Kodomo99 Privacy Policy

01Introduction

This Privacy Policy ("Policy") describes how Kodomo99 ("we", "us", "our") collects, uses, stores, and discloses personal information provided by individuals ("you", "your", "User") who access or use the Kodomo99 platform at kodomo99.cam, including all games, sports betting markets, live dealer services, account management features, and customer support channels.

Kodomo99 is committed to responsible data stewardship. We handle personal information only for legitimate, defined purposes and only to the extent reasonably necessary to deliver, secure, and improve our services to eligible Malaysian players and other permitted users. This Policy is intended to give you clear, practical information about what data we hold, why we hold it, and what rights you have in relation to it.

This Policy should be read alongside the Kodomo99 Terms & Conditions and Responsible Gambling Policy, which together constitute the full regulatory framework governing your relationship with the Platform. By creating a Kodomo99 account or continuing to use the Platform after the effective date of any revised version of this Policy, you acknowledge that you have read and understood its contents.

02Definitions

The following terms carry the meanings set out below wherever they appear in this Policy:

03Information We Collect

Kodomo99 collects Personal Data through several channels, depending on how you interact with the Platform. The categories of information we collect include:

Registration and Account Data: When you create a Kodomo99 account, we collect your full legal name, date of birth, email address, Malaysian mobile telephone number, country of residence, and a chosen username and password. This information is required to establish and maintain your Account.

Identity Verification (KYC) Data: Prior to processing withdrawals or where required under our anti-money laundering obligations, we collect copies of government-issued identity documents such as a Malaysian MyKad or valid passport, and proof of residential address. This may also include source-of-funds documentation for higher-value transactions.

Transaction and Financial Data: We record all deposits, withdrawals, and wagering activity associated with your Account. This includes payment method details — such as the masked account numbers associated with FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, and Hong Leong transactions — as well as cryptocurrency wallet addresses used in connection with BTC, ETH, USDT, and BNB deposits and withdrawals.

Device and Technical Data: When you access the Platform, we automatically collect certain technical information including your IP address, device type, operating system, browser type and version, session duration, and pages accessed. This data is used for security, fraud prevention, and Platform performance monitoring.

Communications Data: If you contact Kodomo99 support via email, live chat, or any other channel, we retain records of those communications including their content and associated metadata. This data is used to manage your enquiry and improve support quality.

Responsible Gambling Data: Where you use deposit limit, loss limit, session alert, cooling-off, or self-exclusion tools, we record the relevant preferences and instructions. This data is used exclusively to enforce your chosen protections and is treated with heightened confidentiality.

04Data Processing & Legal Basis

Kodomo99 processes Personal Data only where a valid legal basis exists for doing so. The legal bases we rely upon are as follows:

05How We Use Your Information

Personal Data collected by Kodomo99 is used for the following purposes:

• To create, verify, and maintain your Kodomo99 Account.
• To process deposits and withdrawals via your chosen payment method, including FPX, DuitNow, eWallet providers, and cryptocurrency channels.
• To deliver casino games, live dealer tables, and sports betting markets to eligible users.
• To administer promotional offers, bonuses, and rewards programmes.
• To complete identity and age verification as required prior to withdrawal or when otherwise mandated by our licence obligations.
• To monitor transactions and gameplay patterns for fraud, collusion, and anti-money laundering compliance purposes.
• To enforce responsible gambling tools including deposit limits, loss limits, and self-exclusion instructions.
• To respond to Account enquiries, support requests, and formal complaints submitted through official Kodomo99 channels.
• To maintain Platform security, detect unauthorised access, and prevent the operation of multiple accounts by a single individual.
• To send transactional communications, including Account verification messages, password reset notifications, deposit and withdrawal confirmations, and important Policy updates.
• To send marketing communications where you have provided Consent, limited to Kodomo99 promotions and Platform updates. You may withdraw marketing consent at any time.
• To conduct internal analytics and platform performance analysis to improve the Kodomo99 user experience for Malaysian players.

Kodomo99 will not use your Personal Data for automated profiling that produces legal or similarly significant effects without first obtaining your explicit consent or making an alternative decision pathway available to you.

06Data Sharing & Disclosure

Kodomo99 does not sell Personal Data to third parties. We do not share your information with any party for their independent marketing purposes. Data sharing is limited to the following categories of recipients and circumstances:

• Payment Processors and Banking Partners: Financial institutions and payment service providers necessary to process your deposits and withdrawals, including FPX network operators, DuitNow, and eWallet providers such as Touch 'n Go, Boost, and GrabPay. These parties receive only the information necessary to complete the transaction.
• Identity Verification Providers: Third-party KYC and anti-money laundering compliance services used to verify the identity and age of account holders. These providers operate under strict data processing agreements and may not use your data for any purpose other than providing the verification service.
• Technology and Infrastructure Providers: Hosting, cloud storage, security monitoring, and platform software providers who process data on Kodomo99's behalf and under documented data processing agreements that prohibit independent use of the data.
• Licensed Game Studios and Content Suppliers: Where gameplay data must be transmitted to content suppliers to deliver and settle game outcomes, only the data strictly required for game operation is shared. No personally identifiable information is transmitted beyond what is technically necessary.
• Regulatory and Law Enforcement Authorities: Kodomo99 will disclose Personal Data to competent authorities where required to do so by applicable law, valid court order, or direction from our licensing authority. We will endeavour to notify affected Users of any such disclosure where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all Platform assets, User data may be transferred to the acquiring entity, subject to the same data protection obligations set out in this Policy. Users will be notified prior to any such transfer.

07Data Retention

Kodomo99 retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, comply with applicable legal and regulatory obligations, and resolve any disputes or enforce agreements. The following general retention principles apply:

• Account Data: Retained for the duration of your active Account and for a period of up to seven (7) years following Account closure, in accordance with applicable anti-money laundering record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification, or longer if required by the applicable licensing authority or AML regulations.
• Transaction Records: Retained for a minimum of seven (7) years to satisfy financial record-keeping obligations.
• Support Communications: Retained for up to three (3) years from the date of the last communication, unless retention is required beyond that period for dispute resolution or legal proceedings.
• Responsible Gambling Records: Self-exclusion instructions and limit settings are retained for the duration of the exclusion period plus six (6) months, to prevent premature reinstatement.
• Technical and Device Data: Session logs and IP address records are retained for up to twelve (12) months for security and fraud investigation purposes.

When data is no longer required for its original purpose and no legal basis for continued retention applies, Kodomo99 will securely delete or anonymise the data in accordance with its data destruction procedures.

08Security Measures

Kodomo99 implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes the following controls:

• 256-bit SSL/TLS encryption applied to all data transmitted between your device and the Kodomo99 Platform.
• Encrypted storage for sensitive Personal Data and KYC documentation held on Platform infrastructure.
• Role-based access controls ensuring that internal personnel can only access Personal Data necessary for their specific function.
• Multi-factor authentication requirements for administrative systems that process User Personal Data.
• Routine security assessments and penetration testing of Platform systems and data storage environments.
• Automated transaction monitoring to detect unusual activity patterns consistent with fraud, identity theft, or Account compromise.

Despite these measures, no online service can guarantee absolute data security. You are responsible for maintaining the confidentiality of your own Account credentials. If you suspect your Account has been compromised, please contact Kodomo99 support immediately at [email protected] (non-clickable).

09Cookies & Tracking

The Kodomo99 Platform uses cookies and similar tracking technologies to maintain session continuity, improve Platform performance, and support security functions. Cookies are small data files stored on your device when you visit the Platform.

The categories of cookies used by Kodomo99 are as follows:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication cookies and security tokens. They cannot be disabled without affecting core Platform functionality.
• Functional Cookies: Used to remember your preferences such as language selection, account settings, and display options across sessions.
• Performance and Analytics Cookies: Used to collect anonymised data about how Users navigate the Platform, which pages are most visited, and where errors occur. This data is used to improve the Platform experience. These cookies are only placed with your Consent.
• Security and Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, including multi-account detection and bot mitigation. These are treated as strictly necessary due to our legal obligations.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair your ability to access and use the Platform. Consent for non-essential cookies can be withdrawn at any time by adjusting your browser settings or contacting Kodomo99 support.

10User Rights

Subject to applicable data protection law and the retention obligations described in Section 7, Kodomo99 account holders have the following rights in relation to their Personal Data. Requests should be submitted in writing to [email protected] (non-clickable).

11Protection of Minors

The Kodomo99 Platform is strictly intended for individuals aged 21 and above. We do not knowingly collect Personal Data from any person under the age of 21. Account registration requires accurate date-of-birth information, and Kodomo99 actively uses KYC verification to confirm that all account holders meet the minimum age requirement.

If Kodomo99 discovers or has reasonable grounds to believe that an Account has been registered by or on behalf of a person under the age of 21, the Account will be immediately suspended, all pending transactions will be voided, and any balance will be returned to the relevant payment source following verification. The associated Personal Data will be securely deleted in accordance with our data destruction procedures, except where retention is required for legal or regulatory purposes.

If you have reason to believe that a minor may have accessed or registered an Account on the Kodomo99 Platform, please contact our support team immediately so that appropriate steps can be taken.

12Amendments to This Policy

Kodomo99 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or Platform functionality. Where amendments are material — meaning they may affect how your Personal Data is used or what rights you have — we will notify you via a site-wide announcement, email to your registered address, or both, not less than fourteen (14) days before the updated Policy takes effect.

Continued use of the Kodomo99 Platform following the effective date of any amendment constitutes your acknowledgement of the revised Policy. The version date displayed at the top of this page reflects the most recent revision. Previous versions are available from Kodomo99 support upon request.

13Contact Us

For any questions, concerns, or formal requests relating to this Privacy Policy or the Personal Data Kodomo99 holds about you, please contact our support team. We aim to acknowledge all privacy-related enquiries within 5 business days and to provide a substantive response within 30 calendar days.

General Support & Privacy Enquiries
Email (non-clickable): [email protected]
Available: 24 hours a day, 7 days a week

For questions about your account data specifically, please log in to your Kodomo99 Account and navigate to the Account Settings section, where you can review your stored information and update communication preferences directly.

For responsible gambling-related enquiries, including self-exclusion requests and limit adjustments, please visit the dedicated Responsible Gambling page, or contact support directly referencing your account and the specific tool you wish to activate.

To review the full framework governing your use of the Platform, including wagering rules, account eligibility, and payment terms, please read the Kodomo99 Terms & Conditions.