winnow44 Privacy Policy

1. About This Privacy Policy

This Privacy Policy ("Policy") describes how winnow44 ("winnow44", "we", "us", "our") collects, uses, stores, shares, and protects the personal data of individuals ("you", "Player", "User") who access or use the winnow44 platform at winnow44.lat and its associated mobile applications, downloadable software, and services (collectively, the "Platform").

This Policy is incorporated by reference into the winnow44 Terms & Conditions and forms an integral part of our agreement with you. By registering an account or using the winnow44 Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

We are committed to processing personal data in a manner that is lawful, fair, transparent, and in accordance with applicable data protection legislation, including but not limited to Malaysia's Personal Data Protection Act 2010 (PDPA 2010) where applicable.

2. Data Controller

For the purposes of applicable data protection law, winnow44 acts as the data controller in respect of personal data collected from players who use the Platform. All queries, access requests, and data-related complaints should be directed to our dedicated data protection contact as set out in Section 14 of this Policy.

3. Information We Collect

3.1 Registration & Account Data

When you create a winnow44 account, we collect personal information including your full legal name, date of birth, residential address, email address, and mobile phone number. This information is required to create and maintain your account, verify your identity, and comply with applicable Know Your Customer (KYC) and anti-money laundering (AML) obligations.

3.2 Identity Verification Documents

As part of our KYC process, winnow44 may collect copies of government-issued identification documents (such as a Malaysian IC or passport), proof of residential address, and in some cases, proof of source of funds. These documents are processed securely and retained only for as long as required by applicable law and our internal compliance policies.

3.3 Financial & Transaction Data

We collect details of your deposits, withdrawals, and gaming transactions on the Platform. This includes payment method details (such as e-wallet account identifiers for Touch n Go eWallet and Boost, or masked bank account details for Maybank, CIMB, and Public Bank), transaction amounts in MYR, timestamps, and transaction reference numbers.

3.4 Technical & Usage Data

When you access the winnow44 Platform, we automatically collect certain technical information, including your IP address, device type and operating system, browser type and version, session start and end times, pages visited and features accessed, and referring URLs. This data is collected via cookies, server logs, and similar technologies.

3.5 Communications Data

If you contact winnow44 through live chat, email, or WhatsApp support, we retain records of those communications — including the content of messages and the time and date of contact — for quality assurance, training, and dispute resolution purposes.

3.6 Responsible Gaming Data

If you use our responsible gaming tools — including setting deposit limits, requesting cooling-off periods, or applying for self-exclusion — we record this information specifically to honour your instructions and prevent access in accordance with your request.

4. How We Use Your Personal Data

winnow44 uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, and securing your winnow44 account; processing logins and authenticating your identity.
• Service delivery: Processing deposits and withdrawals; crediting wins and bonuses; delivering the gaming and sportsbook services you have requested.
• Regulatory compliance: Fulfilling our KYC, AML, and responsible gaming obligations under applicable licensing and regulatory requirements; reporting obligations to competent authorities where required.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, multi-accounting, money laundering, and other prohibited activities on the Platform.
• Customer support: Responding to your enquiries; resolving disputes; processing complaints; improving our support services.
• Platform improvement: Analysing aggregated usage patterns to improve game performance, user interface design, and overall Platform stability and experience.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.
• Responsible gaming: Monitoring gameplay patterns for indicators of problem gambling; applying player-requested limits and exclusions; following up where welfare concerns are identified.

5. Legal Basis for Processing

winnow44 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform the agreement between you and winnow44, including account creation, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable KYC, AML, and regulatory reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, customer support operations, and limited analytics — where these interests are not overridden by your fundamental privacy rights.
• Consent: Processing for direct marketing communications and non-essential cookies — where you have provided explicit, freely given consent. Consent can be withdrawn at any time without affecting the lawfulness of prior processing.

6. Disclosure & Sharing of Personal Data

winnow44 does not sell your personal data to third-party advertisers or data brokers under any circumstances. We may share your personal data with the following categories of recipients:

• Payment service providers: Touch n Go eWallet, Boost, FPX, and banking partners (Maybank, CIMB, Public Bank) solely for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party services used to verify the identity documents and age of winnow44 players as required by our compliance programme.
• Game software providers: Game studios and platform providers whose titles are featured on the winnow44 Platform may receive technical session data necessary to operate their games.
• Regulatory and law enforcement authorities: Where we are required by law, court order, or regulatory directive to disclose personal data to competent authorities.
• Group companies and service providers: Internal affiliates and outsourced service providers (such as cloud hosting, IT infrastructure, and customer support tools) who process data on our behalf under strict data processing agreements that require them to maintain appropriate security standards.

All third-party processors engaged by winnow44 are contractually required to process personal data only in accordance with our instructions and to implement appropriate technical and organisational security measures.

7. Cookies & Tracking Technologies

The winnow44 Platform uses cookies and similar tracking technologies to operate core Platform functionality, remember your preferences, analyse usage, and support responsible gaming monitoring. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function — including session management, login authentication, and security. These cannot be disabled without impairing Platform functionality.
• Functional cookies: Remember your preferences such as language settings and display options to provide a more personalised experience.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate the Platform, which features are most used, and where technical issues occur. This data is used to improve Platform performance.
• Marketing cookies: Where you have consented, these cookies support targeted promotional communications relevant to your gaming preferences.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the winnow44 Platform.

8. Data Retention

winnow44 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including legal, regulatory, accounting, and reporting obligations. In practice:

• Account and KYC data is retained for a minimum of five (5) years following the closure of your account, as required by applicable AML regulations.
• Transaction records are retained for a minimum of seven (7) years in accordance with financial record-keeping requirements.
• Customer support communications are retained for a period of three (3) years from the date of the interaction.
• Marketing consent records are retained for as long as your account is active or until you withdraw consent, whichever is sooner.

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

9. Your Rights

Subject to applicable data protection law, you have the following rights in relation to your personal data held by winnow44:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data in certain circumstances — subject to our legal retention obligations.
• Right to restriction: You may request that we limit processing of your data in certain circumstances, such as while a dispute is being investigated.
• Right to data portability: Where technically feasible, you may request your personal data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing carried out on the basis of legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw consent at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us as set out in Section 14. We will respond within a reasonable timeframe and in any event no later than thirty (30) days of receiving a valid request.

10. Data Security

winnow44 implements industry-standard 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 for all data transmitted between your device and the winnow44 Platform.
• Encryption of sensitive data at rest within our database infrastructure.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits and vulnerability assessments of Platform infrastructure.
• Two-factor authentication requirements for administrative access to systems containing personal data.

Notwithstanding these measures, no internet-based system can be guaranteed to be entirely secure. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, winnow44 will notify affected players without undue delay in accordance with applicable regulatory requirements.

11. International Data Transfers

The winnow44 Platform is operated from and primarily serves users in Malaysia. Where personal data is transferred to or accessed from jurisdictions outside Malaysia — for example, in connection with cloud infrastructure providers or game studio partnerships — winnow44 ensures that appropriate safeguards are in place to protect your data. These safeguards may include contractual data transfer mechanisms, adequacy decisions, or equivalent protections recognised under applicable data protection law.

12. Children and Minors

The winnow44 Platform is strictly restricted to adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If you believe that a person under the age of 21 has registered an account or provided personal data to winnow44, please contact us immediately at the address set out in Section 14 so that we may take appropriate action, including immediate account closure and deletion of the relevant data.

13. Changes to This Policy

winnow44 reserves the right to update or amend this Privacy Policy at any time. The "Last updated" date at the top of this page will be revised accordingly. For material changes that significantly affect how we process your personal data, we will endeavour to provide advance notice via email to your registered address or via a prominent notice on the Platform. We encourage you to review this Policy periodically to stay informed of how winnow44 protects your data.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by winnow44, please contact our data protection team through the following channel:

📧 Email: [email protected]

Our support team is available 24 hours a day, 7 days a week. Data-related requests will be acknowledged within 3 business days and resolved within 30 calendar days wherever possible. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.