1
Introduction & Scope of TH39's Privacy Policy
This Privacy Policy is published by TH39 ("we", "the TH39 platform") and applies to all users, prospective members, registered members, and visitors to th39-win.com. This document sets out our privacy practices in a thorough and transparent manner so that you can make informed decisions about your use of the TH39 platform.
TH39 operates as both a data processor and data controller under Malaysia's Personal Data Protection Act 2010 (PDPA). This means we bear full responsibility for how your personal data is collected, processed, stored, and protected. Every data processing activity we carry out has a valid legal basis, whether founded on your consent, contractual necessity, or a legal obligation.
This Privacy Policy applies to all TH39 services, including EPL and Malaysia Super League football betting, live casino, online slots, blackjack, Sports Betting, virtual sports, Welcome Bonus, and all other platform features. It also applies to all our communication channels, including live chat, email, app notifications, and any other support methods.
Important Note: By registering for or using the TH39 platform, you confirm that you have read, understood, and agreed to this Privacy Policy. If you do not agree, please discontinue use of the platform and contact us to close your account.
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Personal Data TH39 Collects
TH39 only collects data that is strictly necessary to deliver our services safely and effectively. Below is a full breakdown of the types of data we collect:
| Data Category |
Specific Data Examples |
How It Is Collected |
| Identification Data |
Full name, MyKad number, date of birth, photograph |
Registration form, KYC verification |
| Contact Data |
Malaysian phone number, email address, residential address |
Account registration, profile updates |
| Financial Data |
Bank account number, transaction records, deposit & withdrawal history |
DuitNow, FPX, e-wallet payments |
| Game Data |
Betting history, games accessed, wins & losses |
Automated platform usage |
| Technical Data |
IP address, device type, web browser, operating system, cookies |
Automated system logs |
| Communications Data |
Live chat records, support emails, member feedback |
Interactions with the TH39 team |
TH39 Never Collects: Health information, political views, religious beliefs, sexual orientation, or other sensitive data unrelated to betting and gaming services.
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Purpose of Personal Data Use
TH39 uses your personal data solely for lawful purposes that are directly related to the provision of our platform services. Below is a complete list of the purposes for which your data is used:
- Account management: Creating, verifying, and managing your TH39 account, including the login process, identity verification (KYC), and account security.
- Transaction processing: Processing deposits via DuitNow, FPX Maybank2u, CIMB Clicks, Touch 'n Go, GrabPay, Boost, and ShopeePay, as well as withdrawals to your account.
- Provision of betting services: Facilitating football betting, live casino, slots, blackjack, virtual sports, e-sports, and all other games available on the TH39 platform.
- Fraud prevention & security: Detecting and preventing fraud, money laundering, and unlawful activity to protect all TH39 members.
- Legal compliance: Meeting Malaysian legal compliance obligations, including financial reporting, anti-money laundering (AMLA), and regulatory body directives.
- Customer support: Providing technical assistance and support to members via live chat, email, and other communication channels.
- Responsible gaming: Monitoring gameplay patterns to identify signs of at-risk behaviour and providing the necessary support to members who need it.
- Personalised experience: Personalising betting recommendations, bonus promotions, and the platform interface based on your preferences and gaming history (with your consent).
- Promotional communications: Sending information about bonuses, promotions, and platform updates to members who have consented to receive such communications.
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Data Sharing with Third Parties
TH39 does not sell or trade members' personal data to any party. However, in the course of delivering our services, we may share data with certain parties as described below:
4.1 Trusted Service Providers
TH39 works with third-party service providers that help us operate the platform. These include payment processors for DuitNow, FPX, and Malaysian e-wallets; certified gaming software and live casino providers; cloud hosting and security companies; and customer support service providers. All these providers are bound by strict confidentiality agreements and may only use your data for the specific purposes agreed upon with TH39.
4.2 Legal Obligations
TH39 may be required to disclose personal data to the relevant authorities where mandated by Malaysian law, court order, or the directive of a legitimate regulatory body. In all such cases, TH39 will endeavour to notify the affected member in advance, unless such notification is prohibited by law or court order.
4.3 Business Transfers
Should TH39 be involved in a merger, acquisition, or asset sale, members' personal data may be transferred to the successor entity. In such cases, TH39 will ensure that the successor entity adheres to a privacy policy at least equivalent to this one, and will notify members of any material changes.
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TH39 Data Security Measures
TH39 implements multiple layers of technical and organisational security measures to protect your personal data from unauthorised access, loss, destruction, or accidental disclosure.
256-bit SSL Encryption
All data in transit is protected by industry-grade encryption
Internal Access Controls
Principle of least privilege – staff only access data required for their specific role
24/7 Monitoring
A real-time threat detection system monitors unusual activity around the clock
Regular Independent Audits
Penetration testing and security audits by independent firms every quarter
While TH39 takes all reasonable steps to protect your data, no system is completely 100% secure. It is therefore important for members to play their part in safeguarding their own accounts – use a strong and unique password, enable two-factor authentication (2FA), and never share your login credentials with anyone.
TH39 retains your personal data only for as long as necessary to fulfil the original purpose of collection or to comply with legal obligations. The following are our data retention guidelines:
| Data Type | Retention Period | Reason |
|---|
| Active Account Data |
For the duration of the active account |
Service operational requirements |
| Financial Transaction Records |
7 years after the transaction |
Malaysia tax & AMLA legal obligations |
| Identity Verification (KYC) Data |
5 years after account closure |
Malaysia AMLA 2001 Compliance |
| Game History |
3 years |
Responsible gambling & disputes |
| Support Communication Logs |
2 years |
Service quality & dispute resolution |
| Technical Log Data (IP, device) |
90 days |
Security & fraud prevention |
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Your Rights Under PDPA 2010
As a data subject under Malaysia's Personal Data Protection Act 2010, you have the following rights with respect to your personal data held by TH39:
Right of Access
You have the right to request a copy of all personal data TH39 holds about you. Requests will be processed within 21 days.
Right to Rectification
If your data is inaccurate or out of date, you may request a correction at any time through your account settings or by contacting the TH39 support team.
Right to Restriction of Processing
You may request that TH39 cease using your data for specific purposes such as marketing, subject to applicable legal requirements.
Right to Lodge a Complaint
If you are dissatisfied with how TH39 handles your data, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia.
Right to Object to Marketing
You may withdraw your consent to receive marketing communications at any time by clicking "unsubscribe" in any email or by contacting TH39 support.
Right to Data Portability
You may request your data in a machine-readable format for transfer to another service, to the extent permitted by law.
How to Exercise Your Rights: To submit any request relating to your privacy rights, please contact the TH39 Privacy Officer at privacy@th39-win.com or via our platform's live chat. Please include your account number and the nature of your request. We will respond within 21 business days.
TH39 uses cookies and similar tracking technologies to enhance your experience on our platform, ensure account security, and understand how members use our services. Below are the types of cookies we use:
| Cookie Type | Purpose | Duration | Can It Be Disabled? |
|---|
| Important |
Login, session security, 2FA verification |
Session only |
No – required for the platform to function |
| Functional |
Language preference, display settings, preferred sports location |
1 year |
Yes – via account settings |
| Analytics |
Understanding how members use the platform in order to drive improvements |
2 years |
Yes – via privacy settings |
You can manage your cookie preferences at any time through your web browser settings or via the privacy settings panel in your TH39 account. Please note that disabling essential cookies may affect the core functionality of the TH39 platform.
The TH39 platform is intended for adult users aged 18 and above only. TH39 does not knowingly collect personal data from individuals under the age of 18. If you believe that a minor has registered a TH39 account or provided us with their personal data, please contact us immediately at privacy@th39-win.com and we will take immediate action to delete that data and close the account in question.
Minimum Age Requirement of 18: TH39 employs multiple age verification mechanisms, including KYC checks, to ensure our platform remains inaccessible to minors. Parents and guardians are encouraged to use parental control software where appropriate.
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Contact the TH39 Data Protection Officer
TH39 has appointed a Data Protection Officer (DPO) responsible for ensuring PDPA compliance and handling all privacy-related enquiries and complaints.
Privacy Officer Email
privacy@th39-win.com
Response within 72 working hours
Live Chat Support
Available 24 hours a day, 7 days a week
Response within minutes
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TH39 Privacy Policy Amendments
TH39 reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or platform improvements. Any material amendments will be communicated to members via their registered email address at least 14 days before taking effect.
We encourage you to review this Privacy Policy periodically. The "Last updated" date at the top of this document indicates when it was last revised. Your continued use of the TH39 platform following any amendments constitutes acceptance of the latest version of this Privacy Policy.
For record-keeping purposes, all previous versions of the TH39 Privacy Policy are retained and may be requested by emailing our Privacy Officer at privacy@th39-win.com. This ensures full transparency in our privacy management history.