure and security controls are subject to regular penetration testing and independent security audits.
• Data Breach Response: JMD89 maintains an incident response plan. In the event of a data breach affecting your personal data, we will notify you and relevant regulatory authorities within the timeframes required by applicable law.

JMD89 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse user behaviour. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly — including session management, login state, and security tokens. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, game history, and display options to provide a personalised experience.
• Analytics Cookies: Collect aggregated, anonymised data about how visitors interact with the Platform, helping us understand usage patterns and improve performance.
• Security Cookies: Used by our fraud detection systems to identify anomalous device or session behaviour that may indicate account compromise or unauthorised access.

You can manage cookie preferences through your browser settings. However, disabling strictly necessary cookies may impair the functionality of the Platform. For more granular cookie controls, please use the cookie preference panel accessible from the Platform footer.

Subject to applicable law, you have the following rights in respect of your personal data held by JMD89. To exercise any of these rights, please contact us at [email protected]. We will respond to all verifiable requests within 30 days.