Privacy Policy win39 – Protecting Your Data

1 Information We Collect

Win39 collects your personal data through various means as you interact with our platform. We only collect information that is strictly necessary to deliver a secure, fair, and high-quality service to you.

Information you provide directly:

• Full name, date of birth, and identity card or passport number (for the KYC process).
• Email address, phone number and residential address.
• Bank account details, card numbers, or e-wallet information used for deposits and withdrawals.
• Username, password (stored in unreadable hashed form), and security questions.
• Any information you submit via support forms, live chat, or email to the win39 team.

Information collected automatically:

• Your IP address, device type, operating system and web browser version.
• Activity log data including pages visited, session duration, clicks and navigation patterns within the platform.
• State or city-level geolocation data (not precise GPS coordinates) for legal compliance purposes.
• Game performance data including betting history, wins, losses and bonus records used.

2 How We Use Your Data

Every piece of information we collect is used for clear and legitimate purposes. win39 will not use your data for any other purpose without notifying you in advance. The following are the primary purposes for which your data is used:

Win39 uses your gameplay pattern data anonymously to improve the platform experience, ensure smooth gameplay, and identify any technical issues more quickly. This analysis is not linked to your personal identity.

3 Basis for Data Processing

Win39 processes your personal data on valid legal bases in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA). We identify the most appropriate processing basis for each data processing activity:

• Contract fulfilment: Processing required to deliver the services you have requested — including account management, payment processing, and wagering operations.
• Legal obligation: Processing required to fulfil our legal obligations, including KYC requirements and AML reporting to relevant authorities.
• Legitimate interest: Processing required for win39's legitimate interests, such as fraud prevention, platform security, and service improvement — provided these interests do not override your privacy rights.
• Consent: For optional processing such as marketing communications and experience personalisation, we request your explicit consent. You may withdraw this consent at any time.

4 Information Sharing

Win39 does not trade in your personal data. We do not sell, rent, or deal in member information to third parties for commercial gain. However, there are limited situations where we may need to share your data with specific parties:

• Payment service providers: FPX operators, banks, e-wallet providers, and payment gateways used to process your deposits and withdrawals. They receive only the data necessary for those transactions.
• Third-party game providers: win39's partner gaming platforms may receive your username and account balance to enable gameplay. They do not receive your personally identifiable information.
• Legal Authority: win39 will disclose data to government authorities or law enforcement when required by a valid court order, warrant, or other binding legal obligation.
• Technical service providers: Companies that help us manage IT infrastructure, cybersecurity, analytics, and customer support — bound by strict confidentiality agreements.

5 Data Security

Win39 continuously invests in the latest security infrastructure to ensure your personal data is always protected against unauthorised access, breaches, alteration, or loss. Our technical and operational security measures include:

• 256-bit SSL/TLS encryption for all data transmissions between your device and win39 servers.
• Next-generation intrusion detection systems (IDS) and firewalls that continuously monitor traffic.
• Role-based access control — win39 staff may only access data required for their specific duties.
• Regular third-party security audits conducted by recognised independent cybersecurity firms.
• Periodic data backups with encryption and storage at separate, secure locations.
• Mandatory security awareness training for all win39 staff who handle user data.

6 Data Retention Period

Win39 does not retain your personal data longer than necessary. Data retention periods are determined based on operational requirements and applicable legal obligations:

• Active account data: Retained for as long as your account is active and for an additional period after account closure in accordance with legal requirements.
• Financial transaction records: Retained for 7 years after the transaction occurs, in compliance with Malaysia's tax and AML legal requirements.
• Platform activity logs: Retained for 12 months for security and dispute resolution purposes.
• KYC documents: Retained for 5 years after the business relationship ends, in accordance with AML legal requirements.
• Support communication data: Retained for 2 years after the case is closed.

Once the retention period expires and no other legal obligation applies, your data will be permanently deleted or fully anonymised so it can no longer be linked to your identity.

7 Cookies & Tracking Technologies

Win39 uses cookies and similar tracking technologies to enhance functionality, performance, and user experience. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login authentication, session management and security. These cookies cannot be disabled as the platform will not function without them.
• Performance Cookies: Collects anonymous information about how you use the platform — most frequently visited pages, time spent in each section, and any error messages. This data helps us improve the platform.
• Functional Cookies: Remembers your preferences such as language, time zone, and display settings so you do not need to reconfigure them each time you log in.
• Analytics Cookies: Helps us understand overall platform usage patterns in aggregate and anonymised form for product development planning.

You can manage or disable optional cookies through your browser settings. However, disabling certain cookies may affect the full functionality of the win39 platform.

8 Your Rights as a User

As a registered win39 member in Malaysia, you have the following rights regarding your personal data under PDPA 2010 and our policy:

9 International Data Transfers

In operating the win39 platform, some of your personal data may be processed or stored on servers located outside Malaysia. This occurs primarily in the context of cloud service providers and international technology partners.

When such data transfers occur, win39 ensures that:

• The recipient country or organisation maintains adequate and equivalent data protection standards.
• Appropriate data transfer agreements — including recognised standard contractual clauses — are signed between win39 and the recipient.
• Additional protective measures such as data encryption prior to transfer are implemented where appropriate.
• Full compliance with PDPA 2010 requirements regarding the transfer of personal data outside Malaysia.

10 Children's Privacy

The win39 platform is exclusively for users aged 18 years and above. We do not knowingly collect, store or process any personal data from individuals under the age of 18.

If you discover that a child has registered an account on the win39 platform or has provided us with personal data without parental or guardian knowledge, please contact us immediately at [email protected]. We will take immediate action to delete the account and all associated data.

11 Privacy Policy Amendment

Win39 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or technological developments. Any material amendments will be communicated to you via:

• Email notification to your registered address at least 14 days before the changes take effect.
• A clear notice on the win39 platform homepage during the transition period.
• Update the "Last Updated" date at the top of this document.

Continued use of the win39 platform after the effective date of any changes constitutes your acceptance of the amended Privacy Policy. If you disagree with the changes made, you have the right to close your account and request deletion of your data in accordance with the established procedures.

12 Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or how win39 handles your personal data, our privacy team is ready to assist you.

For formal data rights requests (access, correction, deletion), please include your full name, win39 account number, and a clear description of your request in the email to expedite the identity verification process.