Privacy Policy

01. Who We Are

jom91 ("jom91", "we", "us", "the Platform") operates the online casino and sports betting platform accessible at jom91.app. jom91 is the data controller responsible for personal data collected through the Platform. We operate under an international gaming authority licence and are bound by the data protection obligations imposed thereunder.

For the purposes of this Privacy Policy, "personal data" means any information that identifies or can reasonably be used to identify a natural person, whether alone or in combination with other information. "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, and deletion.

02. Data We Collect

jom91 collects personal data through several channels and categories:

We do not collect sensitive special category personal data (such as health data, racial or ethnic origin, or political opinions) unless specifically required for responsible gaming interventions and with your explicit consent.

03. How We Use Your Data

jom91 uses personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your jom91 account; processing login authentication including two-factor verification.
• Payment Processing: Facilitating deposits via Touch 'n Go eWallet, Boost, Maybank, CIMB, and Public Bank; processing withdrawal requests; reconciling transaction records.
• KYC & Age Verification: Verifying your identity and confirming you are at least 21 years of age, as required by our gaming licence obligations.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent transactions, money laundering, account takeovers, and other unlawful activity on the Platform.
• Regulatory Compliance: Meeting reporting, record-keeping, and audit obligations imposed by our international gaming authority licence and applicable laws.
• Responsible Gaming: Monitoring gaming activity patterns to identify potential problem gambling behaviours and to administer self-exclusion and limit requests.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve game selection, user interface, and payment flow performance.
• Communications: Sending account notifications, security alerts, and — where you have opted in — promotional communications about jom91 offers and products.

04. Legal Basis for Processing

For each category of personal data processing, jom91 relies on one or more of the following legal bases:

• Contractual Necessity: Processing required to fulfil the Terms and Conditions you agreed to upon registration — including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with our gaming licence conditions, anti-money laundering regulations, and KYC obligations.
• Legitimate Interests: Processing for fraud detection, security monitoring, and platform improvement, where our interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications, where you have provided explicit opt-in consent. You may withdraw this consent at any time via your account notification settings.

05. Data Sharing

jom91 does not sell, rent, or trade personal data to third-party marketing organisations or data brokers. We share personal data only in the following circumstances:

• Payment Processors: Transaction data shared with Touch 'n Go eWallet, Boost, and banking partners (Maybank, CIMB, Public Bank) as necessary to process your deposits and withdrawals.
• Identity Verification Partners: Identity document data shared with licensed KYC and AML compliance service providers for age and identity verification purposes.
• Gaming Software Providers: Minimum necessary session data shared with game studios to facilitate gameplay and resolve disputes.
• Regulatory Authorities: Data disclosed to our gaming licence authority, financial intelligence units, or law enforcement agencies where legally required or as directed under our licence obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all assets, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party processors engaged by jom91 are subject to data processing agreements that require them to maintain confidentiality, implement appropriate security measures, and process data only as instructed by jom91.

06. Cookies & Tracking Technologies

6.1 jom91 uses cookies and similar tracking technologies (local storage, session tokens) to operate the Platform, maintain your login session, and analyse usage patterns. Cookies are small text files stored on your device.

6.2 Essential Cookies are required for the Platform to function — these include authentication session cookies and security tokens. These cannot be disabled without impairing your ability to use jom91.

6.3 Analytics Cookies collect aggregated, anonymised data about how members navigate the Platform. This data is used solely for internal performance analysis and is not shared with advertising networks.

6.4 You may manage cookie preferences through your browser settings. Blocking all cookies will prevent login and use of the Platform.

07. Data Retention

jom91 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by our licence obligations:

• Account and identity data: Retained for a minimum of five (5) years from account closure, or as required by anti-money laundering regulations.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming and session logs: Retained for a minimum of three (3) years from the session date.
• Support communications: Retained for two (2) years from the date of the communication, or until the associated account is closed, whichever is later.

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

08. Your Rights

Subject to applicable law and our licence obligations, you have the following rights in relation to your personal data held by jom91:

• Right of Access: You may request a copy of the personal data jom91 holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. For certain fields (e.g. name on KYC records), corrections require documentary verification.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose collected, subject to overriding legal retention obligations.
• Right to Restriction: You may request that jom91 restrict processing of your data in certain circumstances, such as while a correction request is being investigated.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, and to direct marketing communications at any time.
• Right to Portability: Where technically feasible, you may request a copy of your personal data in a structured, commonly used, machine-readable format.

To exercise any of these rights, contact the jom91 support team via live chat or at [email protected]. jom91 will respond to verified requests within thirty (30) calendar days.

09. Data Security

9.1 jom91 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS 1.2+ encryption for all data in transit between your device and jom91's servers;
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial identifiers;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular penetration testing and security audits by independent third-party security firms;
• Multi-factor authentication required for all administrative access to systems holding personal data.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jom91 will notify you without undue delay and will take all reasonable steps to contain and remediate the breach.

10. Children's Privacy

The jom91 platform is strictly for adults aged 21+. jom91 does not knowingly collect personal data from persons under 21 years of age. If we become aware that a registered account belongs to a person under 21, the account will be immediately closed, deposits returned, and all personal data associated with the account deleted promptly in accordance with applicable law.

Parents or guardians who believe their minor has registered an account on jom91 should contact our support team immediately at [email protected] for urgent account closure.

11. International Data Transfers

11.1 As an internationally licensed platform, jom91 may process or store personal data on servers located outside Malaysia. Where personal data is transferred to third countries, jom91 ensures that equivalent protections are in place, including through standard contractual clauses, adequacy decisions, or binding corporate rules as applicable.

11.2 By using the jom91 platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Malaysia where data protection laws may differ from those in Malaysia. jom91 takes all reasonably practicable steps to ensure such transfers are conducted in a manner that protects your data rights.

12. Changes to This Privacy Policy

12.1 jom91 may update this Privacy Policy from time to time to reflect changes in legal requirements, our data processing practices, or the services we provide. Material changes will be communicated to registered members via email to the address on file, with at least seven (7) days' notice before the revised Policy takes effect.

12.2 The effective date at the top of this Policy indicates when the current version came into force. Archived versions of previous Privacy Policies are available upon request through the jom91 support team.

12.3 Your continued use of the jom91 platform after the effective date of any revised Privacy Policy constitutes your acceptance of the changes.

13. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the personal data jom91 holds about you, please contact our Data Protection team:

• Live Chat: Available 24/7 on the jom91 platform — the fastest channel for urgent data requests.
• Email: [email protected]

Please include your registered username and a clear description of your request. jom91 will acknowledge your request within two (2) business days and respond substantively within thirty (30) calendar days of identity verification.