Privacy Policy lembu99 –
Your Personal Data Protection

1. Introduction

Lembu99 ("we", "Platform", "Company") takes seriously its responsibility to protect the privacy and personal data of every user on our platform at lembu99.vu. This Privacy Policy explains in detail how we collect, process, store, and protect your personal information.

This document is drafted in accordance with internationally recognised data protection principles and applies to all users who access or use the lembu99 platform, including via our website, mobile app, and customer service channels.

By registering an account or using lembu99's services, you give your consent to the collection and processing of your personal data as described in this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of our platform.

2. Information We Collect

We only collect data that is strictly necessary to provide a safe, efficient, and regulatory-compliant service. The following are the categories of information collected by lembu99:

We do not collect sensitive data categories such as health information, sexual orientation, religious beliefs, or political views unless you voluntarily disclose them while interacting with our support team — and in such cases, that information will not be stored in your account profile.

Data collection sources: Information is collected directly from you during the registration process and platform use, automatically through tracking technologies (cookies and analytics), and from trusted third parties such as payment service providers and identity verification bodies.

3. How We Use Your Data

All personal data collected by lembu99 is used on a lawful and limited basis, strictly for the following purposes:

• Account Management: Creating, verifying, and managing your account securely, including KYC processes and two-factor authentication.
• Transaction Processing: Processing deposits, withdrawals, and all other financial transactions accurately and promptly.
• Platform Security: Detecting and preventing fraud, hacking, money laundering, and activities that violate our terms of use.
• Regulatory Compliance: Fulfilling applicable legal and regulatory obligations, including AML (Anti-Money Laundering) reporting requirements.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and offer appropriate support.
• Service Improvement: Analyzing usage data in aggregate to improve platform design, user experience, and game offerings.
• Communications: Sending important account notifications, security updates, and promotional information (subject to your communication preferences).

We do not use your data for automated decisions that significantly affect you without human involvement, except in fraud detection cases where immediate action is required to protect your account — in such cases, you may request a manual review.

4. Data Sharing

Lembu99 does not sell, rent, or disclose your personal data to third parties for marketing purposes. However, in certain limited and legitimate situations, your data may be shared with the following parties:

• Payment Service Providers: Transaction information that must be shared with banks, e-wallet providers, and payment processors to complete your transactions.
• Game Software Providers: Game data required by licensed game developers to ensure game integrity and dispute resolution.
• KYC Service Providers: Identity information submitted to accredited third-party identity verification providers to meet regulatory requirements.
• Statutory Authorities: Data required by law or upon a lawful request from law enforcement authorities, including anti-money laundering bodies.
• Group Companies: Related entities within the lembu99 group of companies involved in delivering platform services, subject to internal confidentiality agreements.

All third parties who receive your data are required to comply with data protection standards equivalent to or higher than our own. We enter into data processing agreements with each service provider to ensure your data remains protected.

5. Data Security

Lembu99 continually invests in the latest security infrastructure to protect your personal data from unauthorized access, disclosure, alteration, or destruction. The key security measures we employ include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Data encryption at rest (AES-256) for all sensitive information stored in our database.
• Role-based access control (RBAC) ensuring staff can only access data required for their specific duties.
• Regular security audits by independent third parties to identify and address system vulnerabilities.
• 24/7 monitoring system to detect suspicious activity and security breach attempts.
• A comprehensive incident response plan to ensure rapid action in the event of a data breach.

6. Cookies & Tracking

Lembu99 uses cookies and similar tracking technologies to enhance the user experience, maintain session security, and collect platform analytics data. Cookies are small text files stored on your device when you browse our website.

We use four main types of cookies:

• Essential Cookies: Required for core platform functions such as login, session security, and language preferences. These cookies cannot be disabled without affecting website functionality.
• Performance Cookies: Collecting information about how you use our platform in aggregate and anonymized form to help us improve website performance.
• Functional Cookies: Storing your personal preferences such as display settings and game choices to deliver a more personalized experience.
• Analytics Cookies: Used by analytics tools to understand platform usage patterns, most frequently visited pages, and user navigation paths.

You can manage your cookie preferences through your web browser settings. Please note that disabling certain cookies may affect the functionality and your experience on the lembu99 platform. Detailed instructions on managing cookies are available through your web browser's help menu.

7. User Rights

As a lembu99 user, you hold the following rights regarding your personal data, which you may exercise at any time by contacting our support team:

All requests relating to the above rights will be processed within seven (7) business days. In more complex cases, this period may be extended up to thirty (30) days with prior notice to you. We do not charge any fees to process reasonable data rights requests.

8. Data Retention

Lembu99 retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy, or as required by applicable law. Our standard retention periods are as follows:

• Active Account Data: Retained for the duration your account remains active and up to five (5) years after account closure for regulatory compliance purposes.
• Financial Transaction Records: Retained for seven (7) years in accordance with financial reporting and anti-money laundering legal requirements.
• Support Communication Logs: Retained for three (3) years for quality control and dispute resolution purposes.
• Technical Data & Access Logs: Retained for twelve (12) months for security and fraud detection purposes.
• KYC Records: Retained for the minimum period required by the relevant regulatory body, typically between five and seven years.

Once the retention period expires, your data will be securely deleted or fully anonymised so it can no longer be associated with you.

9. Cross-Border Data Transfers

In operating a global platform, your personal data may be transferred to and stored on servers located outside your country of residence. Such transfers occur only when necessary to provide our services and are always carried out with adequate safeguards in place.

The protection measures we apply for cross-border data transfers include:

• Use of approved Standard Contractual Clauses (SCC) for data transfers to international service providers.
• Verification that the recipient country has an adequate or equivalent level of data protection.
• Data encryption in transit for all cross-border transfers without exception.

10. Children's Privacy

The lembu99 platform is intended for adult users aged 18 years and above only. We do not knowingly collect or process personal data from individuals under the age of 18.

If we discover that personal data of minors has been collected without our knowledge, such data will be deleted immediately and the relevant account will be closed. Parents or guardians who become aware that their child has registered on our platform are encouraged to contact our support team promptly.

We apply age verification methods during the registration process and conduct KYC checks to confirm user age. Child protection is our highest priority and we cooperate fully with authorities in cases involving unauthorized access by minors.

11. Policy Changes

Lembu99 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or service improvements. The "Updated" date at the top of this page will always reflect the date of the latest amendment.

For material changes — those that significantly affect how we use your data or your rights — we will provide advance notice of at least 14 days before the changes take effect, via registered email or in-platform notification.

Your continued use of the lembu99 platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your information.

12. Contact Us

If you have any questions, concerns, or wish to submit a request regarding your personal data, the lembu99 Data Protection Officer (DPO) team is ready to assist you through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the chat icon at the bottom-right corner of the platform.
• Email: [email protected] — response within 24 hours on business days.

We are committed to responding to all privacy inquiries transparently, professionally, and within the stipulated timeframe. Your satisfaction and trust are our top priority.