Privacy Policy — Genpak99

This Privacy Policy ("Policy") describes the data protection practices of Genpak99 ("we", "us", "our", "the Company"), operator of the online gaming platform accessible at https://genpak99.cam. This Policy applies to all personal data collected from registered players, prospective players, website visitors, and any other individuals who interact with the genpak99 platform or its associated services.

Genpak99 recognises that the personal data entrusted to us by our players — many of whom are based across Malaysia, including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam — is valuable and deserving of the highest standard of protection. We are committed to handling personal data lawfully, transparently, and in accordance with applicable data protection legislation.

By registering an account, making a deposit, placing a wager, or otherwise using the genpak99 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal data as described herein. If you do not agree with any aspect of this Policy, please discontinue your use of the platform and contact our support team to initiate account closure.

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

• "Personal Data" means any information that identifies or is capable of identifying a natural person, directly or indirectly, including but not limited to names, identification numbers, location data, online identifiers, and factors specific to the physical, economic, cultural, or social identity of that person.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, organisation, adaptation, retrieval, consultation, use, disclosure, dissemination, combination, restriction, erasure, or destruction.
• "Data Controller" means Genpak99, the entity that determines the purposes and means of processing personal data collected through the platform.
• "Data Processor" means any third-party service provider that processes personal data on behalf of genpak99 pursuant to a data processing agreement.
• "Data Subject" means you — the individual whose personal data is being collected and processed.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement by a data subject to the processing of their personal data.
• "KYC Data" means identity verification documentation submitted by players in fulfilment of Know Your Customer compliance requirements, including government-issued identification and proof of address.

Genpak99 collects personal data through several channels, including account registration forms, identity verification processes, transaction activity, customer support interactions, and your general use of the platform. The categories of personal data we collect include:

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data for identification purposes, or health data, except where strictly required for responsible gambling compliance (e.g., recording a player's self-exclusion status or referral to problem gambling support).

Genpak99 processes your personal data for the following purposes, each of which is supported by a legitimate legal basis described in Section 5 of this Policy:

Genpak99 processes your personal data on the following legal bases, depending on the specific purpose of processing:

• Contractual Necessity: The majority of our processing activities are necessary for the performance of the player account agreement between you and genpak99. This includes account administration, payment processing, and game provision.
• Legal Obligation: Certain processing activities are required by applicable law, including KYC identity verification, AML transaction monitoring, age verification, and record-keeping obligations.
• Legitimate Interests: We process certain data categories based on our legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided such interests are not overidden by your fundamental privacy rights. This includes fraud prevention, platform security, and product improvement analytics.
• Consent: Where processing is not covered by the above bases — for example, in the case of direct marketing communications — we will seek your explicit consent in advance and provide a simple mechanism to withdraw that consent at any time.

Genpak99 does not sell, rent, or trade your personal data to third parties for their own commercial use under any circumstances. We may, however, share personal data with the following categories of recipients in the context of our legitimate business operations:

• Payment Service Providers: We share necessary financial data with payment processors facilitating your transactions, including e-wallet operators (Touch 'n Go, Boost, GrabPay), banking partners (Maybank, CIMB, Public Bank, Hong Leong Bank), and cryptocurrency infrastructure providers. These processors are bound by contractual data protection obligations.
• KYC & Identity Verification Providers: Third-party identity verification services that assist us in completing player KYC checks. These providers operate under strict data processing agreements and do not retain your documentation beyond the verification process.
• Game Content Providers: Licensed game studios and aggregators whose titles appear on the genpak99 platform. Minimal technical data may be shared for game session management purposes only.
• Fraud & AML Screening Services: Compliance service providers that assist in transaction monitoring, fraud detection, and anti-money laundering screening.
• Regulatory & Law Enforcement Authorities: We may disclose personal data to competent authorities where required by law, court order, or regulatory direction. We will not voluntarily disclose data to law enforcement without a valid legal basis.
• Professional Advisers: Legal advisers, auditors, and insurance providers, subject to obligations of professional confidentiality.

Genpak99 uses cookies and similar tracking technologies on our platform to enhance your user experience, maintain session security, and gather aggregated analytics data. The categories of cookies we use include:

You may manage cookie preferences through your browser settings. Please note that disabling non-essential cookies will not affect your ability to access the core platform, but may limit certain features or personalisation options.

Genpak99 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. Our standard retention periods are as follows:

• Active Player Accounts: Personal data is retained for the full duration of your account's active status, plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years from the date of verification, or longer where required by applicable regulations.
• Transaction Records: Financial transaction data is retained for a minimum of seven (7) years from the date of each transaction, consistent with standard financial record-keeping obligations.
• Customer Support Records: Communication records are retained for three (3) years from the date of the last interaction, unless retention is required for longer in connection with an ongoing complaint or legal matter.
• Marketing Consent Records: Records of your marketing consent or withdrawal of consent are retained indefinitely to demonstrate compliance with applicable regulations.

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

Genpak99 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, disclosure, or alteration. Our security infrastructure includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the genpak99 platform is encrypted in transit using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Sensitive personal data, including KYC documents and financial information, is stored using strong encryption at rest.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All internal access is logged and subject to regular review.
• Regular Security Audits: We conduct periodic security assessments, including penetration testing and vulnerability scanning, to identify and remediate potential weaknesses in our infrastructure.
• Incident Response: We maintain a documented data breach response procedure. In the event of a security incident that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.

While we take all reasonable steps to protect your personal data, no digital platform can guarantee absolute security against all threats. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

As a data subject, you hold the following rights in relation to your personal data held by genpak99. To exercise any of these rights, please contact our Data Protection team at [email protected]. We will respond to all verified requests within 30 calendar days.

The genpak99 platform is strictly intended for individuals aged21 years and above. We do not knowingly collect, process, or retain personal data belonging to minors. Age verification is a mandatory component of the KYC process, and accounts found to belong to individuals under the minimum age threshold will be immediately closed and all associated data deleted in accordance with our retention procedures.

If you have reason to believe that a minor has registered on the genpak99 platform or that personal data belonging to a minor has been collected, please contact us immediately at [email protected] so that we may take appropriate remedial action without delay.

In the course of providing our services, your personal data may be transferred to, and processed in, countries or territories outside of Malaysia. This may occur when our data processors — such as cloud infrastructure providers, payment processors, or KYC verification services — operate infrastructure in other jurisdictions.

When transfering personal data internationally, genpak99 ensures that adequate safeguards are in place to protect your data to a standard at least equivalent to the protections afforded under applicable Malaysian data protection law. Safeguards may include standard contractual clauses, binding corporate rules, or reliance on adequacy decisions by relevant regulatory authorities.

By using the genpak99 platform, you consent to the international transfer of your personal data as described in this section, subject always to the security measures and safeguards described in this Policy.

With your prior consent, genpak99 may send you promotional communications relating to new games, special offers, bonus promotions (including the 288% Magnificent Welcome Bonus and seasonal promotions), VIP programme updates, and other platform news.

Marketing communications may be delivered by email, in-platform notification, or other channels for which you have provided consent. You may withdraw your marketing consent at any time by:

• Clicking the unsubscribe link contained in any marketing email;
• Updating your communication preferences in your account settings; or
• Contacting our support team and requesting removal from marketing lists.

Withdrawal of marketing consent will not affect the lawfulness of any processing conducted prior to withdrawal, nor will it affect the processing of transactional communications (such as deposit confirmations, withdrawal notifications, and KYC requests) which are sent on the basis of contractual necessity rather than consent.

The genpak99 platform may contain references to or integrations with third-party services, including game providers, payment processors, and technical infrastructure vendors. This Privacy Policy governs only the processing of personal data by genpak99 as Data Controller. Third-party services operate under their own privacy policies, for which genpak99 bears no responsibility.

When you make a payment through a third-party payment provider such as Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, or Public Bank, your financial data is also processed by that provider in accordance with their own terms and privacy documentation. We encourage you to review the privacy policies of all payment providers you use.

Genpak99 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal obligations, or the evolution of our platform and services.

Material changes to this Policy will be communicated to registered players via email notification or a prominent platform notice at least seven (7) days before the updated Policy takes effect. The version number and effective date displayed at the top of this page will always reflect the current version.

Your continued use of the genpak99 platform after the effective date of any amendment constitutes your acknowledgement of the updated Policy. If you do not agree with the amended Policy, you must cease using the platform and contact our support team to initiate account closure.

If you have any questions, concerns, or requests in relation to this Privacy Policy or your personal data held by genpak99, please contact us through the following channels: