QClubs Privacy Policy

1 Introduction

This Privacy Policy (the "Policy") describes how QQClubs (hereinafter "QClubs", "we", "us", or "our"), the operator of the online entertainment platform accessible athttps://qqclubs.cam, collects, uses, stores, discloses, and otherwise processes personal data in connection with your use of the Platform and its associated services.

We recognise that your personal data is important to you, and we are committed to handling it with transparency, integrity, and in accordance with applicable data protection principles. This Policy explains what information we hold about you, why we hold it, and what rights you have regarding that data.

This Policy applies to all users of QClubs globally, including players based in Malaysia — whether accessing the Platform from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, or any other location. Malaysian users should note that this Policy is prepared in accordance with general international data protection standards; QClubs does not operate under specific direction of any Malaysian regulatory body, and users remain responsible for understanding their local data protection obligations.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall relationship between QClubs and its users.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including but not limited to names, email addresses, identity document numbers, financial account details, and IP addresses.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" means QClubs, as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third-party entity that processes Personal Data on behalf of QQClubs, under QClubs' instruction.
• "Platform" means the QQClubs website at https://qqclubs.cam, including all pages, features, games, and services accessible thereon.
• "Account" means the registered user profile created by a Player on the Platform.
• "Cookies" means small text files placed on your device by the Platform when you visit, used to recognise returning users, remember preferences, and collect usage analytics.
• "KYC" means Know Your Customer — the identity and age verification process required before withdrawal privileges are activated on the Platform.
• "Third Party" means any entity other than QQClubs or the User.

3 Personal Data We Collect

QClubs collects Personal Data in several categories, depending on the nature of your interaction with the Platform. The categories of data we may hold include:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued identity document.
• Date of birth (used for 21+ age verification).
• Malaysian NRIC number, passport number, or equivalent national identification document number.
• Copies of identity documents submitted for KYC verification purposes.
• Nationality and country of residence.

3.2 Contact Data

• Email address used for account registration and communications.
• Mobile phone number (used for two-factor authentication and support contact).
• Residential or mailing address (collected during KYC, if required).

3.3 Financial & Transaction Data

• Details of deposit and withdrawal transactions, including amounts, timestamps, and payment references.
• Payment method information, including e-wallet identifiers (e.g., Touch 'n Go eWallet, Boost, DuitNow), bank account numbers (Maybank, CIMB, Public Bank, Hong Leong Bank), and card details where applicable.
• Cryptocurrency wallet addresses where crypto deposits or withdrawals are made.
• Records of bonus credits, wagering activity, and promotional participation.

3.4 Technical & Usage Data

• IP address and approximate geolocation derived therefrom.
• Device type, operating system, and browser information.
• Session logs, login timestamps, and navigation activity on the Platform.
• Game history, bet records, and platform interaction data.
• Referal source and marketing attribution data.

3.5 Communications Data

• Records of live chat conversations with our support team.
• Email correspondence with QClubs.
• Feedback, complaints, and dispute submissions.

4 How We Collect Your Data

We collect Personal Data through the following methods:

5 Purpose of Data Processing

QClubs processes your Personal Data for the following purposes:

• Account Management: To create, maintain, and administer your QClubs Account, including verifying your identity and eligibility to use the Platform.
• Age Verification: To confirm that you meet the minimum age requirement of 21 years, which is a non-negotiable condition of Platform use.
• Transaction Processing: To facilitate deposits, withdrawals, and the tracking of balances, bonuses, and wagering activity on your Account.
• Regulatory Compliance: To fulfil our obligations under applicable international anti-money laundering (AML), counter-terrorism financing (CTF), and KYC requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other forms of abuse on the Platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance via our24/7 support channels.
• Responsible Gambling: To monitor gaming patterns that may indicate problematic gambling behaviour, and to administer self-exclusion, deposit limit, and cooling-off requests.
• Marketing & Promotions: To send you relevant promotional communications, personalised offers, and Platform updates — subject to your consent and applicable laws.
• Platform Improvement: To analyse aggregated usage data and improve the performance, design, and functionality of the QClubs Platform.

6 Legal Basis for Processing

QClubs processes Personal Data on the following legal grounds, depending on the nature and purpose of the processing activity:

• Contractual Necessity: Processing required to perform the contract between QQClubs and the User, including Account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including AML, KYC, and fraud prevention laws.
• Legitimate Interests: Processing for purposes that are reasonably necessary for QClubs' legitimate business interests, including fraud detection, Platform security, and service improvement — where those interests are not overridden by your rights.
• Consent: Where processing is based on your freely given, informed, and specific consent — such as receiving marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

QQClubs may share your Personal Data with the following categories of third parties, strictly for the purposes described in this Policy and subject to appropriate data protection safeguards:

• Payment Service Providers: Including operators of Touch 'n Go eWallet, Boost, GrabPay, DuitNow/FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, and other payment processors, for the purpose of facilitating transactions.
• KYC & Identity Verification Providers: Third-party services engaged to verify player identity and age in compliance with our verification obligations.
• Game Content Providers: Game studios and software providers whose titles are offered on the Platform may receive pseudonymised gaming activity data for support and dispute resolution purposes.
• Analytics & Technology Providers: Service providers assisting with Platform analytics, infrastructure, and cybersecurity — bound by strict data processing agreements.
• Legal & Regulatory Authorities: Where required by applicable law, court order, or lawful request from a competent authority — including, where applicable, financial intelligence units or law enforcement agencies.
• Business Successors: In the event of a merger, acquisition, or sale of QClubs' assets, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.

8 International Data Transfers

QQClubs operates internationally, and your Personal Data may be processed stored, or transferred to servers and service providers located outside Malaysia. Such transfers may involve jurisdictions that do not have data protection laws equivalent to those of your home country.

Where Personal Data is transferred internationally, QQClubs takes steps to ensure that appropriate safeguards are in place — including contractual protections such as standard data protection clauses with third-party processors — to maintain the security and confidentiality of your data.

By using the QClubs Platform, you consent to the transfer, storage, and processing of your Personal Data in jurisdictions outside Malaysia where QClubs or its service providers operate.

9 Data Retention

QQClubs retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following general retention principles apply:

• Account data and KYC records are retained for a minimum of five (5) years from the date of account closure, or longer if required by applicable AML/CTF regulations.
• Transaction records are retained for a minimum of five (5) years from the date of each transaction.
• Support communications and dispute records are retained for three (3) years from the date of closure of the relevant matter.
• Marketing preference data is retained until you withdraw consent or request erasure.
• Technical and usage logs are retained for up to twelve (12) months for security and fraud analysis purposes, after which they are anonymised or deleted.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be associated with any identifiable individual.

10 Cookies & Tracking Technologies

QQClubs uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance Platform functionality, remember your preferences, and collect analytics data that helps us understand how users interact with the Platform.

Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function correctly. These enable core features such as Account login, session management, and security. They cannot be disabled without affecting Platform functionality.
• Functional Cookies: Allow the Platform to remember your preferences, such as language settings and display configurations, to provide a more personalised experience.
• Analytics Cookies: Help us understand how players use the Platform — including which pages are visited most frequently and where users encounter issues — so we can improve the Platform over time.
• Marketing Cookies: Used to track the effectiveness of promotional campaigns and to deliver relevant offers to users based on their activity patterns. These are only active where you have provided consent.

Most web browsers allow you to control cookie settings through your browser preferences. However, disabling essential cookies may impair your ability to use the Platform. For information on managing cookies in your specific browser, please refer to your browser's help documentation.

11 Your Data Protection Rights

Subject to applicable law and certain conditions, you have the following rights in relation to your Personal Data held by QQClubs:

• Right of Access: You have the right to request a copy of the Personal Data QClubs holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data held your Account.
• Right to Erasure: You may request deletion of your Personal Data in certain circumstances — for example, where it is no longer needed for the purpose for which it was collected, or where you have withdrawn consent. This right is subject to our legal retention obligations.
• Right to Restrict Processing: You may request that we limit the processing of your data in specific circumstances, such as while a dispute regarding accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you have the right to receive your data in a structured, machine-readable format.
• Right to Object: You may object to processing of your data based on legitimate interests or for direct marketing purposes. Marketing communications can be opted out of at any time.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Please note that some rights are subject to limitations — for example, we cannot erase data that we are legally required to retain for AML or KYC compliance purposes.

12 Security Measures

QQClubs 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:

• 256-bit Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform.
• Encrypted storage of sensitive data fields, including payment information and identity documents.
• Two-factor authentication (2FA) available for all Account holders to protect against unauthorised logins.
• Restricted access controls ensuring that only authorised personnel can access Personal Data, on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of Platform infrastructure.
• Incident response procedures to detect, contain, and notify affected users of any data breaches within applicable timeframes.

While QClubs takes all reasonable precautions to safeguard your data, no method of internet transmission or electronic storage is completely secure. You are encouraged to use a strong, unique password for your Account and to report any suspected security incidents to our support team immediately.

13 Third-Party Links & Services

The QClubs Platform may contain references to or integrations with third-party services, including payment processors and game providers. Where you interact with third-party services through the Platform, those services are governed by their own privacy policies, over which QQClubs has no control.

QClubs is not responsible for the privacy practices of third-party payment services such as Touch 'n Go eWallet, Boost, or bank internet banking portals. When you are redirected to such services to complete a transaction, please review their respective privacy policies before submitting any information.

14 Children's Privacy

All Account registrations require confirmation of date of birth, and KYC verification requires submission of a government-issued identity document. These measures are in place specifically to prevent underage access to real-money gaming on the Platform.

15 Amendments to This Policy

QClubs reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will update the effective date at the top of this page and, where practicable, notify registered users via email or in-platform notification.

Your continued use of the Platform following the publication of any amended version of this Policy constitutes your acceptance of those changes. We encourage you to review this Policy periodically — particularly if you have been away from the Platform for an extended period.

16 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data, please contact QClubs through the following channels: