Es90 Privacy Policy – Personal Data Protection for Malaysian Players

📋1. Introduction & Scope of This Privacy Policy

This Privacy Policy ("Policy") is published by ES90 ("we", "the Company", or "the Platform") and applies to all individuals who access, register for, or use the ES90 platform in any capacity. This document sets out in detail our practices regarding the collection, processing, storage, sharing, and protection of your personal data.

Es90 fully appreciates how sensitive personal information can be — especially on an online gaming platform where financial and transaction data is involved. Malaysian players at es90 have every right to know exactly what happens to their information, and this Privacy Policy is our written commitment to each and every one of you.

This Policy covers all ES90 services, including the web gaming platform, mobile interface, payment systems, bonus and promotion programmes, customer support, and all our official communication channels. If you have any questions about the contents of this Policy, the ES90 support team is available to assist you at any time.

📊2. Types of Personal Data We Collect

Es90 only collects personal data that is strictly necessary to operate the platform and provide the services you use. We do not collect excessive or irrelevant information. The following are the categories of data we collect:

🔍3. How es90 Collects Your Data

Es90 collects your personal data through several different channels as you interact with our platform:

• During account registration — when you complete the ES90 registration form, you provide us directly with basic information such as your name, email address, phone number, and date of birth.
• During identity verification — if we require further identity verification, you may be asked to upload a copy of your MyKad or another recognised identification document.
• When making a deposit or withdrawal — payment method details such as your Touch 'n Go account number, GrabPay details, or bank account information are collected when financial transactions are processed.
• When contacting customer support — any communication you initiate with the es90 team via live chat or email will be recorded for quality assurance and reference purposes.
• When completing preference settings or feedback forms — when you update your profile, set responsible gaming limits, or complete any form within the ES90 platform.

• Server logs — ES90's systems automatically record your IP address, browser type, pages visited, access times, and referring URL each time you use our platform.
• Cookies and similar tracking technologies — ES90 uses cookies to remember your preferences, maintain your login session, and analyse platform usage patterns in aggregate.
• Device data — device information such as your phone model, operating system, screen resolution, and unique device identifiers are collected automatically for security purposes and to optimise your user experience.

• Payment service providers — when processing deposits via Maybank2u, CIMB Clicks, DuitNow, or local Malaysian e-wallets, transaction verification information is received from those service providers.
• Identity verification body — in certain cases required by law or AML procedures, es90 may receive verification information from recognised bodies to confirm a user's identity.

⚙️4. How ES90 Uses Your Personal Data

Es90 uses collected personal data solely for legitimate purposes that are consistent with the context in which it was gathered. Below are all the purposes for which your data is used on the es90 platform:

• Account management and administration — to process your registration, verify your identity, maintain account records, and ensure the security of your es90 profile.
• Financial transaction processing — processing deposits via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, Maybank2u, CIMB Clicks, and other available payment methods; and processing your withdrawal of winnings promptly and securely.
• Gaming services provision — enables you to access and play all games in the es90 library, tracks your game history, and manages your account credit balance.
• Bonus and promotion management — to ensure you receive eligible bonuses, verify that wagering requirements have been met, and prevent misuse of es90's promotional system.
• Customer support — enabling the es90 support team to assist you more effectively when you reach out to us with enquiries or issues that require resolution.
• Security and fraud prevention — to detect and prevent fraudulent activity, money laundering, multiple account ownership, and any violations of es90's terms of use.
• Legal compliance — fulfilling compliance obligations under the Personal Data Protection Act 2010, mandatory AML/KYC procedures, and any relevant orders or directives issued by the authorities.
• Platform improvements — aggregated (not individual) usage patterns are analysed to improve the interface, introduce suitable new games, and enhance the overall quality of the es90 experience.
• Service communications — to send you important account notifications, security updates, terms changes, and transaction information via email or in-platform messages.

🤝5. Sharing Data with Third Parties

Es90 does not sell, transfer, or disclose your personal data to third parties for their own commercial purposes. However, there are limited situations where data sharing is necessary to lawfully operate our platform:

ES90 works with carefully selected third-party service providers to help us operate the platform. These include payment service providers (such as FPX gateways for Maybank2u and CIMB Clicks, as well as local Malaysian e-wallet operators), server and cloud computing service providers, and analytics services that help us understand platform usage. All such service providers are bound by strict confidentiality agreements and are only permitted to use your data for purposes we direct.

Es90 may be required to disclose your personal data to Malaysian authorities where mandated by law, court order, official investigation, or in connection with anti-money laundering (AML) and know-your-customer (KYC) procedures required by the relevant regulatory bodies.

In exceptional circumstances, es90 may disclose information as necessary to protect the rights, property, or safety of es90, our players, or the public — to the extent permitted or required by applicable law in Malaysia.

🔒6. es90 Data Security Measures

Es90 employs multiple layers of technical and organisational safeguards to ensure your personal data remains secure at every stage of processing. The following are the key security measures we have in place:

• Encryption in Transit: All data transmitted between your device and es90's servers is protected by the latest TLS (Transport Layer Security) protocol with 256-bit SSL encryption — rendering the data completely unreadable even if intercepted.
• Storage Encryption: Sensitive data stored in es90's databases — including passwords and financial information — is encrypted using industry-leading hashing and encryption algorithms.
• Strict Access Controls: Access to es90 players' personal data is restricted solely to staff with a legitimate need to access it, and all access is logged and continuously monitored.
• Two-Factor Authentication (2FA): ES90 supports and encourages players to enable two-factor authentication on their accounts for an additional layer of security during login.
• 24/7 Security Monitoring: ES90's automated monitoring system operates around the clock to detect any suspicious activity, unauthorised access attempts, or potential security threats.
• Regular Security Testing: The es90 platform undergoes regular penetration testing and security assessments conducted by independent security experts to identify and address any potential vulnerabilities.

🍪7. Cookies & Similar Tracking Technologies

Es90 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you access the es90 website.

• Essential Cookies: Required for the core functionality of the es90 platform — including maintaining your login session, remembering language preferences, and enabling security features to operate correctly. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collects information on how players use the es90 platform — which pages are visited most frequently, time spent on each, and where players encounter issues. This data is used in aggregated form to improve the platform.
• Functional Cookies: Allows the es90 platform to remember your preferences — such as saved usernames (excluding passwords), display preferences, and game settings — for a more personalised experience.

You can manage and delete cookies through your web browser settings at any time. Please note, however, that disabling certain cookies may affect the functionality of some areas of the ES90 platform and your overall gaming experience.

👦8. Protection of Children's Data & Underage Players

Es90 takes the protection of minors extremely seriously. Our platform is strictly for individuals aged 18 and above and we do not intentionally collect or process personal data from any individual under the age of 18.

All registrants are required to confirm that they are aged 18 or above during the registration process. es90 also implements additional age verification procedures where necessary, including requesting official identification documents to verify a player's date of birth.

Should es90 discover or receive information that an individual under the age of 18 has registered or is using our platform, the account in question will be closed immediately, all funds will be returned to their original source, and all related data will be deleted from our systems as promptly as possible. The matter will also be reported to the relevant authorities if required by law.

⚖️9. Your Rights as a Data Subject

As an es90 player and data subject under Malaysia's Personal Data Protection Act 2010 (PDPA), you hold the following rights with respect to the personal data es90 processes:

🗓️10. Data Retention & Deletion

Es90 does not retain your personal data indefinitely. We have a clear data retention policy based on operational needs and legal obligations:

• Active account data — retained for as long as your account remains active and for the minimum period required by law following account closure.
• Financial transaction records — retained for a minimum of seven (7) years in accordance with Malaysian accounting and AML compliance requirements, including records of deposits via Touch 'n Go, GrabPay, DuitNow, Maybank2u, CIMB Clicks, and other payment methods.
• Customer support communication records — retained for two (2) years for reference purposes and in the event any disputes arise.
• Technical and security logs — retained for ninety (90) days for security monitoring and incident investigation purposes, unless a longer retention period is required for a specific investigation.
• Marketing data and preferences — retained until you withdraw your consent or close your ES90 account, whichever occurs first.

Once the designated retention period has elapsed and there is no legal obligation preventing deletion, your personal data will be erased or anonymised using secure, irreversible procedures. es90 conducts regular reviews of data records to ensure that information no longer required is disposed of appropriately.

🔄11. Amendments to This Privacy Policy

ES90 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the way we operate. Each updated version of the Policy will be published on this page, with the new effective date clearly stated at the top of the document.

For material changes that significantly affect how we process your personal data, es90 will endeavour to provide registered players with reasonable advance notice via their registered email address or an in-platform notification before such changes take effect.

Your continued use of the es90 platform after any amendments to this Privacy Policy take effect will be considered your acceptance of those changes. We therefore encourage you to review this page periodically so you are always informed of how es90 protects your personal information.

📧12. Contact es90 about Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or how es90 handles your personal data, please contact us through the following channels:

• Privacy Email: [email protected] (please include "Data Privacy" in the email subject line)
• Live Chat: Available on the es90 platform, 24 hours a day, 7 days a week
• Support Language: Bahasa Melayu and English

The ES90 team will endeavour to respond to privacy-related enquiries within 5 business days of receipt. For more complex requests relating to data rights or breach investigations, the response time may be longer, but we will keep you updated on progress at regular intervals.