Privacy Policy — Winnow44

Winnow44 ("we", "us", "our", "the Platform") operates the online casino and sports betting platform accessible at https://winnow44.cam. We are committed to safeguarding the privacy and personal data of every individual who registers an account, visits the Platform, or interacts with our services in any capacity.

This Privacy Policy ("Policy") describes the categories of personal data that Winnow44 collects, the purposes for which we process that data, the circumstances under which we may share it with third parties, the security measures we apply to protect it, and the rights available to you as a data subject.

This Policy applies to all players, prospective players, and website visitors regardless of their location, and covers all personal data processed in connection with your use of the Winnow44 Platform. It should be read alongside our Terms & Conditions.

The following terms carry specific meanings throughout this Privacy Policy:

Winnow44 collects only the categories of personal data that are reasonably necessary for the operation of the Platform and the provision of our services. The data we collect falls into the following categories:

3.1 Registration & Identity Data

• Full legal name as it appears on your identification document.
• Date of birth (to verify that you are aged 21 years or above).
• Email address and mobile phone number.
• Residential address, including city, state, and postcode — e.g., addresses in Kuala Lumpur, Petaling Jaya, Shah Alam, Penang, or Johor Bahru.
• Username and account credentials (password stored in encrypted form only).

3.2 KYC Verification Data

• Copy of government-issued photo identification (MyKad, passport, or equivalent).
• Proof of residential address (utility bill, bank statement dated within 3 months).
• Payment method verification documents where required by our compliance procedures.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method identifiers.
• Payment method details in tokenised or partially masked form — e.g., the last four digits of a bank account, e-wallet identifier for Touch 'n Go eWallet, Boost, GrabPay, or DuitNow accounts.
• Account balance history and bonus credit records.

3.4 Gaming Activity Data

• Game session logs including start/end times, wager amounts, and outcomes.
• Sports betting selections, odds accepted, and settlement records.
• Bonus claims and wagering requirement progress.
• Responsible gambling limit settings applied to your account.

3.5 Technical & Device Data

• IP address and approximate geographic location derived therefrom.
• Device type, operating system, browser type and version.
• Session duration and page interaction data collected via cookies and analytics tools.
• Login timestamps and authentication event logs.

3.6 Communications Data

• Records of live chat conversations, email correspondence, and support ticket submissions.
• Responses to voluntary surveys or feedback forms.
• Marketing preference choices and opt-in/opt-out records for promotional communications.

Winnow44 collects personal data through the following channels:

• Directly from you: When you complete the account registration process, submit KYC documentation, make a deposit or withdrawal request, contact our support team, or interact with any feature of the Platform that requires data input.
• Automatically: Through cookies, server logs, and analytics scripts that operate when you access and navigate the Platform. This includes IP address, session data, and browsing behaviour within the Platform.
• From payment processors: Transaction confirmation data from payment service providers including FPX, DuitNow, and e-wallet platforms, provided in accordance with applicable data sharing agreements.
• From identity verification services: Where Winnow44 engages a third-party KYC verification provider to assist with document authentication and identity screening.
• From fraud prevention services: Risk scoring and device fingerprint data from fraud prevention tools used to protect the integrity of the Platform.

Winnow44 processes your personal data on the basis of one or more of the following lawful grounds, depending on the specific processing activity:

Winnow44 uses the personal data we hold about you for the following specific purposes:

• Account management: To create, maintain, and administer your Winnow44 player account, including processing login events and maintaining your account balance.
• Payment processing: To facilitate MYR deposit and withdrawal transactions via your chosen payment method, whether that is Touch 'n Go eWallet, Maybank2u, CIMB Clicks, DuitNow, FPX, or any other accepted method.
• Identity & age verification: To verify that you meet the minimum age requirement of 21 years and that your identity matches the information provided at registration, in compliance with our KYC obligations.
• Service delivery: To enable your participation in casino games, live dealer tables, sports betting markets including EPL and Liga Super Malaysia, and all other Platform features.
• Security & fraud prevention: To monitor account activity for signs of fraudulent behaviour, money laundering, multi-accounting, or other prohibited conduct as defined in our Terms & Conditions.
• Customer support: To respond to enquiries, resolve disputes, and provide assistance via live chat and email in connection with your account.
• Responsible gambling: To monitor gaming behaviour patterns, apply self-imposed limits set by you, and — where necessary — to contact you regarding potential signs of problem gambling in accordance with our responsible gambling obligations.
• Regulatory compliance: To maintain transaction records, respond to lawful regulatory enquiries, and comply with applicable anti-money laundering and financial crime prevention obligations.
• Platform improvement: To analyse aggregated, anonymised usage data for the purpose of improving Platform performance, game selection, payment processing efficiency, and user experience.
• Marketing communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications, and Winnow44 product updates by email or other agreed channels.

Winnow44 does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment service providers: Malaysian banking institutions and e-wallet operators (including those operating Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect, Touch 'n Go eWallet, Boost, GrabPay, and DuitNow/FPX infrastructure) receive the minimum data required to process your deposit and withdrawal transactions.
• KYC and identity verification providers: Third-party verification services that assist us in authenticating identity documents and conducting AML screening. These providers are contractually bound to process data only for the verification purposes instructed by Winnow44.
• Fraud prevention and security services: Technology providers that assist in detecting and preventing fraudulent transactions, multi-accounting, and platform abuse. Data shared is limited to technical and transactional signals necessary for risk assessment.
• IT infrastructure and cloud service providers: Hosting, data storage, and platform infrastructure providers that process data on Winnow44's behalf under binding data processing agreements.
• Legal and regulatory authorities: Where Winnow44 is required by applicable law, court order, or regulatory directive to disclose personal data, we will comply with such requirements and will notify you where legally permissible to do so.

The Winnow44 Platform uses cookies and similar tracking technologies to operate core platform functionality and to improve your experience as a player. The following categories of cookies are in use:

• Strictly necessary cookies: These are essential for the Platform to function. They maintain your logged-in session state, remember your language preferences, and enable secure authentication. These cookies cannot be disabled without disrupting Platform functionality.
• Functional cookies: These remember your preferences such as display settings and responsible gambling limit configurations, allowing us to provide a more consistent experience across sessions.
• Analytics cookies: Anonymised data about how pages are accessed, which features are used most frequently, and where users encounter difficulties. This data is used in aggregate to improve Platform design and performance.
• Security cookies: Used to detect and prevent fraudulent sessions, multi-account usage, and automated bot interactions with the Platform.

You may manage cookie preferences through your browser settings. Disabling certain cookies may limit the functionality available to you on the Platform. Winnow44 does not use third-party advertising cookies or track your behaviour across websites that are unrelated to this Platform.

Winnow44 retains personal data for no longer than is reasonably necessary for the purposes described in this Policy or as required by applicable law and regulatory obligations. The following indicative retention periods apply:

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

Winnow44 implements a layered approach to data security, applying technical and organisational measures commensurate with the sensitivity of the personal data we hold. Our security framework includes:

• Encryption in transit: All data transmitted between your device and the Winnow44 Platform is protected using TLS 1.2 or higher (256-bit SSL encryption). This applies to all account interactions, payment processing, and API communications with third-party service providers.
• Encryption at rest: Sensitive personal data stored in our systems, including KYC documents, payment method identifiers, and authentication credentials, is encrypted at rest using industry-standard encryption protocols.
• Access controls: Access to personal data is restricted on a need-to-know basis. Winnow44 staff are granted system access only to the minimum data necessary to perform their specific role. All access events are logged.
• Password security: Account passwords are stored in hashed form using a strong one-way algorithm. Winnow44 does not have the ability to retrieve plain-text passwords and will never ask you for your password through any channel.
• Incident response: Winnow44 maintains an internal data breach response procedure. In the event of a data security incident that poses a risk to your rights and interests, we will notify affected players without undue delay through the registered contact channels on file.

While Winnow44 applies robust security measures, no internet-based system can be guaranteed completely secure. Players are encouraged to maintain strong, unique passwords and to notify our support team immediately if they suspect any unauthorised access to their account.

Winnow44 is a platform primarily serving Malaysian players. Some of the third-party service providers engaged by Winnow44 — including cloud infrastructure providers, KYC verification services, and gaming software suppliers — may process data in jurisdictions outside of Malaysia.

In all cases where personal data is transferred to a service provider operating outside of Malaysia, Winnow44 ensures that appropriate safeguards are in place to provide an equivalent level of data protection to that which applies within Malaysia. These safeguards may include:

• Contractual data processing agreements incorporating standard data protection clauses.
• Selection of service providers who operate under equivalent or stronger data protection frameworks.
• Limiting the scope of data transferred to only what is strictly necessary for the service provider to perform their contracted function.

You may request further information about specific international transfer arrangements applicable to your personal data by contacting us using the details in Section 16 of this Policy.

As a data subject, you hold the following rights in respect of the personal data that Winnow44 holds about you. Requests should be submitted in writing to the contact details in Section 16:

Winnow44 will acknowledge all data rights requests within 5 business days and endeavour to respond substantively within 30 calendar days. Where a request is particularly complex or high in volume, this period may be extended by a further 30 days, with notice provided to you.

The Winnow44 Platform may, in certain contexts, reference or interact with third-party services — including payment processors such as FPX, DuitNow, Touch 'n Go eWallet, and Boost — in the course of processing your transactions. These services operate under their own privacy policies and terms of service.

Winnow44 is not responsible for the privacy practices of third-party payment service providers or banking institutions. When you authenticate a transaction through a third-party banking portal (such as Maybank2u, CIMB Clicks, Public Bank Online, or Hong Leong Connect), the data you enter in that portal is subject to that institution's own privacy terms.

We encourage you to review the privacy documentation of any third-party service you interact with in the course of using the Winnow44 Platform.

The Winnow44 Platform is strictly intended for use by individuals who are 21 years of age or older. We do not knowingly collect or process personal data belonging to individuals under the age of 21.

Registration on the Platform requires affirmative declaration that the individual is of legal age. All accounts are subject to age verification as part of the KYC process. Where Winnow44 discovers that personal data has been collected from an individual who does not meet the minimum age requirement, that data will be deleted promptly and the associated account permanently suspended.

Winnow44 reserves the right to update or amend this Privacy Policy at any time. Material changes to this Policy — such as the introduction of new data processing activities, changes to retention periods, or updates to data sharing arrangements — will be communicated to registered players via the email address on file, at least 14 days prior to the changes taking effect where operationally feasible.

Non-material changes, such as corrections to typographical errors or clarifications that do not alter the substance of the Policy, may be made without prior notice. The date of the most recent revision is displayed at the top of this page.

Your continued use of the Winnow44 Platform following notification of a material Policy update constitutes your acceptance of the amended terms. If you do not accept the changes, you may request account closure as described in the Terms & Conditions.

If you wish to exercise any of your data rights, raise a privacy concern, or submit a formal complaint regarding the handling of your personal data by Winnow44, please contact our Data & Privacy team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, through the Winnow44 Platform.
• Email: [email protected] — Please include the subject line "Privacy Request" or "Data Rights Enquiry" to ensure prompt routing to the appropriate team. We aim to respond within 5 business days.
• Business Hours (Malaysia / MYT): 8:00am – 12:00am, Monday to Sunday.

Winnow44 serves players across Kuala Lumpur, Petaling Jaya, Shah Alam, Penang, Johor Bahru, and throughout Malaysia. Our support team is fully conversant with Malaysian banking systems and can assist with any data-related query in the context of your Winnow44 account.

Where you are not satisfied with our response to a privacy complaint, you may seek further guidance from applicable consumer protection authorities or data protection oversight bodies in your jurisdiction.