Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by QQEmas ("we", "us", "our", "Company") and applies to all personal data collected from individuals ("you", "Player", "User") who access or use the QQEmas online gaming platform at qqemas.lat (the "Platform"), including its associated mobile interfaces, customer support channels, and any other services operated under the QQEmas brand.

QQEmas is committed to protecting the privacy and security of personal information belonging to all players who use our platform — whether they are accessing the service from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, or any other location. We adhere to recognised principles of data protection and process personal information only in accordance with the purposes described in this Policy.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, which together form the full legal framework governing your use of the QQEmas Platform.

2 Definitions

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, identification number, contact details, financial information, IP address, device identifiers, and behavioural data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, restriction, deletion, or destruction.
• "Data Controller" means QQEmas, the entity that determines the purposes and means by which Personal Data is processed.
• "Data Processor" means a third party that processes Personal Data on behalf of QQEmas, acting under our instructions and subject to contractual data processing obligations.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• "KYC Data" means identity and address verification documents submitted by a Player as part of the Know Your Customer verification process, including government-issued identification, proof of address, and photographic verification.
• "Cookies" means small text files placed on a Player's device by the QQEmas Platform to support functionality, analytics, and (where consented) personalisation.
• "Platform" has the same meaning as in QQEmas's Terms and Conditions — the QQEmas Website, mobile interface, and all associated gaming and account services.

3 Data We Collect

3.1 Registration Data

When you create a QQEmas account, we collect the information you provide during the registration process, including your full name, date of birth, email address, mobile telephone number, residential address, and preferred currency (MYR for Malaysian players). This information is required to create and maintain your account and to fulfil our legal verification obligations.

3.2 KYC Verification Data

To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations, QQEmas collects identity verification documents from Players prior to enabling withdrawals above specified thresholds. KYC data typically includes:

• A copy of a valid government-issued photo ID — Malaysian MyKad (NRIC), Driver's Licence, or Passport;
• Proof of residential address — a utility bill (such as Tenaga Nasional, Syabas, or equivalent) or a statement from a Malaysian financial institution such as Maybank, CIMB, Public Bank, or Hong Leong, dated within three months;
• A selfie photograph of the Player holding their identification document.

3.3 Transaction Data

QQEmas records all financial transactions associated with your account, including deposits made via approved Malaysian payment methods (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect), cryptocurrency deposits (BTC, ETH, USDT, LTC), withdrawal requests, and bonus credits. Transaction records include payment method details, amounts in MYR, timestamps, and processing status.

3.4 Gaming Activity Data

We collect detailed records of your gaming and betting activity on the Platform, including games played, wagers placed, outcomes, session durations, and bet histories. This data is used for account management, dispute resolution, fraud prevention, responsible gambling monitoring, and regulatory compliance.

3.5 Technical & Device Data

When you access the QQEmas Platform, we automatically collect technical data including your IP address, browser type and version, operating system, device identifiers, screen resolution, and referring URL. This data is used for platform security, fraud detection, technical troubleshooting, and aggregate analytics.

3.6 Communications Data

If you contact QQEmas customer support via live chat, email, or any other channel, we retain records of those communications, including the content of messages, timestamps, and any supporting documentation you provide. This data is used to resolve queries, improve our services, and maintain an audit trail of player-support interactions.

4 Legal Basis for Processing

QQEmas processes personal data on the following legal grounds, as applicable:

5 How We Use Your Data

QQEmas uses the personal data we collect for the following purposes:

• Account Management: Creating, maintaining, and securing your QQEmas account; verifying your identity and age; processing login requests and two-factor authentication.
• Transaction Processing: Facilitating deposits and withdrawals via Malaysian payment methods and cryptocurrency channels; maintaining accurate financial records; detecting and preventing fraudulent transactions.
• Regulatory Compliance: Fulfilling KYC, AML, and CTF obligations; responding to lawful requests from regulatory authorities; maintaining records as required by applicable international gaming and financial regulations.
• Responsible Gambling: Monitoring gaming behaviour for indicators of problem gambling; enforcing self-exclusion requests; administering deposit limits, loss limits, and session time restrictions; enforcing our 21+ minimum age policy.
• Customer Support: Responding to queries, resolving disputes, and improving our support processes based on interaction history.
• Platform Security: Detecting and preventing account takeover, bonus abuse, collusion, and other prohibited activities; conducting fraud investigations.
• Marketing Communications (with consent): Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications.
• Analytics & Product Improvement: Analysing aggregate usage patterns to improve platform functionality, game selection, and user experience.

6 Data Sharing & Disclosure

6.1 Service Providers & Data Processors

QQEmas may share your personal data with carefully selected third-party service providers who act as Data Processors on our behalf, including payment processing partners, KYC verification technology providers, cloud infrastructure providers, fraud detection services, and customer support platform providers. All such providers are subject to binding data processing agreements and may only process your data in accordance with our instructions and for the purposes specified in this Policy.

6.2 Legal & Regulatory Disclosure

QQEmas may disclose your personal data to law enforcement agencies, regulatory authorities, or other government bodies where we are legally required to do so, or where we reasonably believe disclosure is necessary to prevent fraud, money laundering, or other illegal activity, or to protect the rights and safety of our players or the public.

6.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of QQEmas's business, your personal data may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection obligations being imposed on the recipient.

6.4 No Sale of Data

QQEmas does not sell, rent, or exchange your personal data with unaffiliated third parties for their own marketing or commercial purposes. Any sharing of data for promotional activities (such as game studio partnerships) involves only aggregate, anonymised data — not personally identifiable information.

7 Cookies & Tracking Technologies

7.1 Types of Cookies Used

The QQEmas Platform uses the following categories of cookies and similar tracking technologies:

• Strictly Necessary Cookies: Essential for the operation of the Platform — enabling login sessions, security tokens, and core functionality. These cannot be disabled without impairing platform function.
• Analytics Cookies: Used to collect aggregate, anonymised data about how players interact with the Platform — pages visited, session durations, game categories accessed. This data informs product development and does not identify individual players.
• Functionality Cookies: Remember your preferences such as language settings, display preferences, and recently played games to deliver a more personalised experience.
• Security Cookies: Used to detect and prevent fraud, including bot activity, account takeover attempts, and suspicious session behaviour.

7.2 Managing Cookies

You can manage your cookie preferences at any time via your browser settings. Please note that disabling strictly necessary cookies may impair your ability to use core QQEmas features. Most modern browsers also offer the option to block or delete cookies from specific domains — refer to your browser's help documentation for instructions.

8 Data Security

QQEmas implements a comprehensive suite 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 SSL/TLS encryption for all data transmitted between your device and the QQEmas Platform;
• Encryption of personal data stored on QQEmas servers, including KYC documents and financial records;
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent required for their specific function;
• Two-factor authentication available for all player accounts;
• Regular security assessments and penetration testing of Platform infrastructure;
• Incident response procedures enabling prompt identification and containment of any data security breach.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, QQEmas will notify affected players and relevant authorities in accordance with applicable notification obligations, without undue delay.

9 Data Retention

QQEmas retains personal data for the periods set out below, after which data is securely deleted or irreversibly anonymised:

10 Your Rights

As a data subject, you are entitled to exercise the following rights in respect of your personal data held by QQEmas. To exercise any of these rights, please contact our Data Protection team at the details set out in Section 15.

11 Children & Minors

The QQEmas Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the account registration process, and QQEmas reserves the right to request proof of age at any time.

If QQEmas discovers or has reason to believe that a registered account belongs to an individual under the age of 21, the account will be immediately suspended, all balances frozen pending investigation, and the matter referred to our compliance team. Any personal data collected from a minor in breach of this Policy will be deleted as promptly as practicable upon discovery.

If you are a parent or guardian and believe that a minor in your care has accessed or registered on the QQEmas Platform, please contact our support team immediately at the details provided in Section 15.

12 International Data Transfers

QQEmas operates servers and engages service providers located in various jurisdictions. As a result, your personal data may be transferred to and processed in countries outside Malaysia. Where such transfers occur, QQEmas ensures that appropriate safeguards are in place to protect your data to a standard consistent with this Policy and applicable data protection principles, including the use of contractual data protection clauses with processors in third countries.

By using the QQEmas Platform, you acknowledge and consent to the potential transfer of your personal data to jurisdictions outside Malaysia as described in this section, where such transfers are necessary to deliver the services described in this Policy.

13 Third-Party Links

The QQEmas Platform may contain links to third-party websites or services, for example in the context of responsible gambling support resources or payment method information pages. This Privacy Policy applies solely to data processing by QQEmas and does not extend to any third-party websites or services. QQEmas takes no responsibility for the privacy practices or content of third-party platforms. We encourage you to review the privacy policies of any third-party services you access.

14 Amendments to This Policy

QQEmas reserves the right to amend this Privacy Policy at any time. Material amendments — such as changes to the categories of data collected, the purposes for which data is used, or the rights available to Players — will be communicated to Players via their registered email address or via a prominent notice on the Platform at least fourteen (14) days prior to the changes taking effect.

Non-material amendments (such as clarifications of existing provisions or updated contact details) may be made without prior notice. The current version of this Policy is always accessible at qqemas.lat/privacy-policy and displays the date of last revision. Your continued use of the Platform following any amendment constitutes acceptance of the revised Policy.

15 Contact Us & Complaints

If you wish to exercise any of your data subject rights, have a question about how your personal data is handled, or wish to make a complaint about our data processing practices, please contact the QQEmas Data Protection team through the following channels:

• Email: [email protected] (displayed as plain text — not a clickable link)
• Subject Line: Please mark privacy-related enquiries with the subject heading "DATA PRIVACY REQUEST" to ensure prompt routing to the appropriate team member.
• Live Chat: Available 24 hours a day, 7 days a week via the QQEmas Platform — select "Privacy / Data" as the query category for fastest routing.
• Response Time: QQEmas aims to acknowledge all data subject requests within five (5) business days and to issue a substantive response within thirty (30) days. Where the complexity or volume of requests requires an extension, we will notify you and provide an updated timeline.

If you are not satisfied with QQEmas's response to your privacy concern, you have the right to escalate your complaint to a relevant independent supervisory authority in your jurisdiction. QQEmas will cooperate fully with any such process.