Privacy Policy — w1win

1 Introduction

This Privacy Policy ("Policy") describes how w1win ("w1win", "the Platform", "we", "us", "our") collects, uses, stores, discloses and protects the personal data of individuals ("User", "Player", "you") who access or use the w1win website, mobile application and all related services available at w1win.asia (collectively, the "Platform").

w1win is committed to handling personal data responsibly and in accordance with applicable data protection laws and principles. We recognise that privacy matters deeply to our Malaysian players, and we have designed our data practices to be transparent, proportionate and respectful of your rights.

By registering an account, accessing the Platform or using any of our services, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. This Policy forms part of our Terms & Conditions.

2 Definitions

For the purposes of this Policy, the following terms shall have the meanings assigned below:

3 Data We Collect

3.1 Registration Data

When you create a w1win account, we collect:

• Full legal name;
• Date of birth (for age verification — minimum age 21);
• Residential address, including city and postcode (e.g., Kuala Lumpur, Petaling Jaya, Penang, Johor Bahru);
• Email address;
• Mobile phone number;
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with applicable regulations and to prevent underage gambling and fraud, we may collect:

• Copy of government-issued photo identification (Malaysian MyKad, passport or driving licence);
• Proof of residential address (utility bill, bank statement or official correspondence dated within 90 days);
• Proof of payment method ownership (e.g., screenshot of Touch 'n Go eWallet, GrabPay or bank account registered in your name);
• Selfie or liveness check photographs as required by our KYC verification partner.

3.3 Financial & Transaction Data

In connection with deposits and withdrawals, we collect:

• Deposit and withdrawal amounts, dates and methods;
• Payment method identifiers (e.g., registered DuitNow number, FPX bank name, cryptocurrency wallet address);
• Transaction reference numbers and processing status records;
• Account balance and wagering history.

3.4 Technical & Usage Data

When you access the Platform, we automatically collect:

• IP address and approximate geolocation;
• Device type, operating system and browser version;
• Session start and end times, pages visited and features used;
• Referring URL and click-path data;
• Error logs and crash reports.

3.5 Communications Data

When you contact our support team via live chat or email, we retain records of those communications, including the content of messages, timestamps and the outcome of any support request or dispute.

3.6 Responsible Gambling Data

Where you use our responsible gambling tools — including deposit limits, session time reminders or self-exclusion — we record your preferences and any changes made. This data is used to enforce your chosen controls and is never used for marketing purposes.

4 How We Collect Your Data

w1win collects personal data through the following channels:

• Directly from you — through account registration forms, KYC submission, deposit/withdrawal requests, support enquiries and survey participation;
• Automatically — through cookies, session tracking technology and server logs when you use the Platform;
• From third-party providers — including KYC verification platforms, payment processors (such as DuitNow, FPX, Touch 'n Go eWallet operators), fraud detection services and analytics providers who supply data to us pursuant to their own privacy policies and applicable data-sharing agreements;
• From publicly available sources — where permitted by law, including sanctions screening databases and publicly available identity records used for fraud prevention.

5 Purpose of Data Processing

We process your personal data for the following specific purposes:

6 Legal Basis for Processing

w1win processes your personal data on one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and w1win, including account management, payment processing and the provision of gaming services;
• Legal Obligation: Processing is required to comply with applicable laws, including KYC regulations, anti-money laundering obligations and data retention requirements;
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security and service improvement, provided those interests are not overridden by your fundamental rights;
• Consent: Where we rely on your consent — for example, for certain marketing communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

7.1 Authorised Third-Party Processors

w1win engages carefully selected third-party service providers to assist in operating the Platform. These providers act as Data Processors and are contractually bound to process your data only on our instructions and in accordance with applicable data protection standards. Categories of processors include:

• KYC and identity verification providers;
• Payment gateway operators, including Malaysian e-wallet and banking partners (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank);
• Cryptocurrency transaction processing services;
• Cloud hosting and data storage providers;
• Fraud detection and risk management platforms;
• Customer support software providers;
• Analytics and platform performance monitoring services.

7.2 Regulatory & Legal Disclosure

w1win may disclose personal data to regulatory authorities, law enforcement agencies or courts where required by applicable law, court order or lawful regulatory directive. We will, where legally permitted to do so, notify you of any such disclosure.

7.3 No Sale of Personal Data

w1win does not sell, rent, lease or otherwise transfer your personal data to third-party marketers, data brokers or any commercial entity for their independent use. Any data sharing beyond the categories described in this Policy requires your explicit prior consent.

8 Data Retention

w1win retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data disposal procedures.

9 Security Measures

w1win implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure or destruction. These include:

• Encryption in Transit: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption;
• Encryption at Rest: Sensitive personal data stored in our databases is encrypted using industry-standard algorithms;
• Access Controls: Access to personal data is restricted on a strict need-to-know basis using role-based access controls and multi-factor authentication for internal systems;
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems and regular penetration testing;
• Vulnerability Management: We conduct regular security assessments and promptly remediate identified vulnerabilities;
• Staff Training: All personnel with access to personal data receive mandatory data protection training.

10 Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the Platform. They allow us to recognise your device, remember your preferences and provide a functional, personalised experience. Similar technologies include web beacons, pixel tags and local storage objects.

10.2 Types of Cookies We Use

10.3 Managing Cookies

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect Platform functionality. Essential cookies cannot be disabled as they are strictly necessary for the Platform to operate securely.

11 Your Data Rights

Subject to applicable law, you have the following rights in relation to your personal data held by w1win. To exercise any of these rights, please contact our support team via live chat or at [email protected]. We will respond to all valid requests within 30 calendar days.

12 Minors & Age Restriction

The Platform is strictly intended for individuals aged 21 years and above. w1win does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a minor, we will immediately suspend the relevant account, delete the personal data and, where applicable, report the matter to relevant authorities.

Parents and guardians are encouraged to use parental control software to prevent underage individuals from accessing online gambling services. If you believe a minor has registered an account, please contact our support team immediately at [email protected].

13 International Data Transfers

To deliver our services, it may be necessary to transfer your personal data to servers or service providers located outside Malaysia. Where such transfers occur, w1win ensures that adequate safeguards are in place to protect your data, including:

• Contractual data protection clauses that bind recipients to processing standards equivalent to those described in this Policy;
• Transfer only to jurisdictions that provide an adequate level of data protection, as assessed by applicable regulatory standards;
• Use of encryption and access controls throughout the transfer and storage process.

By using the Platform, you acknowledge and consent to the transfer of your personal data outside Malaysia where necessary, subject to the safeguards described above.

14 Amendments to This Policy

w1win reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable laws or the services we provide. When a material change is made, we will notify registered Players by email or via a prominent notice on the Platform prior to the effective date of the change.

The "Last Updated" date at the top of this Policy reflects the most recent revision. We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the updated Policy.

15 Contact Us

If you have any questions, concerns or complaints regarding this Privacy Policy, or if you wish to exercise any of your data rights, please contact our Data Protection team through the following channels:

• Live Chat: Available 24/7 directly through the Platform
• Email: [email protected]

We aim to acknowledge all privacy-related enquiries within 5 business days and to provide a substantive response within 30 calendar days. Our support team serves players across Malaysia, including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam and Bangsar.