Privacy Policy for qq101

This Privacy Policy ("Policy") describes how qq101, operating at https://qq101.lat ("Platform", "we", "us", "our"), collects, processes, stores, shares and protects personal information relating to individuals ("you", "Player", "User") who access or use the Platform or any associated services.

qq101 is committed to handling personal data responsibly and in a manner consistent with internationally recognised data protection principles, including those reflected in Malaysia's Personal Data Protection Act 2010 ("PDPA") where applicable to commercial transactions involving Malaysian data subjects, as well as principles drawn from comparable international frameworks.

This Policy applies to all visitors, registered account holders and any other person whose personal data is processed in connection with the Platform. It is incorporated by reference into the qq101 Terms & Conditions and should be read alongside that document.

The following terms carry the meanings set out below throughout this Policy:

qq101 acts as the Data Controller in respect of personal data collected through the Platform. The Platform is operated under an international licensing framework and specific operator entity details are provided within the Platform's account documentation at the time of registration.

For data protection enquiries, requests to exercise your rights, or complaints relating to the handling of your personal data, please contact qq101 using the email address provided in Section 16 (Contact Us) of this Policy. All formal data subject requests must be submitted in writing to be processed in accordance with applicable timelines.

qq101 collects personal data across several categories depending on your interaction with the Platform. The table below summarises the principal categories and their typical scope:

qq101 does not intentionally collect special category data (for example, health information, racial or ethnic origin, or political opinions) except where directly volunteered by the player in the context of a responsible gambling request or similar safeguarding interaction.

qq101 collects personal data through the following channels:

• Direct submission: Information you enter when creating an account, completing KYC, making a deposit or withdrawal, contacting support, or responding to a survey.
• Automated technical collection: Device and session data gathered automatically when you access the Platform, including IP address, browser fingerprint, and behavioural interaction logs.
• Payment processors: Transaction-level references provided by payment service providers including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank and cryptocurrency network providers, when you initiate a financial transaction.
• Identity verification services: Data returned from third-party KYC and document verification providers engaged to confirm your identity and age (21+ requirement).
• Cookies and similar technologies: As described in Section 11 of this Policy.

qq101 processes personal data on one or more of the following legal bases, consistent with internationally recognised data protection principles and, where applicable, Malaysia's PDPA:

• Contractual necessity: Processing is required to enter into and perform the contract governing your use of qq101 — for example, creating and managing your account, processing deposits and withdrawals, and administering bonuses.
• Consent: Where you have provided clear and informed consent, for example, opt-in marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Legitimate interests: Processing necessary to protect the security and integrity of the Platform, detect fraud and bonus abuse, and improve service quality, where such interests are not overridden by your rights and freedoms.
• Legal obligation: Processing required to comply with applicable anti-money laundering regulations, identity verification requirements, and lawful requests from competent authorities.

qq101 uses personal data for the following purposes:

• Creating, verifying and maintaining your qq101 account, including age and identity confirmation to enforce the 21+ minimum age requirement.
• Processing financial transactions — deposits via DuitNow, FPX, e-wallets and cryptocurrency channels — and paying out verified withdrawals in MYR or equivalent.
• Administering bonuses, promotions and loyalty rewards, including verifying compliance with wagering requirements and eligibility conditions.
• Providing customer support and resolving complaints or disputes in a documented, auditable manner.
• Conducting fraud detection, security monitoring and anti-money laundering checks in compliance with applicable regulatory requirements.
• Operating responsible gambling tools including deposit limits, loss limits, session reminders, cooling-off periods and self-exclusion, as described on the Responsible Gambling page.
• Sending service notifications — for example, account activity alerts, security notifications and updates to these policies — that are necessary for platform operation and do not constitute direct marketing.
• Sending direct marketing communications where you have opted in; you may withdraw this consent at any time.
• Improving the Platform through aggregate analysis of usage patterns. Such analysis uses anonymised or pseudonymised data wherever possible.

qq101 does not sell, rent or trade your personal data. We may share your personal data with third parties strictly in the following circumstances:

• Payment service providers: Financial data is shared with the payment processor relevant to each transaction (for example, Maybank, CIMB, DuitNow network operators, or a cryptocurrency network node) solely to execute that transaction.
• Identity verification providers: KYC documentation is shared with contracted third-party verification services engaged to confirm age and identity. These providers are bound by confidentiality agreements and are not permitted to use data for their own purposes.
• Technology and infrastructure providers: Data may be processed by cloud infrastructure, analytics and security service providers who act as Data Processors under documented agreements prohibiting independent use of the data.
• Legal and regulatory authorities: qq101 will disclose personal data to competent governmental or law enforcement authorities where required to do so by law, court order, or in response to a verified lawful request. qq101 will endeavour to notify affected users of such disclosures where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, restructuring or sale of assets, personal data may be transferred to a successor entity subject to equivalent privacy commitments.

All third parties with whom qq101 shares personal data are required to handle that data in a manner consistent with this Policy and applicable data protection standards.

qq101 operates within an international licensing framework. As a result, personal data collected from Malaysian players may be transferred to, stored in or processed in jurisdictions outside Malaysia. Such transfers may include jurisdictions whose data protection laws differ from those applicable in Malaysia.

Where personal data is transferred outside Malaysia, qq101 applies safeguards including contractual protections and technical security measures to ensure that the data receives a standard of protection substantially equivalent to that required under applicable international data protection principles.

By using the Platform, Malaysian players acknowledge that their data may be processed in jurisdictions outside Malaysia as described in this clause.

qq101 retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or for as long as required by applicable legal, regulatory or contractual obligations — whichever is the longer period.

The following general retention principles apply:

• Account data: Retained for the duration of the account relationship and for a period of not less than five years following account closure, to meet anti-money laundering and audit requirements.
• Transaction and financial records: Retained for a minimum of seven years from the date of each transaction, consistent with financial record-keeping obligations.
• KYC documentation: Retained for the period required by applicable identity verification standards and for a reasonable period following account closure to satisfy potential regulatory enquiries.
• Support communications: Retained for a period sufficient to resolve any outstanding disputes and for quality assurance purposes, typically not less than three years.
• Technical and session data: Retained for a shorter period sufficient for security monitoring and platform analytics, typically not exceeding 24 months in identifiable form.

When personal data is no longer required, qq101 will delete or anonymise it using secure deletion methods. Anonymised aggregate data may be retained indefinitely for statistical and analytical purposes.

qq101 uses cookies and similar technologies (including session tokens and local storage mechanisms) to support platform functionality, maintain user sessions, remember preferences and support aggregate usage analytics. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens that keep you logged in during a visit. They cannot be disabled without preventing core functionality.
• Functional cookies: Remember your language preference, session settings and responsible gambling limit configurations between visits.
• Analytics cookies: Collect anonymised or pseudonymised data about how users navigate the Platform — for example, which sections are visited most frequently — to guide improvements.
• Security cookies: Used to detect and prevent fraud, bot activity and other abusive behaviour patterns.

qq101 does not use third-party advertising network cookies or cross-site behavioural tracking technologies for the purpose of serving targeted advertisements based on your activity on other websites.

You may control cookie behaviour through your browser settings. Disabling cookies other than strictly necessary ones may affect certain platform features and session stability. Continued use of qq101 constitutes acceptance of the use of strictly necessary cookies.

Subject to applicable law and verification of your identity, you hold the following rights in respect of your personal data held by qq101:

To exercise any of these rights, submit a written request to qq101 using the contact details in Section 16. qq101 will respond within 30 calendar days of receiving a valid, verified request. Extensions of up to an additional 60 days may apply for complex or voluminous requests, with notification provided to you.

qq101 is strictly for adults aged 21 years and above. The Platform does not knowingly collect, store or process personal data relating to individuals under the age of 21. Age verification is conducted as part of the KYC process for all new registrations.

If qq101 discovers or has reasonable grounds to believe that an account has been registered by a person under 21, the account will be suspended immediately, any funds held will be handled in accordance with the Terms & Conditions, and all associated personal data will be deleted from active systems as soon as the investigation is concluded.

If you are a parent or guardian and believe that an individual under 21 has accessed qq101, please contact us immediately using the details in Section 16.

qq101 implements a layered approach to data security, combining technical and organisational measures to protect personal data against unauthorised access, loss, destruction or alteration. Key measures include:

• Encryption in transit: All data exchanged between your device and the Platform is protected using industry-standard TLS encryption.
• Access controls: Internal access to personal data is restricted on a role-based, need-to-know basis. Privileged access is subject to additional authentication requirements.
• Security monitoring: The Platform employs automated monitoring for indicators of unauthorised access, brute force attempts and other suspicious activity patterns.
• Vendor due diligence: Third-party processors engaged by qq101 are assessed for security capability prior to engagement and are contractually required to maintain appropriate security standards.
• Incident response: qq101 maintains documented procedures for identifying, managing and, where required by law, notifying affected parties of personal data breaches.

No data transmission over the internet is guaranteed to be entirely secure. While qq101 takes all reasonable steps to protect your data, you are responsible for maintaining the confidentiality of your account credentials. Do not share your password with any third party. qq101 will never ask for your password by email, live chat or telephone.

qq101 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. When material changes are made, the "Last updated" date at the top of this page will be revised and, where reasonably practicable, registered Players will be notified through the Platform.

Your continued use of qq101 after any revised Policy has been published constitutes your acknowledgement and acceptance of those changes. We recommend reviewing this Policy periodically to remain informed of how your personal data is handled.

For any enquiries relating to this Privacy Policy, to exercise your data subject rights, or to submit a formal complaint regarding the handling of your personal data by qq101, please contact us in writing. All formal requests must be submitted in written form to be processed within the applicable response timelines.

qq101 data protection contact email: [email protected] (plain text — this is not a clickable link).

qq101 targets a response within 30 calendar days of receiving a complete and verifiable request. Where requests are complex or high in volume, an extension of up to a further 60 days may apply, with written notification provided to you at the earliest opportunity.

If you are not satisfied with qq101's handling of a data protection complaint, you may have the right to escalate the matter to the applicable data protection or regulatory authority in the jurisdiction under which the Platform's operator holds its licence.