Privacy Policy

This Privacy Policy ("Policy") issued by Kaya100 ("we", "usour", "the Platform") and applies to all personal data collected from users ("you", "the User", "the Player") of the Kaya100 website atkaya100.cam and all associated services, mobile applications, and communications (collectively, "the Services").

Kaya100 operates as an online casino and sports betting platform serving the Malaysia market. In the course of providing our Services — including account registration, payment processing, KYC verification, customer support, and promotional communications — we collect, process, and store personal data about you. This Policy governs all such data processing activities.

We are committed to handling your personal data responsibly and in accordance with applicable protection law. This Policy is designed to be read and understood by all users — not only legal professionals. If any part of this Policy is unclear to you, please contact our support team at support@kaya100.cam and we will explain it in plain terms.

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 identify a natural person, directly or indirectly, including name, identification number, contact details, financial data, and online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, Kaya100.
• "Data Processor" means any third party that processes Personal Data on Kaya100's behalf pursuant to a written data processing agreement.
• "KYC" (Know Your Customer) means the identity and age verification process required of all registered users, involving submission of government-issued identification and supporting documents.
• "Cookies" means small text files placed on your device by the Kaya100 website that collect and store certain data about your browsing session and preferences.
• "Sensitive Data" means a subset of Personal Data that warants heightened protection, including but not limited to financial account details, government-issued identification numbers, and biometric data.

Kaya100 collects personal data across several categories, depending on the nature of your interaction with the Platform. The table below sets out what we collect and why:

Kaya100 collects personal data through the following methods and touchpoints:

4.1 Directly from You

• During account registration, when you provide your name, date of birth, email address, and Malaysian phone number.
• During the KYC verification process, when you submit identity documents and supporting proof-of-address materials.
• When you initiate a deposit or withdrawal, through which payment method details are captured.
• Through your interactions with our customer support team via live chat, WhatsApp, or email.
• When you complete surveys, respond to promotional communications, or participate in competitions.

4.2 Automatically

• Through cookies and similar tracking technologies placed on your device when you visit the Kaya100 website (see Section 8for full cookie details).
• Through server-side logs that record your IP address, device identifiers, browser type, access timestamps, and pages visited.
• Through our gaming platform systems, which record all bet placements, game sessions, and account activity as part of normal platform operation.

4.3 From Third Parties

• From payment service providers (such as Touch'n Go eWallet, DuitNow, FPX operators, and banking partners like Maybank and CIMB) in connection with transaction verification and fraud screening.
• From identity verification and KYC service providers engaged to assist in document authenticity verification.
• From fraud prevention and anti-money laundering (AML) screening services, where required by applicable regulatory obligations.

Kaya100 processes your personal data for the following specific purposes. We do not use your data for any purpose not identified here:

• Account Management: Creating, maintaining, and operating your registered Kaya100 account, including authentication and access control.
• KYC & Age Verification: Fulfilling our legal obligation to verify that all registered players are aged 21 years or above and to confirm their identity for regulatory compliance.
• Payment Processing: Facilitating MYR deposits and withdrawals via Touch 'n Go eWallet, DuitNow, FPX, Maybank, CIMB, Public Bank, GrabPay, Boost, and other supported payment channels.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent transactions, money laundering, account compromise, bonus abuse, and other prohibited activities.
• Platform Operation: Providing access to our gaming products, processing bets, calculating results, and maintaining the technical infrastructure required for Service delivery.
• Customer Support: Responding to your queries, resolving disputes, and providing assistance through our live chat, WhatsApp, and email support channels.
• Responsible Gambling: Monitoring gaming patterns to identify potential problem gambling behaviour and to operate our self-exclusion, deposit limit, and responsible gambling tools.
• Legal & Regulatory Compliance: Meeting our obligations under applicable anti-money laundering (AML), counter-terrorist financing (CTF), and data protection regulations.
• Marketing Communications (opt-in only): Sending you relevant promotional offers, bonus notifications, and platform updates, where you have explicitly opted in to receiving such communications.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the performance, usability, and features of the Kaya100 Platform.

Kaya100 processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under our Terms & Conditions — including account management, payment processing, and Service delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations — including KYC verification, AML/CTF screening, age verification, and financial record retention obligations.
• Legitimate Interests: Processing carried out in pursuit of Kaya100's legitimate business interests where these interests do not override your fundamental rights — including fraud prevention, platform security, and internal analytics.
• Consent: Processing carried out based on your explicit and freely given consent — specifically, sending opt-in marketing communications and placing non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Kaya100 does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data with trusted third parties only in the following circumstances, and only to the extent necessary for the stated purpose:

7.1 Service Providers (Data Processors)

We engage carefully selected third-party service providers who process personal data on our behalf pursuant to written data processing agreements that bind them to confidentiality and data security obligations equivalent to or exceding our own. These providers include payment gateways (Touch 'n Go, DuitNow, FPX operators), KYC and identity verification platforms, IT infrastructure and hosting providers, and customer support software vendors.

7.2 Regulatory & Law Enforcement Authorities

Kaya100 may disclose personal data to regulatory bodies, law enforcement agencies, financial intelligence units, or courts where required to do so by applicable law, court order, regulatory directive, or where we reasonably believe disclosure is necessary to prevent fraud, money laundering, or other criminal activity.

7.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or other corporate restructuring involving Kaya100, personal data held by the Platform may be transferred to the acquiring or successor entity, subject to equivalent privacy protections and notification to affected users.

Kaya100 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your login session, analyse usage patterns, and support fraud detection. The following categories of cookies are used:

You may manage cookie preferences through your browser settings. Note that disabling essential cookies may impair the functionality of the Platform. Kaya100 does not use third-party advertising cookies or retargeting technologies.

Kaya100 retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law. Our general retention periods are as follows:

• Active account data (identity, contact, gaming activity) is retained for the duration of your account relationship with Kaya100 and for a period offive (5) years following account closure, in compliance with financial record-keeping obligations.
• KYC documents (identity documents, proof of address) are retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later, in accordance with AML regulations.
• Transaction records (deposit and withdrawal history) are retained for a minimum of five (5) years from the date of each transaction, for financial audit and regulatory compliance purposes.
• Support communications (live chat logs, email records) are retained for two (2) years from the date of the interaction, for quality assurance and dispute resolution purposes.
• Marketing consent records are retained for the duration of the consent period and for one year following withdrawal of consent, for compliance evidence purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any individual. Where data is anonymised rather than deleted, it may be retained indefinitely for statistical and analytical purposes.

Kaya100 implements a comprehensive range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the Kaya100 Platform is encrypted using 256-bit SSL/TLS encryption, ensuring that your data cannot be intercepted in transit.
• Access Controls: Access to personal data held by Kaya100 is strictly role-based and limited to authorised personnel who require access to fulfil their specific job functions. Access is authenticated and logged.
• Secure Data Storage: Personal data is stored on secure servers with multiple layers of physical and logical access controls, including firewall protection, intrusion detection systems, and regular vulnerability assessments.
• Employee Training: All Kaya100 personnel who handle personal data receive regular training on data protection obligations, security best practices, and incident response procedures.
• Incident Response: In the event of a data security incident that poses a risk to your rights, Kaya100 will notify affected users as promptly as practicable, providing details of the nature of the incident and the steps taken to address it.

As a registered user of Kaya100, you hold the following rights in respect of your personal data. To exercise any of these rights, please submit a written request tosupport@kaya100.cam with the subject line "Data Rights Request – [Your Username]". We will respond within a reasonable timeframe and in any event within 30 days of receipt.

The Kaya100 Platform is strictly intended for individuals aged21 years of age or older. Kaya100 does not knowingly collect personal data from any person under the age of 21.

All accounts are subject to mandatory KYC age verification. If Kaya100 becomes aware that personal data has been collected from an individual below the minimum age of 21, we will immediately suspend the relevant account, delete all personal data associated with that account, and reverse any financial transactions where possible.

If you are a parent or guardian and believe that a person under the age of 21 in your care has registered an account on Kaya100, please contact us immediately at support@kaya100.cam.

Kaya100's primary operational infrastructure is hosted within secure data centre environments. In certain circumstances, personal data may be processed by third-party service providers located outside of Malaysia — for example, global payment technology providers or cloud infrastructure vendors.

Where personal data is transferred internationally, Kaya100 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to or exceeding the protections provided under this Policy. Such safeguards include contractual data processing agreements containing standard data protection clauses and requirements for technical and organisational security measures.

Kaya100 will not transfer personal data to any jurisdiction that is recognised as providing materially inadequate data protection standards without first implementing robust contractual and technical safeguards.

Kaya100 reserves the right to update or amend this Privacy Policy at any time. We will review this Policy at least once per year, and additionally whenever there is a material change to our data processing practices, the introduction of new product features, or changes to applicable data protection legislation.

When material changes are made to this Policy, we will notify registered users via a prominent notice on the Platform homepage, an in-app notification within your account, or by email to the address associated with your registered account. The updated effective date will be displayed at the top of this page.

Your continued use of the Kaya100 Platform following notification of an updated Privacy Policy constitutes your acknowledgement and acceptance of the revised terms. If you do not agree with the changes, you should cease using the Platform and request account closure in accordance with our Terms & Conditions.

If you have any questions, concerns, or requests related to this Privacy Policy or the way in which Kaya100 handles your personal data, please contact our Data Privacy team through the following channels:

• Email: support@kaya100.cam — please use the subject line "Privacy Request — [Your Account Username]" to ensure prompt routing to our privacy team.
• Live Chat: Available 24/7 on the Kaya100 Platform in English, Bahasa Melayu, and Mandarin. Average response time: 3–5 minutes.
• WhatsApp: Available 24/7. Contact details are provided within the Platform upon login.