1 Introduction
jj9pm ("we", "us", "our", "the Platform") is committed to protecting and respecting the privacy of all individuals who interact with our website located at https://jj9pm.cam and all associated services, including online casino games, sports betting, live dealer games, payment processing, and customer support.
This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. It covers: what personal data we collect and why; how we use, store, and protect that data; with whom we may share it; how long we retain it; and the rights you have in relation to your personal data.
This Policy should be read in conjunction with our Terms & Conditions, which govern the overall contractual relationship between you and jj9pm. By using the Platform, you confirm that you have read and understood this Policy and consent to the processing of your personal data as described herein.
This Policy applies to all users of the jj9pm platform, including players based in Malaysia and internationally. Malaysian users are encouraged to also familiarise themselves with the Personal Data Protection Act 2010 (PDPA), which governs the processing of personal data in Malaysia. While jj9pm operates under its international licensing framework, we take Malaysian data protection obligations seriously.
If you have any questions about how your personal data is handled, you may contact our Data Protection contact at any time. Details are provided in Section 16 (Contact Us) of this Policy.
2 Definitions
For the purposes of this Privacy Policy, the following terms carry the meanings set out below:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person — including name, email address, identification document number, IP address, device identifier, and financial transaction data. |
| "Processing" | Any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, transmission, erasure, or destruction. |
| "Data Subject" | The identified or identifiable natural person to whom personal data relates — in the context of this Policy, this means you, the registered Player or website visitor. |
| "Data Controller" | The entity that determines the purposes and means of processing personal data — jj9pm in the context of this Policy. |
| "Data Processor" | Any third-party service provider that processes personal data on behalf of jj9pm under a data processing agreement. |
| "KYC" | Know Your Customer — the identity and document verification process required of all Players before their first withdrawal. |
| "Cookies" | Small text files placed on your device by the Platform to store information about your session, preferences, and browsing behaviour. |
| "Platform" | The jj9pm website at https://jj9pm.cam and all services, features, and tools made available thereon. |
3 Personal Data We Collect
jj9pm collects personal data in several categories depending on how you interact with the Platform. The following table summarises the categories of data we collect and the context in which they arise:
| Data Category | Examples | Context |
|---|---|---|
| Identity Data | Full name, date of birth, nationality, gender | Account registration, KYC verification |
| Contact Data | Email address, phone number | Account registration, support communications |
| Document Data | Malaysian MyKad, passport, driver's licence, proof of address (utility bill, bank statement) | KYC identity verification, age verification |
| Financial Data | Payment method details (e-wallet IDs, masked bank account/card numbers), deposit and withdrawal history, transaction amounts in MYR | Deposit processing, withdrawal verification, AML compliance |
| Gaming Activity Data | Bets placed, games played, win/loss records, bonus redemption history, session duration | Platform operation, responsible gambling monitoring, dispute resolution |
| Technical Data | IP address, device type, browser type and version, operating system, unique device identifiers | Security monitoring, fraud detection, platform optimisation |
| Usage Data | Pages visited, links clicked, time spent on pages, navigation paths | Analytics, UX improvement, marketing effectiveness |
| Communications Data | Live chat transcripts, support email content, complaint records | Customer support, dispute resolution, quality monitoring |
| Preference Data | Responsible gambling settings (deposit limits, self-exclusion status, session reminders) | Responsible gambling tools, player protection |
We collect only the minimum data necessary for each specific purpose. We do not collect sensitive personal data (such as racial or ethnic origin, religious beliefs, or health data) except where strictly required by our KYC or responsible gambling obligations.
4 How We Collect Personal Data
jj9pm collects personal data through the following means:
- Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, set responsible gambling limits, or respond to platform communications.
- Automatically: When you browse or interact with the Platform, we automatically collect Technical Data and Usage Data via cookies, server logs, and similar tracking technologies. See Section 8 (Cookies & Tracking) for full details.
- From third-party service providers: We may receive data about you from KYC verification partners, payment processors (including operators of Touch 'n Go eWallet, DuitNow, FPX, Maybank, CIMB, and other Malaysian payment channels), fraud prevention services, and credit reference agencies where relevant.
- From publicly available sources: In limited circumstances related to fraud prevention or due diligence, we may consult publicly available records such as sanctions lists or court records.
5 Purposes of Processing
We use your personal data for the following specific purposes:
| Purpose | Data Categories Used |
|---|---|
| Account registration and management | Identity Data, Contact Data |
| Identity and age verification (KYC) | Identity Data, Document Data |
| Processing deposits and withdrawals | Identity Data, Financial Data, Document Data |
| Anti-money laundering (AML) compliance and fraud prevention | Identity Data, Financial Data, Technical Data, Gaming Activity Data |
| Delivering platform services (games, betting, live dealer) | Identity Data, Gaming Activity Data, Technical Data |
| Responsible gambling monitoring and enforcement | Gaming Activity Data, Preference Data, Identity Data |
| Customer support and dispute resolution | Identity Data, Communications Data, Financial Data, Gaming Activity Data |
| Platform security and abuse prevention | Technical Data, Usage Data, Identity Data |
| Platform analytics and improvement | Usage Data, Technical Data (anonymised where possible) |
| Sending service-related communications (account updates, security alerts) | Contact Data, Identity Data |
| Sending promotional communications (where consent has been given) | Contact Data, Preference Data, Gaming Activity Data |
You may opt out of promotional communications at any time by updating your notification preferences in your account settings or by contacting our support team. Opting out of promotional emails does not affect service-related communications, which are necessary for platform operation.
6 Legal Basis for Processing
jj9pm processes your personal data on the following legal bases, consistent with applicable data protection legislation including the Malaysian Personal Data Protection Act 2010 (PDPA) and other applicable international frameworks:
- Contractual necessity: Processing required to perform our contractual obligations to you as a registered Player — including account management, game delivery, payment processing, and withdrawal handling.
- Legal obligation: Processing necessary to comply with applicable legal and regulatory requirements, including anti-money laundering (AML) obligations, age verification requirements, and responses to lawful requests from competent authorities.
- Legitimate interests: Processing necessary for jj9pm's legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring, and analytics — where such interests do not override your fundamental rights and freedoms.
- Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily in relation to promotional communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.
7 Data Sharing & Third-Party Disclosure
jj9pm does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. We share personal data only where strictly necessary, under appropriate contractual safeguards, and for the limited purposes described below:
- Payment Processors: We share transaction-relevant data with the payment service providers you use — including but not limited to Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, Visa, Mastercard, and cryptocurrency network processors — solely for the purpose of processing your transactions.
- KYC Verification Partners: We share identity and document data with accredited third-party KYC verification providers for the purpose of conducting identity checks and age verification as required under our licensing obligations.
- Fraud Prevention & AML Services: We may share data with fraud detection services and anti-money laundering compliance tools to identify and prevent unlawful activity on the Platform.
- IT Infrastructure & Hosting Providers: Our platform infrastructure is hosted on third-party cloud services. These providers process data on our behalf under binding data processing agreements and are not permitted to use your data for their own purposes.
- Competent Authorities: We may disclose your personal data to law enforcement agencies, regulators, or courts where required by law, or where we believe in good faith that such disclosure is necessary to prevent fraud, abuse, or harm.
- Corporate Transactions: In the event of a merger, acquisition, or sale of all or substantially all assets of jj9pm, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.
jj9pm will never share your personal data with any third party for advertising, profiling, or commercial data-brokering purposes. All third-party data processors are vetted and bound by data processing agreements requiring appropriate security standards.
8 Cookies & Tracking Technologies
The jj9pm platform uses cookies and similar tracking technologies to provide core platform functionality, improve user experience, and support security monitoring. The following categories of cookies are used:
| Cookie Type | Purpose | Consent Required |
|---|---|---|
| Strictly Necessary | Essential for platform functionality — session management, login authentication, security tokens. Cannot be disabled without breaking platform features. | No (essential) |
| Functional | Remember your preferences such as language settings, display options, and responsible gambling tool configurations. | Yes |
| Analytics | Collect anonymised usage data to understand how players interact with the Platform — pages visited, session duration, navigation paths. Used to improve platform design and performance. | Yes |
| Security | Support fraud detection, bot prevention, and account security monitoring. | No (legitimate interest) |
You may manage your cookie preferences via your browser settings. Please note that disabling certain cookies may affect the functionality of the jj9pm platform. Most browsers allow you to refuse or accept cookies, delete existing cookies, and configure notifications when a new cookie is set. Refer to your browser's help documentation for instructions.
9 Data Retention
jj9pm retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting obligations. The following retention periods apply:
| Data Category | Retention Period | Rationale |
|---|---|---|
| Account & Identity Data | Duration of account + 5 years following closure | Legal obligation, AML compliance, dispute resolution |
| KYC Documents | Duration of account + 5 years following closure | Regulatory requirement, fraud prevention |
| Transaction Records | Duration of account + 7 years following closure | Financial record-keeping, AML, tax compliance |
| Gaming Activity Logs | Duration of account + 3 years following closure | Dispute resolution, responsible gambling enforcement |
| Support Communications | 3 years from date of communication | Quality monitoring, dispute resolution |
| Analytics & Usage Data | Up to 26 months (anonymised) | Platform improvement |
| Marketing Preferences | Until consent is withdrawn or account is closed | Consent-based processing |
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where data is anonymised, it may be retained indefinitely for analytical purposes as it no longer constitutes personal data.
10 Data Security
jj9pm implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, destruction, or accidental loss. Our security infrastructure includes:
- 256-bit SSL/TLS Encryption: All data transmitted between your device and jj9pm's servers is encrypted using industry-standard Transport Layer Security (TLS). Look for the padlock icon in your browser address bar when using the Platform.
- Data Encryption at Rest: Sensitive stored data — including identity documents, financial records, and account credentials — is encrypted at rest using AES-256 encryption.
- Access Controls: Personal data is accessible only to authorised jj9pm personnel who require access in the performance of their duties. Access is controlled on a least-privilege basis and all access events are logged.
- Regular Security Audits: Our platform undergoes periodic independent security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.
- Fraud Monitoring: Automated systems monitor account activity and transactions in real time to detect patterns indicative of fraud, account takeover, or money laundering.
- Incident Response: In the event of a data security incident that is likely to result in a risk to the rights and freedoms of affected individuals, jj9pm will notify affected players and relevant authorities within applicable regulatory timeframes.
You also play an important role in keeping your data secure. Use a strong, unique password for your jj9pm account, enable two-factor authentication where available, and never share your login credentials with any third party. If you suspect your account has been compromised, contact us immediately.
11 Your Data Protection Rights
Depending on applicable law and the circumstances of your data processing relationship with jj9pm, you may have the following rights in respect of your personal data. We will respond to all valid rights requests within 30 days of receipt, or sooner where practically possible.
Right of Access
You may request a copy of the personal data jj9pm holds about you, along with information about how it is processed.
Right to Rectification
You may request correction of any inaccurate or incomplete personal data held about you.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purposes it was collected, subject to legal retention obligations.
Right to Restriction
You may request that we restrict processing of your data in certain circumstances — for example, while the accuracy of your data is contested.
Right to Portability
Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, machine-readable format.
Right to Object
You may object to processing based on legitimate interests or for direct marketing purposes. Marketing opt-outs take effect immediately.
Right to Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
Right to Lodge a Complaint
You have the right to lodge a complaint with the relevant data protection authority in your jurisdiction if you believe your rights have been infringed.
To exercise any of the above rights, please contact our support team via the details set out in Section 16 of this Policy. We may require you to verify your identity before processing a rights request.
Please note that certain rights are subject to limitations under applicable law. For example, we cannot delete transaction records or KYC documents that we are legally required to retain. Where we are unable to fulfil a rights request in full, we will explain the reasons in our response.
12 Children, Minors & Age Restrictions
The jj9pm platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or store personal data relating to any person under the age of 21. The collection of data from minors is not permitted under any circumstances.
Age verification is a mandatory step in the account registration and KYC process. Any account found to belong to a person under 21 years of age will be immediately closed, all data will be deleted (subject to any legal obligation to retain records of the fraudulent registration), and any deposits will be returned.
If you are a parent or guardian and believe that your child has provided personal data to jj9pm, please contact us immediately using the details in Section 16. We will investigate and take prompt action to delete the relevant data and close any associated account.
21+ Enforcement: jj9pm uses third-party KYC verification services to confirm player age and identity. Misrepresentation of age is a serious breach of our Terms & Conditions and may be reported to relevant authorities.
13 Cross-Border Data Transfers
As an internationally operating platform, jj9pm may transfer your personal data to servers and service providers located in countries outside Malaysia. Such transfers are necessary for the operation of the Platform, including cloud hosting, payment processing, and KYC verification services.
Where personal data is transferred outside your country of residence, jj9pm takes steps to ensure that appropriate safeguards are in place, including:
- Contractual clauses requiring receiving entities to protect personal data to an equivalent standard as required in the originating jurisdiction.
- Working only with third-party processors that operate under recognised data protection frameworks or are subject to equivalent legal obligations.
- Conducting due diligence assessments on data processors prior to engagement and on an ongoing basis.
By using the jj9pm platform, you acknowledge and consent to cross-border transfers of your personal data as described in this section, subject to the protections outlined above.
14 Third-Party Links & External Services
The jj9pm platform may, from time to time, reference or display content from third-party providers — including game studios, payment service providers, or information resources. jj9pm does not control the privacy practices of any third-party websites or services and is not responsible for their content or privacy policies.
We encourage you to review the privacy policies of any third-party service before providing personal data to them directly. jj9pm's Privacy Policy applies only to data processed by jj9pm and its authorised data processors. Any data you provide to third-party payment services (such as Touch 'n Go eWallet or Maybank) is subject to those providers' own privacy terms.
15 Amendments to This Privacy Policy
jj9pm reserves the right to amend, update, or replace this Privacy Policy at any time in response to changes in applicable law, our business operations, or industry best practices. When material changes are made to this Policy, we will:
- Update the "Last Updated" date at the top of this page.
- Display an in-platform notification to logged-in Players at their next session.
- Send an email notification to registered accounts for significant changes affecting your rights or how your data is used.
Your continued use of the jj9pm platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the amended terms. If you disagree with any changes, you should discontinue use of the Platform and request account closure.
We recommend bookmarking this page and reviewing it periodically. The version date at the top of this document indicates when it was last revised.
16 Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or jj9pm's handling of your personal data, please do not hesitate to get in touch. We are committed to addressing all privacy-related enquiries promptly and transparently.
Email (plain text — not a clickable link):
[email protected]
Live Chat: Available 24 hours a day, 7 days a week, via the live chat function on the Platform. Average first response time: under 2 minutes.
Subject line guidance: For data rights requests, please mark your email subject as "Data Rights Request — [Your Full Name]". For privacy complaints, use "Privacy Complaint — [Your Full Name]". This helps us route your enquiry to the correct team promptly.
For formal data protection complaints that cannot be resolved through our internal process, Malaysian users may contact the Department of Personal Data Protection (JPDP) Malaysia — the statutory body responsible for enforcing the Personal Data Protection Act 2010 — or the relevant data protection authority in their jurisdiction.
We aim to respond to all privacy enquiries within 30 calendar days. For complex requests, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reasons for it within the initial 30-day window.