Privacy Policy — melodi99

1 Introduction

melodi99 ("melodi99", "we", "us", "our") operates the online casino and sports betting information platform accessible at https://melodi99.cam. This Privacy Policy ("Policy") governs how melodi99 collects, uses, stores, shares and protects the personal data of individuals ("Users", "you", "your") who access or use our platform, including website visitors, registered account holders and any individual who contacts melodi99 directly.

This Policy is written in English and applies to all Users accessing melodi99, with particular relevance to Users located in Malaysia. Where reference is made to applicable law, this includes relevant Malaysian data protection and consumer legislation as well as any international standards that melodi99 voluntarily adopts in the interest of best practice.

2 Definitions

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

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, directly or in combination with other information.
• "Processing" means any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means melodi99, 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 melodi99 in accordance with our instructions and this Policy.
• "Sensitive Personal Data" means data revealing racial or ethnic origin, political opinions, religious beliefs, health information, biometric data or other categories that warrant heightened protection.
• "KYC" means Know Your Customer — the identity and address verification process required to confirm account eligibility and prevent fraud and financial crime.
• "Cookies" means small text files placed on a User's device by the melodi99 platform to support functionality, analytics and security.

3 Data We Collect

melodi99 collects the following categories of personal data from Users, depending on the nature of their interaction with the platform:

melodi99 does not intentionally collect Sensitive Personal Data unless legally required for regulatory compliance purposes, such as where identity verification involves health-related documentation in exceptional KYC scenarios.

4 How We Collect Data

melodi99 collects personal data through the following means:

• Direct provision by the User: Data submitted during account registration, KYC document upload, payment processing, support interactions and the configuration of responsible gambling tools.
• Automated technical collection: Device and technical data collected via cookies, web beacons and server logs when you access the melodi99 platform. See Section 8 for our full Cookies policy.
• Third-party service providers: Identity verification agencies, payment processors (including e-wallet providers such as Touch 'n Go eWallet, Boost and GrabPay), fraud prevention services and analytics partners may provide melodi99 with data about Users in the course of service delivery.
• Transaction records: Financial institutions and payment networks through which MYR deposits and withdrawals are processed may generate records that melodi99 receives as part of the transaction confirmation process.

5 Data Processing & Purposes

melodi99 processes personal data for the following specific and legitimate purposes:

• Account administration: Creating, maintaining and managing registered User accounts, including login authentication and profile management.
• Identity and age verification: Confirming that Users meet the 21+ minimum age requirement and are who they claim to be, in compliance with KYC obligations.
• Payment processing: Facilitating MYR deposits and withdrawals using methods including DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, Touch 'n Go eWallet, Boost, GrabPay and USDT TRC20.
• Fraud prevention and security: Detecting, investigating and preventing fraudulent activity, account takeovers, money laundering and other prohibited conduct on the platform.
• Responsible gambling management: Monitoring account activity to identify potential problem gambling indicators and administering deposit limits, self-exclusion and cool-off periods at the User's request.
• Legal and regulatory compliance: Meeting obligations under applicable Malaysian and international law, including record-keeping, reporting and cooperation with lawful authority requests.
• Service improvement: Analysing aggregated and anonymised usage data to improve platform functionality, content relevance and User experience for Malaysian players.
• Communication: Sending account-related notifications, security alerts, policy update notices and, where opted in, promotional communications.

6 Legal Basis for Processing

melodi99 processes personal data on the following legal bases, applied as appropriate to each processing activity:

• Contractual necessity: Processing required to perform the account agreement between melodi99 and the User — including account setup, payment processing and service delivery.
• Legal obligation: Processing required to comply with applicable laws, including KYC obligations, anti-money laundering requirements and lawful regulatory requests.
• Legitimate interests: Processing necessary for melodi99's legitimate business interests — including fraud prevention, platform security, responsible gambling monitoring and service improvement — where these interests are not overridden by Users' rights and expectations.
• Consent: Where melodi99 requests consent for a specific processing activity, such as the receipt of promotional communications, that consent may be withdrawn at any time by contacting melodi99 support. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

7 Payment Data

melodi99 takes particular care with payment-related personal data given its financial sensitivity. All MYR payment transactions, whether processed via e-wallets (Touch 'n Go eWallet, Boost, GrabPay), bank transfer (Maybank, CIMB, Public Bank, Hong Leong Bank), FPX, DuitNow or cryptocurrency (USDT TRC20), involve the collection and processing of payment identifiers.

8 Cookies & Tracking Technologies

The melodi99 platform uses cookies and similar tracking technologies to support essential platform functionality, maintain session security, analyse aggregated usage patterns and improve the User experience. By continuing to use the melodi99 platform, you consent to the use of cookies in accordance with this section.

melodi99 uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function correctly, including maintaining login sessions, security tokens and language preferences. These cannot be disabled without affecting platform functionality.
• Performance and analytics cookies: Used to collect aggregated and anonymised data about how Users interact with the melodi99 platform, helping us identify areas for improvement. No personally identifiable information is retained in analytics reports.
• Functional cookies: Allow the platform to remember preferences such as display settings and responsible gambling configurations set by the User.
• Security cookies: Support fraud detection, login anomaly identification and the prevention of cross-site request forgery.

Most browsers allow you to block or delete cookies through browser settings. Note that disabling strictly necessary cookies may affect the operation of the melodi99 platform and prevent account login.

9 Third-Party Disclosure

melodi99 does not sell, rent or trade personal data to third parties for their own commercial purposes. We may disclose personal data to the following categories of recipients, strictly on a need-to-know basis and under appropriate contractual or legal controls:

• Payment service providers: E-wallet operators (including Touch 'n Go eWallet, Boost, GrabPay), financial institutions (Maybank, CIMB, Public Bank, Hong Leong Bank) and cryptocurrency processing services, for the purpose of executing and verifying User transactions.
• Identity verification providers: KYC and age verification service partners used to confirm account eligibility and prevent fraudulent registrations.
• Fraud prevention and security services: Specialist third-party providers that assist melodi99 in detecting, investigating and preventing account fraud, collusion and financial crime.
• Platform technology providers: Hosting, infrastructure, analytics and customer support technology vendors that process data on behalf of melodi99 under strict data processing agreements.
• Regulatory and law enforcement authorities: Where required by applicable law, court order or regulatory instruction, melodi99 may disclose personal data to competent authorities. We will notify affected Users where legally permitted to do so.

10 Data Retention

melodi99 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention principles apply:

• Active account data: Retained for the duration of the active account relationship and for a defined period thereafter to address any post-closure queries, disputes or regulatory requirements.
• Transaction and financial records: Retained for the period required by applicable anti-money laundering and financial record-keeping obligations, which may extend to several years following the last transaction.
• KYC documentation: Retained for the legally required period following account closure or the last verification event, in accordance with applicable compliance obligations.
• Support and communication records: Retained for a reasonable period to support dispute resolution and service quality improvement.
• Marketing consent records: Retained for as long as the consent remains valid and for a reasonable period thereafter to demonstrate compliance if challenged.

When personal data is no longer required, melodi99 takes appropriate steps to securely delete or anonymise it in accordance with our data disposal procedures.

11 User Rights

Subject to applicable law and any overriding legal obligations, Users have the following rights in relation to their personal data held by melodi99:

• Right of access: You may request a copy of the personal data melodi99 holds about you, along with information about how it is used.
• Right to rectification: You may request correction of inaccurate or incomplete personal data. You are encouraged to keep your account profile details current and accurate at all times.
• Right to erasure: In certain circumstances, you may request deletion of your personal data. This right is subject to melodi99's legal retention obligations — data required for regulatory compliance cannot be deleted on request.
• Right to restrict processing: You may request that melodi99 limit the processing of your personal data in certain defined circumstances, such as where accuracy is contested or processing is unlawful.
• Right to object: Where processing is based on legitimate interests, you may object to that processing. melodi99 will review the objection and cease processing unless compelling legitimate grounds override your rights.
• Right to withdraw consent: Where processing is based solely on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing.

12 Protection of Minors

melodi99 is strictly an adults-only platform. Casino-style gambling and sports betting are available exclusively to individuals aged 21 years and above. melodi99 does not knowingly collect, use or retain personal data from individuals under the age of 21.

Where melodi99 identifies or has reasonable grounds to believe that personal data has been collected from a minor, that account will be immediately suspended, all associated personal data will be reviewed and, where appropriate, securely deleted. Any funds deposited by or on behalf of a minor will be held pending investigation and returned to the source payment method where possible.

If you are a parent or guardian and believe your child has accessed the melodi99 platform and provided personal data, please contact us immediately at the address provided in Section 15 of this Policy.

13 Security Measures

melodi99 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure and destruction. These measures include but are not limited to:

• Encrypted data transmission using industry-standard TLS protocols for all communications between User devices and melodi99 servers.
• Access controls limiting internal access to personal data to authorised personnel with a documented operational requirement.
• Regular review of system security configurations, including vulnerability assessments appropriate to the nature of the data processed.
• Staff training on data protection obligations and information security best practices.
• Incident response procedures for the prompt identification, containment and reporting of data security incidents where notification obligations apply.

14 Policy Amendments

melodi99 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, platform functionality, data processing practices or our organisational structure. The date of the most recent revision is displayed at the top of this document.

Where changes are material — for example, where we introduce a new category of data processing or a new third-party disclosure — melodi99 will provide reasonable prior notice through the platform or by email to registered Users. Your continued use of the melodi99 platform following the effective date of any amendment constitutes acceptance of the revised Policy.

If you do not accept an amendment to this Policy, you should discontinue use of the platform and may request account closure by contacting melodi99 support. We will process your request in accordance with our data retention obligations.

15 Contact Us

If you have questions, concerns or requests relating to this Privacy Policy or the way in which melodi99 handles your personal data, please contact the melodi99 data team through the following channel. All privacy-related enquiries are handled with priority by our support team.