Luckin88 Privacy Policy – Data Protection for Malaysian Players

1. Introduction and Scope of the Privacy Policy

This Privacy Policy describes how luckin88 ("we", "our platform") collects, uses, discloses, and protects the personal information of users ("you", "players") who register for and use the services on luckin88.net. This Policy applies to all players accessing the luckin88 platform from Malaysia, whether via mobile browser or desktop computer.

By registering an account with luckin88 or continuing to use our platform after a Privacy Policy update notice, you consent to the collection and use of your personal information as described in this policy. If you do not agree with any part of this policy, you are advised not to use luckin88's services.

2. Information We Collect

2.1 Information You Provide Directly

When you register an account, use our services, or contact luckin88 customer support, we may collect the following information:

• Identity details: Full name, date of birth, identification number (MyKad), gender
• Contact information: Email address, mobile phone number, residential address in Malaysia
• Account information: Username, password (stored in encrypted hash form), language preferences
• Financial information: eWallet account details (Touch 'n Go, GrabPay, Boost, ShopeePay), bank account information for FPX processing via Maybank2u or CIMB Clicks, and records of deposit and withdrawal transactions
• Identity verification documents (KYC): MyKad copy, bank statement, or other documents required for the verification process

2.2 Automatically Collected Information

When you use the luckin88 platform, our systems automatically collect several types of technical and behavioural information:

• Device information: Device type, operating system, phone model (Android or iOS), web browser version
• Network information: IP address, internet service provider (ISP) name, country and city inferred from the IP address
• Usage data: Pages visited, games played, session duration, login times and dates, betting history (excluding actual card or bank account details)
• Cookie data and tracking technologies: Session cookies, preference cookies, analytics cookies to understand platform usage patterns

3. How We Use Your Information

Luckin88 uses the personal information collected for the following purposes:

3.1 Account Management and Services

The information you provide during registration is used to create and manage your luckin88 account, verify your identity when you log in, process deposit and withdrawal requests in Malaysian Ringgit (RM) via your chosen payment method, and send you transaction and account activity notifications.

3.2 Security and Fraud Prevention

Technical data such as IP addresses and device information is used to detect suspicious activity, prevent unauthorized access to your account, and identify potential fraud or collusion between players. This is to protect your interests and the overall integrity of the luckin88 platform.

3.3 Legal Compliance and KYC Verification

Some of the data collected, particularly KYC documents, is required to comply with Malaysian legal obligations relating to anti-money laundering (AML) compliance and customer identity verification. luckin88 is obligated to retain financial transaction records for the period prescribed by applicable law.

3.4 Platform Improvement and User Experience

Usage and analytics data allows luckin88 to understand how players interact with the platform, identify areas for improvement, optimise game performance on the Android and iOS devices most commonly used by Malaysian players, and ensure the user interface remains intuitive and easy to navigate.

3.5 Service Communications

Your email address and phone number are used to send important account notifications such as registration confirmations, transaction alerts, security notices, and policy updates. These are essential service communications that cannot be unsubscribed from, as they are directly tied to the security of your account.

4. Information Sharing and Disclosure

Luckin88 takes a highly cautious approach to sharing players' personal data. We do not sell, rent, or trade your personal information to any third party for commercial or marketing purposes. However, there are limited situations where data sharing is necessary:

4.1 Payment Service Providers

When you make a deposit or withdrawal, the information required to process that transaction is shared with the relevant payment service provider — such as Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow, or a bank via FPX. This sharing is limited strictly to the information needed to complete the transaction, and these service providers are bound by strict confidentiality agreements.

4.2 Legal Requirements

Luckin88 may be required to disclose personal information in response to a valid court order, an official request from a Malaysian law enforcement agency, or other applicable legal compliance obligations. In such circumstances, luckin88 will disclose only the minimum information necessary and will notify you in advance where permitted by law.

4.3 Technical Service Providers

Third-party providers that deliver technical services to luckin88 — such as server hosting, platform analytics, and cybersecurity support — may have limited access to certain data in the course of performing their duties. All such providers are bound by strict data processing agreements and are not permitted to use that data for any other purpose.

5. Your Rights Regarding Personal Data

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and data protection best practices, you have the following rights regarding the personal data we hold about you:

To exercise any of the rights above, please contact the luckin88 customer support team via live chat or email at support@luckin88.net. We will endeavour to process your request within 14 business days. For more complex requests, we may require up to 30 days and will notify you if additional time is needed.

6. Cookies and Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files stored on your device by your web browser when you visit a website. They help the site remember information about your visit, making your experience smoother and more consistent from one session to the next.

6.2 Types of Cookies Used by luckin88

• Essential cookies: Required for core platform functions such as login authentication and session security. These cookies cannot be disabled without affecting your ability to use the platform.
• Preference cookies: Saves your preferences such as interface language and display settings, so you don't need to reconfigure them each time you log in.
• Analytics cookies: This helps luckin88 understand how players use the platform, which pages are visited most frequently, and where players encounter difficulties. This data is used in aggregated form and does not personally identify any individual.
• Security cookies: Used to detect suspicious activity, prevent CSRF (Cross-Site Request Forgery) attacks, and protect your login session from hijacking attempts.

6.3 Managing Cookie Settings

You can manage and delete cookies through your web browser settings. Most modern browsers — whether Chrome, Safari, Firefox, or Edge — offer options to block third-party cookies, delete all stored cookies, or receive notifications when new cookies are set. Please note that disabling certain cookies may affect the functionality and user experience of the luckin88 platform.

7. Data Security

Luckin88 implements comprehensive technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction:

• Transmission encryption: All data transmitted between your device and luckin88's servers is encrypted using TLS 1.2 or higher with 256-bit encryption keys.
• Storage encryption: Sensitive data such as passwords is stored as one-way hashes that cannot be decrypted. Financial information is stored with an additional layer of encryption.
• Access controls: Access to the player database is restricted to staff with a legitimate need, and all access is logged for audit purposes.
• Security monitoring: A 24/7 monitoring system is in place to detect and respond to any security threats in real time.
• Regular security testing: The luckin88 platform undergoes regular penetration testing and security audits conducted by independent experts.

While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely 100% secure. If you suspect your account has been compromised, please contact luckin88 customer support immediately.

8. Data Retention Period

Luckin88 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected and to meet the relevant legal obligations:

Once the retention period expires, your data will be securely deleted or anonymised in accordance with luckin88's internal procedures. If you close your account, we will process your data deletion request within a reasonable timeframe, subject to any applicable legal retention obligations.

9. Cross-Border Data Transfers

Personal data belonging to luckin88 players is primarily processed and stored within Malaysia, or in countries that maintain an equivalent level of data protection. Where data transfers outside Malaysia are necessary — for example, to support backup server infrastructure or specialised technical services — luckin88 ensures that such transfers are carried out in accordance with appropriate safeguards and in compliance with Malaysia's PDPA requirements.

10. Children's Privacy

The luckin88 platform is strictly for individuals aged 21 and above. luckin88 does not accept registrations from individuals under 21 and does not knowingly collect personal data from minors. If we discover that data belonging to an individual under 21 has been collected without our knowledge, we will take immediate steps to delete that data and close the account in question.

If you are a parent or guardian and suspect that your child has registered an account on luckin88, please contact our customer support immediately at support@luckin88.net.

11. Changes to the Privacy Policy

Luckin88 reserves the right to update or amend this Privacy Policy at any time. Any material changes will be communicated to you via email or an in-platform notification at least 7 days before the changes take effect. Your continued use of the luckin88 platform after the effective date of any such changes will be considered your acceptance of the updated Privacy Policy.

We encourage you to review this Privacy Policy page periodically to stay informed about how we protect your information. The date of the most recent update is always displayed at the top of this page.

12. Contact Us Regarding Privacy

If you have any questions or concerns, or would like to exercise your privacy rights in relation to this Privacy Policy, please contact the luckin88 customer support team through the following channels:

• Email: support@luckin88.net (for privacy-related enquiries, please include "Privacy Enquiry" in the subject line)
• Live chat: Available 24 hours a day, 7 days a week via the luckin88 platform

Our Malay-speaking team will endeavour to respond to privacy-related enquiries within 3 business days. For rights enforcement requests (such as data access or deletion requests), processing may take up to 14 business days depending on the complexity of the request.