Shell99 Privacy Policy – Malaysia Member Personal Data Protection

1 Information We Collect

To provide a safe and responsible online entertainment platform, shell99 collects the following categories of information:

We only collect information that is strictly necessary for the stated purposes. We do not collect sensitive data such as health information or religious beliefs unless there is a specific legal requirement to do so.

2 How We Use Your Information

Information you provide to shell99 is used responsibly for the following purposes only:

• Verify your identity during registration and throughout your membership via required KYC processes.
• Process deposits, withdrawals, and other financial transactions quickly and securely using your preferred payment methods.
• Send you important notifications related to your account, transactions, promotions, and relevant platform updates.
• Detect and prevent fraud, money laundering, and any platform misuse that could compromise the safety of other members.
• Improve our services and user experience through aggregated data analysis that cannot be individually identified.
• Comply with applicable legal and regulatory requirements, including PDPA 2010, AML requirements, and directives from relevant regulatory bodies.
• Provide effective customer support and resolve any enquiries or complaints you submit to us.

3 Legal Basis for Data Processing

Shell99 processes your personal data on the following legal bases under Malaysia's Personal Data Protection Act 2010 (PDPA):

• Your consent – When you register a shell99 account, you provide explicit consent for the data processing described in this policy.
• Contract performance – Data processing is required to fulfill the service agreement between you and shell99, including processing your financial transactions.
• Legitimate interest – We process certain data based on our legitimate interests in securing the platform, preventing fraud, and improving service quality.
• Legal obligation – Certain data processing such as KYC and AML records is required to meet our legal obligations.

4 Data Sharing and Disclosure

Shell99 fully respects your privacy. We only share your personal data in the following limited circumstances:

• Approved service providers – Selected third parties such as payment gateway providers, KYC service providers, and authorized gaming platforms, all of whom are bound by strict confidentiality agreements.
• Legal requirement – When required by law or court order, or upon request from lawful authorities such as the Royal Malaysia Police or the Financial Intelligence Unit.
• Vital interest protection – In emergency situations requiring the protection of someone's life or safety.
• Business restructuring – In the event of a merger, acquisition, or sale of shell99 assets, where the new recipient will be bound by the same privacy policy.

5 Data Storage and Security

Your data security is our absolute priority at shell99. We implement comprehensive, multi-layered protection to ensure your data remains safe at all times:

• End-to-end encryption – All data transmitted using TLS 1.3 protocol with AES-256 encryption, ensuring no unauthorized party can read data in transit.
• Role-based access control – Only staff with a legitimate operational need are permitted to access member personal data, and every access is logged for audit purposes.
• Regular data imaging – Your data is automatically backed up across multiple data center locations to prevent data loss from technical failures.
• Continuous security monitoring – Our intrusion detection system operates 24 hours a day, 7 days a week to detect and respond to any security threats promptly.
• Regular penetration testing – We conduct regular security testing by independent experts to identify and address system vulnerabilities before they can be exploited.

Your personal data will be retained for the duration of your active membership and for up to 7 years after account closure to comply with AML and financial record legal requirements. After this period, data that is no longer required will be securely deleted or anonymised.

6 Cookies and Tracking Technologies

Shell99 uses cookies and similar tracking technologies to enhance your experience on our platform. The following are the types of cookies we use:

• Essential cookies – Required for core platform functions such as secure login, session management, and transaction processing. These cookies cannot be disabled without affecting platform functionality.
• Performance cookies – Helps us understand how members use our platform through aggregate analytics, enabling us to make meaningful improvements.
• Functional cookies – Stores your preferences such as language, display settings, and saved login information for your convenience.
• Security cookies – Helps us detect suspicious activity and protect your account from unauthorized access attempts.

You can manage or disable cookies through your web browser settings. Please note, however, that disabling certain cookies may affect the functionality and user experience of the Shell99 platform.

7 Your Privacy Rights as a Member

As a shell99 member, you have important rights regarding your personal data under Malaysia's PDPA 2010. We respect and facilitate the exercise of these rights:

To exercise any of the above rights, please contact our data protection team via live chat in the shell99 app. We will process your request within 14 business days.

8 Children's Privacy

Shell99 is an online entertainment platform intended exclusively for adults aged 18 and above. We do not knowingly collect or process personal data of minors.

• All new registrants are required to confirm that they are 18 years of age or older during the registration process.
• We conduct age verification as part of the KYC process to ensure compliance with this requirement.
• Should we discover that personal data of a minor has been collected without our knowledge, we will immediately delete that data and close the account in question.

9 Changes to This Privacy Policy

Shell99 reserves the right to modify or update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or new platform features. When we make significant changes:

• We will update the "Last updated" date at the top of this page.
• We will notify members via email or in-app notification for significant changes.
• Continued use of the shell99 platform after changes are published constitutes acceptance of the updated policy.

We encourage you to review this page periodically to stay informed about how we manage your personal data.

10 How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us through the following channels:

• In-app live chat – The fastest channel, available 24 hours a day, 7 days a week.
• Support email – [email protected] (response within 1–2 business days)
• In-app support page – Access via the shell99 app downloaded from our Download.

Our dedicated data protection team will carefully process your enquiry and provide a comprehensive response within a reasonable timeframe. We take every privacy concern seriously and are committed to resolving it in the most satisfactory way possible.