Win1 Privacy Policy – Personal Data Protection for Malaysian Members

1 Introduction

This Privacy Policy ("Policy") describes how win1 ("we", "the platform", or "win1") collects, uses, discloses, and protects your personal information when you use the win1 platform accessible at win1-jit.com.

Win1 is fully committed to protecting the privacy of every member who uses our platform. This Policy has been drafted in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA 2010) and reflects our firm commitment to the security and confidentiality of your personal data.

By registering an account and using the win1 platform, you agree to the collection and use of your personal information as described in this Policy. If you do not agree, you should not use our platform.

2 Information We Collect

Win1 collects several categories of personal information from members for platform operation purposes. The information collected falls into two main categories: information you provide directly, and information collected automatically as you use the platform.

Information you provide directly:

• Full name as stated in your MyKad or Malaysian passport
• Identity card number (MyKad) or passport number
• Email address and Malaysian mobile number
• Date of birth for age verification
• Payment method details (Touch 'n Go e-wallet account number, DuitNow, GrabPay, Boost, ShopeePay, or bank account details for FPX)
• Current residential address
• Identity documents submitted during the KYC process

Information collected automatically:

• The IP address of the device used to access the platform
• Web browser type, operating system, and device type
• Gaming session data including access times, games played, and total wager amounts
• Deposit and withdrawal transaction log data
• Cookies and similar tracking technologies to enhance the user experience
• Approximate geolocation data derived from IP address for compliance purposes

3 Data Collection & Usage Purposes

Win1 uses the personal data it collects strictly for the purposes listed below. We do not use your data for any other purpose without first obtaining your consent.

Win1 will only use your personal data for the purposes stated at the time of collection, or for purposes consistent with the original intent. Should we wish to use your data for a materially different new purpose, we will seek your consent beforehand.

4 Sharing Data with Third Parties

Win1 does not sell, rent, or trade members' personal data to any third party for commercial or marketing purposes. However, in the normal course of platform operations, there are limited situations where data may be shared with selected third parties.

Third parties that may receive your data:

• Payment providers: Touch 'n Go, DuitNow, GrabPay, Boost, ShopeePay, FPX providers (including Maybank2u and CIMB Clicks) — to process your deposit and withdrawal transactions.
• Game providers: Companies such as Evolution Gaming, Pragmatic Play, and PG Soft receive minimal session data necessary to operate the games you choose to play.
• Identity verification providers: Third-party services that assist win1 with the KYC process to verify member identities.
• Regulatory and legal authorities: win1 may be legally required to disclose certain data to the relevant authorities upon receipt of a valid request.

5 Data Security

Win1 implements a range of technical and organisational security measures to protect members' personal data against unauthorised access, disclosure, alteration, or destruction. The key security measures we employ include:

• 256-bit SSL Encryption: All communications between your browser and win1's servers are encrypted using 256-bit TLS/SSL protocol, ensuring that your data cannot be intercepted in transit.
• Stored data encryption: Sensitive information such as passwords and identity card numbers is stored in encrypted form using industry-standard encryption algorithms. win1 does not store passwords in plain text.
• Two-factor authentication (2FA): win1 members are encouraged and able to enable 2FA for additional protection on their accounts.
• 24/7 security monitoring: A security threat monitoring system operates continuously to detect and respond to any suspicious activity.
• Internal access controls: Access to members' personal data by win1 staff is strictly controlled on a need-to-know basis and is fully logged.
• Periodic security audits: win1 conducts regular penetration testing and security audits to identify and address any system vulnerabilities.

6 Data Retention Period

Win1 retains members' personal data only for as long as necessary for the purposes set out in this Policy, or as required by applicable law. The following are general guidelines for data retention periods:

• Active account data: Retained for as long as your account remains active and for the period following account closure as required under anti-money laundering legislation.
• Financial transaction data: Retained for a minimum of 7 years in accordance with Malaysian financial legal requirements.
• Session and game log data: Retained for 2 years for dispute resolution and internal analytics purposes.
• Customer support communication data: Retained for 3 years from the date of last interaction.
• KYC Documents: Retained for a minimum of 5 years following account closure, in compliance with anti-money laundering legal requirements.

When data is no longer needed for its stated purpose and there is no legal obligation to retain it, win1 will securely delete or anonymise that data.

7 Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 and win1's Privacy Policy, you have several rights regarding the personal data win1 holds about you. These rights can be exercised by contacting our support team.

8 Cookies & Tracking Technologies

Win1 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

Win1 uses several types of cookies, each serving a different purpose:

• Essential Cookies: Required for core platform functions such as login verification and session security. These cookies cannot be disabled without affecting your ability to use the platform.
• Preference Cookies: Saves your preferences such as display language and account settings to deliver a more personalised experience.
• Analytics Cookies: Helps win1 understand how members use the platform in order to improve our services. Data collected is aggregated and does not identify individual users.
• Functional Cookies: Enables certain platform features to function correctly, such as remembering your game preferences.

You can manage and delete cookies through your web browser settings. However, disabling certain cookies may affect the functionality of some areas of the win1 platform. For guidance on managing cookies in your browser, refer to your browser's Help section.

9 Marketing & Communications

Win1 may send marketing communications to members regarding promotions, bonuses, new games, and other relevant service updates. All marketing communications are based on the consent you provided at registration or at a later date.

You have full control over the types of communications you receive from win1. You can opt out of marketing emails, SMS notifications, or any other communications at any time through your account settings or by contacting the win1 support team.

10 Children's Privacy

The win1 platform is not intended for individuals under the age of 18, and we do not knowingly collect personal data from minors. Should we discover that personal data belonging to a child (under 18) has been collected without appropriate parental consent verification, we will take immediate steps to delete that data and close the account in question.

Win1 conducts rigorous age verification checks during registration and the KYC process to ensure that only individuals aged 18 and above are able to use the platform. If you suspect that a minor is using this platform, please notify us immediately at support@win1-jit.com.

11 Cross-Border Data Transfers

In the course of operating the win1 platform, some of your personal data may be transferred to and processed in countries outside Malaysia — particularly in connection with international game providers such as Evolution Gaming and Pragmatic Play, which operate their servers and studios across various global locations.

Win1 ensures that any such data transfers are carried out with adequate safeguards in place, including standard data transfer agreements that require recipients in other countries to meet data protection standards comparable to Malaysia's PDPA 2010. We only work with providers that have robust, audited data protection policies.

12 Changes to the Privacy Policy

Win1 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or changes to the services we offer. Each new version of this Policy will carry an updated "Last Updated" date at the top of the document.

For material changes — that is, changes that significantly affect your privacy rights or how we use your data — win1 will notify you via your registered email at least 14 days before the changes take effect. For non-material changes (such as spelling corrections or language clarifications), we will update the Policy without prior notice.

Continued use of the win1 platform after the effective date of any Policy changes will be considered acceptance of the updated Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we handle your personal data.