qqclubs Privacy Policy — How We Protect and Handle Your Personal Data

1.1  This Privacy Policy ("Policy") describes how qqclubs ("we", "us", "our") collects, processes, stores, and protects the personal data of individuals who access or use the qqclubs platform at qqclubs.lat, including registered Members and non-registered visitors.

1.2  qqclubs is committed to protecting the privacy of all individuals whose personal data we handle. We process personal data lawfully, fairly, and transparently, and we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks involved.

1.3  By accessing the qqclubs platform, creating an account, or otherwise providing us with your personal data, you acknowledge that you have read and understood this Policy. If you do not agree to the terms of this Policy, please discontinue use of the platform immediately.

1.4  This Policy should be read in conjunction with the qqclubs Terms & Conditions, which govern the broader relationship between qqclubs and its Members.

2.1  For the purposes of applicable data protection law, qqclubs acts as the data controller in respect of personal data collected through the platform. As data controller, qqclubs determines the purposes and means by which personal data is processed.

2.2  Where qqclubs engages third-party service providers to process data on its behalf, such providers act as data processors under qqclubs' instruction and are bound by appropriate data processing agreements that require them to handle personal data in accordance with this Policy and applicable law.

2.3  Contact information for data-related enquiries is provided in Section 15 of this Policy.

3.1  Registration and Identity Data: When you create a qqclubs account, we collect the information you provide, which typically includes your full legal name, date of birth, residential address, email address, and contact telephone number.

3.2  KYC Verification Data: To comply with applicable identity verification and anti-money laundering requirements, qqclubs may collect copies of government-issued identification documents (such as a MyKad, passport, or driving licence) and proof of address documents.

3.3  Financial Data: We collect information necessary to process deposits and withdrawals, including bank account details, e-wallet account references (such as Touch n Go eWallet or Boost registered information), and transaction records. Full payment card numbers are never stored by qqclubs.

3.4  Transaction and Wagering Data: We record all financial transactions and wagering activity conducted through the platform, including deposit and withdrawal history, bet placement records, game session data, and bonus usage history.

3.5  Technical and Usage Data: We automatically collect certain technical data when you access the platform, including your IP address, device type, operating system, browser type, session duration, pages visited, and referring URLs.

3.6  Communications Data: Records of communications between you and qqclubs support channels, including live chat transcripts and email correspondence, are retained for service quality and dispute resolution purposes.

4.1  Directly from you — during account registration, KYC verification submission, deposit and withdrawal requests, support communications, and completion of responsible gaming forms.

4.2  Automatically — through cookies, web beacons, server logs, and similar tracking technologies when you access and use the platform. See Section 8 for full details on cookies and tracking.

4.3  From third-party verification providers — qqclubs may receive supplementary identity or address verification data from licensed third-party KYC and anti-fraud service providers.

4.4  From payment processors — transaction confirmation data and payment status updates are received from payment processing partners, including local Malaysian e-wallet operators.

5.1  qqclubs uses the personal data we collect for the following purposes:

• Creating, maintaining, and administering your qqclubs member account;
• Verifying your identity and age eligibility (21 years and above) as required for platform access;
• Processing deposits, withdrawals, and other financial transactions;
• Complying with anti-money laundering (AML) obligations and other applicable regulatory requirements;
• Detecting, investigating, and preventing fraud, prohibited conduct, and platform security breaches;
• Providing customer support and resolving disputes;
• Operating responsible gaming tools, including monitoring for indicators of problem gambling behaviour;
• Sending transactional communications, including account notifications, deposit confirmations, and security alerts;
• Sending marketing and promotional communications where you have not opted out (see Section 13);
• Improving, personalising, and developing the platform's products and features;
• Complying with legal obligations, court orders, and requests from competent authorities.

6.1  qqclubs processes your personal data on the following legal bases:

• Contractual necessity — processing required to fulfil our obligations under the Member Agreement (Terms & Conditions), including account management, payment processing, and service delivery;
• Legal obligation — processing required to comply with applicable laws and regulations, including KYC, AML, and licensing framework obligations;
• Legitimate interests — processing conducted for qqclubs' legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where those interests are not overridden by your fundamental rights;
• Consent — processing for optional purposes, such as marketing communications, where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7.1  qqclubs does not sell, rent, or trade your personal data to third parties. We may share data with the following categories of recipients only to the extent necessary for the stated purpose:

• KYC and identity verification providers — to facilitate identity and age verification during registration and ongoing compliance reviews;
• Payment processing partners — to facilitate deposits and withdrawals, including Touch n Go eWallet, Boost, and banking partners such as Maybank, CIMB, and Public Bank;
• Game technology providers — game providers may receive session data necessary to operate the games you play, subject to their own privacy and data security standards;
• Fraud prevention and security services — to detect and prevent fraudulent activity, security breaches, and prohibited conduct;
• Legal and regulatory authorities — where required by applicable law, court order, or a legitimate request from a competent regulatory authority;
• Professional advisers — legal counsel, accountants, and auditors, where required in the course of their professional engagement with qqclubs, subject to appropriate confidentiality obligations.

7.2  All third-party data processors engaged by qqclubs are required to process personal data only on qqclubs' documented instructions and to implement appropriate data security measures.

8.1  The qqclubs platform uses cookies and similar tracking technologies to enable core platform functionality, improve user experience, and gather analytical data about platform usage.

8.2  The categories of cookies used by qqclubs include:

• Essential cookies — strictly necessary for platform operation, including session management, authentication, and security. These cannot be disabled without affecting platform functionality;
• Functional cookies — used to remember your preferences, such as language settings and responsible gaming configurations;
• Analytical cookies — used to collect aggregated, anonymised information about how Members navigate and use the platform, enabling us to improve features and performance;
• Marketing cookies — used, where consent has been provided, to deliver relevant promotional content based on your platform activity.

8.3  You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the core qqclubs platform, but may affect the availability of certain personalisation features.

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

• 256-bit SSL/TLS encryption for all data transmitted between Member devices and qqclubs servers;
• AES-256 encryption for personal data stored in qqclubs databases;
• One-way cryptographic hashing of account passwords — no staff member can view your password in plain text;
• Role-based access controls limiting staff access to personal data to the minimum necessary for their function;
• Two-factor authentication availability for all Member accounts;
• Regular security assessments and penetration testing of platform infrastructure;
• Login anomaly detection and automatic session timeout on inactive sessions.

9.2  In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, qqclubs will notify affected Members without undue delay and will take all appropriate remedial measures.

10.1  qqclubs retains personal data for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law or regulatory obligation. The following general retention principles apply:

• Active account data is retained for the duration of the Member relationship;
• Following account closure, Member data is retained for a minimum of five (5) years to satisfy AML record-keeping obligations and to facilitate the resolution of any post-closure disputes;
• Financial transaction records are retained in accordance with applicable financial record-keeping requirements;
• KYC documentation is retained for the period required under applicable anti-money laundering regulations;
• Technical logs and usage data are retained for up to 24 months for security and analytical purposes.

10.2  Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to an identifiable individual.

11.1  Subject to applicable law and certain conditions, qqclubs Members have the following rights in relation to their personal data:

11.2  To exercise any of the above rights, please contact qqclubs support using the contact details in Section 15. qqclubs may require you to verify your identity before processing a data rights request.

12.1  The qqclubs platform is strictly intended for adults aged 21 years and above. qqclubs does not knowingly collect personal data from individuals under the age of 21.

12.2  If qqclubs becomes aware that personal data has been collected from an individual below the minimum age threshold, such data will be deleted immediately, the account will be closed, and any funds associated with the account will be handled in accordance with applicable law.

12.3  If you believe that a minor has registered an account on the qqclubs platform, please contact support immediately using the details in Section 15.

13.1  With your consent, qqclubs may send you promotional communications about bonuses, new products, tournaments, and other qqclubs offers. You may opt in to such communications during registration or at any time through your account notification settings.

13.2  You may opt out of marketing communications at any time by updating your notification preferences in your qqclubs account settings, or by notifying support. Opting out of marketing communications will not affect your receipt of transactional and account-related notifications, which are necessary for platform operation.

13.3  qqclubs will not send marketing communications to Members who have active self-exclusion arrangements in place, regardless of their notification preferences.

14.1  qqclubs may update this Privacy Policy periodically to reflect changes in our data processing practices, applicable law, or platform functionality. The date of the most recent revision is displayed at the top of this page.

14.2  Where material changes are made to this Policy, qqclubs will notify registered Members by email or in-platform notification prior to the changes taking effect.

14.3  Your continued use of the qqclubs platform following publication of an updated Privacy Policy constitutes your acknowledgement of the changes. We encourage Members to review this Policy periodically.

15.1  If you have questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how qqclubs handles your personal data, please contact the qqclubs Data Privacy team via the email address below. All enquiries are acknowledged within 5 business days.