1. Introduction
This Privacy Policy ("Policy") is issued by HBO9 ("the Platform", "we", "us", "our") and applies to all personal data processed in connection with your use of the HBO9 website at hbo9.click, including account registration, deposits, withdrawals, gameplay, customer support interactions, and marketing communications.
HBO9 is committed to protecting the personal data of all users, including players based in Malaysia and other eligible jurisdictions. We process personal data in accordance with applicable international data protection standards, our licensing obligations, and the principles of transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and accountability.
By creating an account on HBO9 or by continuing to use our platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read in conjunction with our Terms & Conditions, which incorporate this Policy by reference.
Policy Scope: This Policy applies to data collected through the HBO9 website, live chat support, email correspondence, and any other digital touchpoints operated by HBO9. It does not apply to third-party websites or services that may be linked from our platform.
2. Definitions
For the purposes of this Privacy Policy, the following terms have the meanings assigned below:
- "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to: name, email address, phone number, date of birth, IP address, device identifiers, and financial account details.
- "Data Subject" means the individual to whom the Personal Data relates — in the context of this Policy, typically a registered player on the HBO9 platform.
- "Data Controller" means HBO9, which determines the purposes and means by which Personal Data is processed.
- "Data Processor" means any third party that processes Personal Data on behalf of HBO9 under a formal data processing agreement.
- "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, erasure, or destruction.
- "Consent" means a freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the processing of their Personal Data for a stated purpose.
- "KYC" means Know Your Customer — the process of verifying the identity and eligibility of a player in accordance with licensing and AML obligations.
- "Cookies" means small text files placed on a user's device by the HBO9 website for the purposes of functionality, analytics, and personalisation.
3. Personal Data We Collect
HBO9 collects the following categories of personal data from users, depending on the nature of the interaction and the services accessed:
3.1 Identity & Contact Data
Collected at account registration and through the KYC process. This includes:
3.2 Financial & Transaction Data
Collected in connection with deposits, withdrawals, and payment method verification. This includes:
Payment methods processed through HBO9 include Touch 'n Go eWallet, Boost eWallet, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank PBe, Hong Leong Connect, and selected cryptocurrencies. Financial data is processed in compliance with our licensing obligations and AML requirements.
3.3 Technical & Usage Data
Automatically collected when you access and use the platform:
3.4 Communications Data
Collected when you contact our support team or respond to marketing communications:
3.5 KYC & Compliance Documentation
As required by our licensing and AML obligations, we may collect copies of identity documents (Malaysian MyKad, passport, or driver's licence), proof of address documents, and in certain circumstances, source-of-funds documentation. These documents are processed solely for compliance purposes and are stored with enhanced security controls.
4. How We Collect Personal Data
HBO9 collects personal data through the following channels and mechanisms:
| Collection Method | Description |
|---|---|
| Account registration | Data provided directly by you when creating an account on HBO9. |
| KYC submission | Identity and address documents submitted voluntarily as part of verification. |
| Payment processing | Transaction data generated when you deposit or withdraw funds. |
| Platform interaction | Usage data automatically collected via server logs, analytics tools, and session tracking. |
| Cookies & tracking technologies | Data collected via first-party cookies placed on your device when browsing HBO9. |
| Customer support | Information you provide when contacting us via live chat or email. |
| Third-party verification | Data received from identity verification, fraud prevention, or payment processing partners. |
5. Legal Basis for Processing
HBO9 processes personal data on one or more of the following legal bases, as applicable to each specific processing activity:
- Contractual necessity: Processing required to perform the contract between HBO9 and the player — including account management, deposits, withdrawals, game provision, and customer support.
- Legal obligation: Processing required to comply with applicable laws, including KYC and anti-money laundering (AML) requirements under international licensing conditions.
- Legitimate interests: Processing carried out in pursuit of HBO9's legitimate business interests, including fraud prevention, platform security, product improvement, and responsible gambling monitoring, provided these interests do not override the rights of data subjects.
- Consent: Processing carried out on the basis of your freely given, specific consent — primarily in respect of marketing communications and optional profiling for personalised offers. Consent may be withdrawn at any time without detriment to your account standing.
6. How We Use Your Personal Data
HBO9 processes your personal data for the following specific purposes:
6.1 Account Management
To create, maintain, and administer your player account, including authentication, account security, password recovery, and account settings management.
6.2 Transaction Processing
To process deposits and withdrawal requests via supported payment methods, including Touch 'n Go eWallet, DuitNow, FPX, Maybank, CIMB, and cryptocurrency networks. Financial data is used solely for the purpose of completing the relevant transaction and fulfilling our AML obligations.
6.3 Identity Verification & AML Compliance
To verify your identity through the KYC process, to screen against sanctions lists, and to monitor transaction patterns in accordance with our anti-money laundering obligations under our licensing framework.
6.4 Responsible Gambling Monitoring
To monitor gameplay patterns for signs of problem gambling behaviour, to apply and enforce player-set deposit limits or self-exclusion, and to ensure compliance with our responsible gambling obligations. This processing is carried out in your interest and in fulfilment of our regulatory duties.
6.5 Customer Support
To respond to enquiries, resolve disputes, process complaints, and provide technical assistance. Communications data is retained to maintain a record of support interactions and to monitor service quality.
6.6 Platform Analytics & Improvement
To analyse usage patterns, identify technical issues, and improve the functionality, performance, and user experience of the HBO9 platform. Analytics data is used in aggregated or pseudonymised form where possible.
6.7 Fraud Prevention & Security
To detect, investigate, and prevent fraudulent activity, bonus abuse, unauthorised access, and other security threats. This includes cross-referencing account data against known fraud indicators and sharing relevant data with fraud prevention partners under appropriate safeguards.
6.8 Marketing Communications
Where you have provided consent, to send you promotional offers, bonus notifications, and product updates relevant to the HBO9 platform via email or other electronic channels. You may opt out of marketing at any time by updating your account preferences or by contacting support.
Data Minimisation: HBO9 collects only the data necessary for the stated purposes above. We do not engage in excessive or disproportionate data collection. If you have questions about the specific data we hold on you, please refer to Section 12 (Your Rights).
7. Data Sharing & Disclosure
HBO9 does not sell, rent, or trade your personal data to third parties for commercial purposes. We may, however, share your data with the following categories of recipients under strictly controlled conditions:
7.1 Payment Processing Partners
We share financial data with payment service providers and banking partners — including those facilitating DuitNow, FPX, and e-wallet transactions — for the sole purpose of completing your requested transactions. These partners are bound by confidentiality obligations and data processing agreements.
7.2 Identity Verification & AML Providers
We engage specialist third-party KYC and AML compliance providers to assist with identity verification, sanctions screening, and fraud detection. These providers process your data as authorised data processors under our instruction.
7.3 Game Technology Providers
Certain gameplay data (such as session identifiers and bet history) may be processed by our licensed game studio partners for the purpose of delivering game content, resolving disputes, and ensuring fair play. No personally identifiable information beyond what is technically necessary is shared for this purpose.
7.4 Legal & Regulatory Authorities
We may disclose your personal data to regulatory bodies, licensing authorities, law enforcement agencies, or courts of competent jurisdiction where we are legally required to do so, or where such disclosure is necessary to protect the rights, property, or safety of HBO9, its players, or the public.
7.5 Corporate Transactions
In the event of a merger, acquisition, restructuring, or sale of all or part of HBO9's business, your personal data may be transferred to the successor entity as part of the transaction. You will be notified of any such change and the relevant privacy policy of the acquiring entity will apply from the effective date of transfer.
No Sale of Data: HBO9 does not sell, license, or otherwise monetise your personal data to third parties for advertising or marketing purposes. We do not share your data with data brokers or advertising networks.
8. Cookies & Tracking Technologies
HBO9 uses cookies and similar tracking technologies to support platform functionality, remember your preferences, and analyse how users interact with our website. By continuing to use the HBO9 platform, you consent to the use of cookies in accordance with this Policy.
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Required for the platform to function, including session management, login authentication, and security tokens. | Session / persistent |
| Functional | Remembers your preferences such as language settings, currency display, and game lobby layout. | Up to 12 months |
| Analytics | Collects anonymised data on how users navigate the site to help us improve performance and usability. | Up to 24 months |
| Marketing | Used to track visits and conversions from referral sources. Only active where you have provided consent. | Up to 30 days |
You can manage or disable cookies through your browser settings at any time. Please note that disabling strictly necessary cookies may impair the functionality of the platform, including your ability to log in or complete transactions.
9. Data Retention
HBO9 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and licensing obligations. The following general retention periods apply:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years post-closure | AML / licensing obligation |
| KYC & identity documents | 5 years from date of submission | AML / licensing obligation |
| Transaction & financial records | 5 years from date of transaction | AML / tax reporting |
| Customer support records | 3 years from last interaction | Legitimate interests |
| Marketing consent records | Until consent is withdrawn + 3 years | Legal / consent compliance |
| Technical & usage logs | 90 days (anonymised after 30 days) | Legitimate interests / security |
Upon expiry of the applicable retention period, data is securely deleted or anonymised in a manner that prevents identification of the data subject.
10. Data Security
HBO9 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:
- 256-bit SSL/TLS encryption on all data transmitted between your device and HBO9's servers.
- At-rest encryption for sensitive data categories, including KYC documents and financial records.
- Access controls and role-based permissions ensuring that personal data is accessible only to authorised personnel with a legitimate need.
- Two-factor authentication (2FA) available on all player accounts and enforced for internal administrative access.
- Regular security audits and penetration testing conducted by third-party security specialists.
- Incident response procedures to detect, contain, and notify affected parties in the event of a data breach, in accordance with applicable notification requirements.
- Staff training on data protection obligations, with dedicated data protection responsibilities assigned within the organisation.
Notwithstanding these measures, no digital transmission or storage system is entirely impervious to risk. We encourage all players to use strong, unique passwords, enable two-factor authentication, and exercise caution when accessing their account from shared or public devices.
11. International Data Transfers
HBO9 operates as an international platform and may process or store personal data on servers located outside Malaysia. Where personal data is transferred to jurisdictions that may not offer the same level of data protection as your home country, HBO9 ensures that appropriate safeguards are in place, including:
- Data processing agreements with receiving parties that incorporate equivalent data protection standards.
- Contractual clauses requiring the recipient to protect your data in accordance with applicable privacy obligations.
- Technical and organisational measures commensurate with the sensitivity of the data being transferred.
By registering an account with HBO9, you acknowledge and consent to the transfer of your personal data to our servers and authorised third-party processors, which may be located outside of Malaysia, for the purposes described in this Policy.
12. Your Data Rights
As a data subject, you hold the following rights in relation to the personal data that HBO9 holds about you. Requests to exercise these rights should be submitted via live chat or email to [email protected] and will be actioned within a reasonable timeframe, subject to identity verification and any applicable legal exemptions.
Right of Access
You may request a copy of the personal data we hold about you, together with information on how it is processed.
Right of Rectification
You may request correction of inaccurate or incomplete personal data held on your account.
Right of Erasure
You may request deletion of your personal data, subject to legal retention obligations that may prevent full erasure.
Right to Restrict Processing
You may request that we limit the processing of your data in certain circumstances, such as while a dispute is being resolved.
Right to Data Portability
You may request a structured, machine-readable copy of personal data you have provided to us for transfer to another provider.
Right to Withdraw Consent
Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of prior processing.
13. Minors & Age Policy
The HBO9 platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. Mandatory KYC identity verification is in place to enforce this requirement.
If HBO9 discovers or is notified that an account has been registered by a person under the age of 21, the account will be immediately suspended, all funds will be returned via the original payment method where operationally possible, and all associated personal data will be deleted unless retention is required by law for fraud or AML reporting purposes.
If you believe that a person under the age of 21 may have registered or used an account on HBO9, please contact us immediately via live chat or at [email protected] so that we may investigate and take appropriate action.
14. Marketing Communications
HBO9 may send you promotional emails, bonus notifications, and platform updates if you have opted in to receive such communications during account registration or subsequently through your account settings. Marketing communications may reference offers relevant to Malaysian players, including deposit bonuses, sports betting promotions for Liga Super Malaysia or EPL match days, and seasonal campaigns.
You may withdraw consent for marketing communications at any time by:
- Clicking the "unsubscribe" link included in any marketing email.
- Updating your communication preferences in your account settings.
- Contacting our support team via live chat or at [email protected] with an opt-out request.
Opting out of marketing communications will not affect the delivery of transactional communications related to your account (such as deposit confirmations, withdrawal notifications, and security alerts), which are necessary for the performance of our contract with you.
15. Third-Party Links & Services
The HBO9 website does not contain links to external third-party websites. All navigation, game content, and support channels are operated within the HBO9 platform environment. Accordingly, this Policy governs all data processed in the course of your use of hbo9.click and its associated services.
Where third-party service providers (such as payment processors or analytics tools) interact with data on our behalf, those relationships are governed by formal data processing agreements. HBO9 remains the data controller and retains responsibility for the protection of your personal data in all such arrangements.
16. Changes to This Privacy Policy
HBO9 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, licensing requirements, or platform functionality. All updates will be effective immediately upon publication to the HBO9 website.
Where material changes are made to this Policy — particularly changes that affect your rights or how we use your data — we will take reasonable steps to notify you, which may include displaying a banner on the platform or sending an email to your registered address. The "Last Updated" date at the top of this document reflects the most recent revision.
Your continued use of the platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. We recommend reviewing this page periodically to stay informed of how we protect your data.
17. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by HBO9, please contact us through the following channels:
- Live Chat: Available 24 hours a day, 7 days a week via the chat function on the HBO9 website. This is the fastest way to reach our data team for urgent requests.
- Email: [email protected] — for formal data subject access requests, erasure requests, and privacy-related complaints. We aim to acknowledge requests within 2 business days and respond in full within 30 days.
When submitting a data rights request, please include your registered username, the specific right you wish to exercise, and any supporting information that will assist us in processing your request. We may need to verify your identity before actioning a data access or erasure request.
For responsible gambling support or account self-exclusion, please visit our dedicated Responsible Gambling page — these requests are handled separately from data rights requests and are actioned immediately.