Privacy Policy — Sabas99

Introduction

This Privacy Policy (hereinafter "Policy") issued by Sabas99 (hereinafter "the Company", "we", "us", or "our") and governs the collection, processing, storage, and disclosure of personal data belonging to users of the Sabas99 online gaming platform, accessible at sabas99.cam and all associated subdomains (collectively, the "Platform").

Sabas99 operates the Platform for the entertainment of eligible adult players, primarily in Malaysia. We are committed to handling personal data responsibly and in accordance with applicable data protection legislation and internationally recognised privacy principles.

By registering an account on the Platform, making a deposit, or otherwise using any feature of Sabas99, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the Platform and should contact us to request account closure.

This Policy should be read together with our Terms & Conditions, which are incorporated by reference and govern your use of the Sabas99 Platform in its entirety.

Definitions

For the purposes of this Privacy Policy, the following terms shall carry the meanings ascribed below:

• "Personal Data" — Any information that relates to an identified or identifiable natural person, including name, identification number, contact details, financial data, and device identifiers.
• "Processing" — Any operation performed on personal data, including collection, storage, use, disclosure, transfer, deletion, or any combination thereof.
• "Data Controller" — The entity that determines the purposes and means of processing personal data. In relation to this Platform, the Data Controller is Sabas99.
• "Data Processor" — A third party that processes personal data on behalf of the Data Controller pursuant to a contractual obligation.
• "User" / "Player" — Any individual who accesses the Platform, whether registered or not.
• "KYC" — Know Your Customer. The identity verification process required prior to the activation of full account functionality.
• "Cookies" — Small text files placed on a User's device by the Platform for the purpose of session management, analytics, and personalisation.
• "Consent" — Freely given, specific, informed, and unambiguous indication of agreement to the processing of personal data for a stated purpose.

Data Controller Identity

Sabas99 is the Data Controller responsible for the personal data of all registered players and visitors to the Platform. As Data Controller, Sabas99 determines the purposes for which personal data is collected and the manner in which it is processed, stored, and disclosed.

All data protection inquiries, access requests, correction requests, and deletion requests should be directed to the Sabas99 Data Protection contact, details of which are provided in Section 15 of this Policy.

Where Sabas99 engages third-party service providers to process personal data on its behalf — such as payment processors, KYC verification providers, or analytics platforms — those service providers act as Data Processors operating under contractual obligations that require them to process data only in accordance with Sabas99's documented instructions and to maintain appropriate security standards.

Personal Data We Collect

Sabas99 collects personal data through several channels: account registration, ongoing platform use, KYC verification, payment processing, customer support interactions, and automated technical data collection. The categories of personal data we collect are as follows:

4.1 Registration & Account Data

• Full legal name
• Date of birth (to verify age eligibility of 21+)
• Email address
• Malaysian mobile telephone number
• Username and encrypted password
• Residential address (including city, state, and postcode)
• Preferred language

4.2 Identity Verification (KYC) Data

• Copy of Malaysian Identity Card (MyKad), passport, or other government-issued photo identification
• Proof of address document (utility bill, bank statement, or equivalent dated within 90 days)
• Selfie photograph (where requested for enhanced verification)
• Payment method ownership documentation

4.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment channel used (DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, or cryptocurrency)
• Account balance history
• Bonus redemption and wagering records
• Currency exchange data where applicable (MYR and cryptocurrency)

4.4 Gaming & Behavioural Data

• Game session logs, bet history, and wagering patterns
• Sports betting selections, including Liga Super Malaysia, EPL, UFC, and other markets
• Session duration and frequency of play
• Responsible gambling tool usage (deposit limits set, session timers activated, self-exclusion requests)

4.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Unique device identifiers
• Platform access timestamps and navigation logs
• Cookie and session token data

4.6 Communications Data

• Records of live chat, email, and any other written correspondence with Sabas99 support staff
• Feedback and complaint submissions
• Email marketing preferences and opt-in/opt-out status

Purpose & Legal Basis for Processing

Sabas99 processes personal data only where a lawful basis for processing exists. The table below sets out the primary purposes for which we process your data and the corresponding legal basis for each:

Data Sharing & Disclosure

Sabas99 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We may share your personal data with third parties only in the following circumstances, and always subject to appropriate contractual safeguards:

6.1 Payment Processors

To facilitate deposits and withdrawals, we share transaction-relevant personal data with our payment processing partners, including operators of DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, and the participating Malaysian banks (Maybank, CIMB, Public Bank, Hong Leong, and others). These processors operate under their own data protection obligations and handle your data only to the extent necessary to complete the requested transaction.

6.2 KYC Verification Service Providers

Identity verification documents submitted during the KYC process are reviewed by our contracted KYC verification service providers. These providers process identity data solely for the purpose of verifying your identity and age in accordance with Sabas99's onboarding obligations and are contractually prohibited from using this data for any other purpose.

6.3 Game Content Providers

Game studios and sports data providers that power games and markets on the Sabas99 Platform may receive certain session and wagering data necessary for game operation and outcome verification. This data does not include full identity information unless specifically required for platform-level account management.

6.4 Legal & Regulatory Authorities

Sabas99 may be required to disclose personal data to regulatory bodies, law enforcement agencies, tax authorities, financial intelligence units, or courts of competent jurisdiction where such disclosure is required or authorised by applicable law. In such cases, we will disclose only the minimum data necessary to fulfil the legal obligation.

6.5 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of Sabas99's business, personal data held by the Company may be transferred to the relevant successor entity, subject to the same privacy protections as described in this Policy. Players will be notified of any such transfer where it materially affects their rights.

Data Retention

Sabas99 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, unless a longer retention period is required by applicable law. The following general retention principles apply:

• Active account data: Retained for the duration of the account relationship and for a period of not less than five (5) years following account closure, in compliance with anti-money laundering and financial record-keeping obligations.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of the last transaction processed on the account, or as required by applicable law.
• Transaction records: Retained for a minimum of seven (7) years from the date of the transaction in accordance with applicable financial regulations.
• Customer support communications: Retained for a period of three (3) years following the resolution of the relevant support interaction.
• Marketing consent records: Retained until you withdraw consent and for a reasonable period thereafter as evidence of the consent given.
• Technical and device data: Retained in aggregated or anonymised form following account closure, where it cannot be attributed to a specific individual.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in manner that prevents reconstruction of the original data.

Data Security

Sabas99 takes the security of your personal data seriously and implements a range of technical and organisational measures designed to protect your information against unauthorised access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• 256-bit SSL (Secure Socket Layer) encryption for all data transmitted between the Platform and your device.
• Encrypted storage of all personal data and financial records in secured data environments.
• Role-based access controls limiting employee access to personal data strictly to those whose job functions require it.
• Multi-factor authentication for internal platform administration systems.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Formal data breach response and notification procedures.
• Staff training on data protection obligations and information security best practices.

Notwithstanding the security measures in place, no system of data transmission or storage can be guaranteed to be entirely secure. You are responsible for keeping your own account credentials confidential and for taking reasonable steps to secure the device from which you access the Platform.

Cookies & Tracking Technologies

Sabas99 uses cookies and similar tracking technologies (including web beacons and local storage) on the Platform. Cookies are small text files stored on your device that enable the Platform to recognise you across sessions, remember your preferences, and analyse how users interact with the Platform.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Platform to function. These include session management cookies that keep you logged in during an active game session. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences, such as language selection, display settings, and previously used payment methods. Disabling these may reduce personalisation.
• Functional Cookies: Remember your preferences, such as language selection, display settings, and previously used payment methods. Disabling these may reduce personalisation.
• Security Cookies: Used to detect suspicious login behaviour, prevent fraudulent account access, and enforce rate limiting on sensitive actions such as password resets and withdrawal requests.

9.2 Cookie Consent and Control

Non-essential cookies are placed only where you have provided consent, either via the cookie consent banner displayed on your first visit to the Platform or through your account preferences. You may update your cookie preferences at any time. Please note that disabling strictly necessary cookies will prevent you from accessing core Platform functionality.

Most web browsers allow you to manage cookie settings through the browser menu. Rejecting cookies at the browser level may affect your experience on the Sabas99 Platform and on other websites you visit.

International Data Transfers

The Sabas99 Platform serves users primarily in Malaysia. Certain third-party service providers engaged by Sabas99 — including payment processors, KYC verification services, and cloud infrastructure providers — may be located in or operate from jurisdictions outside Malaysia. Where personal data is transferred to such providers, Sabas99 ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that required under applicable Malaysian data protection law.

Such safeguards may include contractual data processing agreements containing standard data protection clauses, certification schemes recognised by applicable regulatory authorities, or reliance on adequacy determinations where the recipient jurisdiction has been assessed as providing an adequate level of data protection.

By using the Sabas99 Platform, you acknowledge that your personal data may be transferred to, stored in, and processed in jurisdictions other than Malaysia as described in this section.

Your Data Rights

As a data subject whose personal data is processed by Sabas99, you hold a number of rights in relation to your personal information. These rights are described below and may be exercised by contacting our support team as described in Section 15.

To exercise any of the above rights, please contact our support team via live chat or at [email protected]. We will respond to all verified requests within thirty (30) calendar days. We may request proof of identity before processing a data rights request to ensure that we do not disclose or modify data in response to fraudulent requests.

Protection of Minors

The Sabas99 Platform is strictly intended for adults aged 21 years and above. The Platform does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the KYC process and is mandatory for all registered players.

If Sabas99 becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, all associated data will be reviewed, and the account will be closed in accordance with our safeguarding obligations. Any winings accumulated on an underage account will be forfeited.

Third-Party Services & External Links

The Sabas99 Platform may contain references to or integrations with third-party services, including payment gateways, game providers, and data analytics platforms. These third parties operate under their own privacy policies, for which Sabas99 assumes no responsibility. Players should review the privacy policies of any third-party service they interact with in connection with their use of the Platform.

Sabas99 does not control the data practices of third-party service providers beyond the contractual obligations imposed upon them as Data Processors. Where a third party processes personal data as an independent Data Controller — such as a bank processing a payment instruction — their processing is governed entirely by their own privacy notice.

Policy Amendments

Sabas99 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, Platform features, or our data processing practices. All revisions will be published on this page with an updated effective date.

Where amendments are material — that is, where they significantly change how your personal data is used or your rights in relation to it — Sabas99 will notify registered players via the email address associated with their account and provide a notice on the Platform no less than fourteen (14) days before the changes take effect, unless immediate implementation is required by law.

Your continued use of the Platform following the effective date of any update constitutes acceptance of the revised Policy. If you do not accept the revised terms, you should cease use of the Platform and contact support to request account closure.

Contact Us — Data Protection Inquiries

For all privacy-related questions, personal data access requests, correction requests, erasure requests, or complaints relating to Sabas99's handling of your personal data, please contact using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available24/7 via the Platform in English, Bahasa Melayu, and Mandarin.
• Subject Line: Please mark data rights requests with the subject "Data Privacy Request — [Your Username]" to ensure prompt routing to our data protection team.

We aim to acknowledge all data rights requests within five (5) business days and to provide a substantive response within thirty (30) calendar days. If the complexity of your request requires additional time, we will notify you of the extended timeline and the reason for the delay.

For all other support queries — account issues, payment enquiries, responsible gambling assistance — please visit ourFAQ page or contact our24/7 live chat support team directly.