Privacy Policy — How mywin161 Protects Your Personal Data

Introduction

mywin161 ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all individuals who access or use the mywin161 website atmywin161.cam and any associated services, including online casino games, sports betting markets, and customer support channels (collectively, "the Services").

This Privacy Policy ("Policy") describes in detail the categories of personal data we collect, the purposes and legal bases for which we process that data, the circumstances in which we may share it with third parties, and the rights available to you as a data subject. This Policy applies to all registered users and visitors to the Platform, including those accessing from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and all other locations in Malaysia and beyond.

This Policy should be read in conjunction with our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference. By creating an account on mywin161 or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial information, and online identifiers.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, erasure, or destruction.
• "Data Subject" means the natural person whose personal data is being processed — in this context, you as a User of the Platform.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, mywin161.
• "Data Processor" means a third-party entity that processes personal data on behalf of mywin161, pursuant to a written data processing agreement.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the data subject's wishes, signifying agreement to the processing of their personal data for a specified purpose.
• "Cookies" means small text files placed on your device by the Platform to store information about your session, preferences, and behaviour on the Platform.

Data We Collect

mywin161 collects personal data across several categories depending on how you interact with the Platform. The categories of personal data we collect are summarised in the table below:

We do not knowingly collect sensitive personal data (such as racial or ethnic origin, religious beliefs, or health data) unless specifically required for responsible gambling assessments and with your explicit consent.

How Data Is Collected

mywin161 collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, contact our support team, or update your account profile.
• Automatically via the Platform: Technical and usage data is collected automatically through cookies, session tracking, and server logs as you browse and interact with the Platform.
• From payment service providers: When you initiate a transaction via FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, or your Malaysian bank, our payment processors may share transaction confirmation and fraud-screening data with us.
• From identity verification services: Where we use third-party KYC or identity verification providers to assist with document authentication, these providers may share verification outcomes and relevant identity data with us.
• From publicly available sources: We may supplement account information with data from publicly available registers or databases where required for AML compliance purposes.

Legal Basis for Processing

mywin161 processes your personal data only where a valid legal basis exists. The legal bases applicable to our processing activities are as follows:

• Contract Performance: Processing necessary to fulfil our contractual obligations to you under the Terms & Conditions, including operating your account, processing deposits and withdrawals, and providing access to games and betting markets.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) legislation, Know Your Customer (KYC) requirements, and regulatory reporting obligations.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, service improvement, and responsible gambling monitoring — provided such interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent for specific processing activities (such as sending marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

How We Use Your Data

mywin161 uses your personal data for the following purposes:

• To create, verify, and manage your account on the Platform.
• To process deposits and withdrawals using your chosen Malaysian payment methods, including FPX, DuitNow, and e-wallets.
• To conduct mandatory KYC and age verification to confirm that you are aged 21 or above and that your identity details are accurate.
• To detect, investigate, and prevent fraud, money laundering, and other forms of financial crime.
• To administer bonuses, loyalty programmes, and promotional offers in accordance with their specific terms.
• To provide customer support via live chat and email, and to maintain records of communications for quality assurance purposes.
• To monitor your gambling behaviour for responsible gambling purposes, including identifying patterns that may indicate problem gambling, and to apply or enforce account-level tools such as deposit limits and self-exclusion.
• To personalise your experience on the Platform, including recommending games and promotions relevant to your preferences.
• To improve Platform functionality, fix technical issues, and develop new features through analysis of aggregated usage data.
• To send you transactional and service communications, including account notifications, security alerts, and policy updates.
• To send you marketing communications where you have opted in to receive such communications, or where we have a legitimate interest in doing so.

Data Sharing & Disclosure

mywin161 does not sell, rent, or trade your personal data to any third party for commercial gain. We share personal data only in the following limited circumstances:

• Payment Service Providers: We share financial data with our payment gateway partners (including those facilitating FPX, DuitNow, and e-wallet transactions) to the extent necessary to process your transactions. These providers are bound by contractual data processing terms and applicable financial regulations.
• Identity Verification Providers: KYC and document authentication services receive the identity documents you submit for verification purposes only. These providers are prohibited from using your data for any purpose other than the verification service they provide to us.
• Technology & Hosting Partners: Cloud infrastructure, data storage, and platform software providers who process data on our behalf under strict contractual data processing agreements.
• Regulatory Authorities: We are required by law to disclose certain information to licensing and regulatory bodies, financial intelligence units, tax authorities, and law enforcement agencies when required by a valid legal obligation or court order.
• Fraud Prevention Agencies: We may share information with fraud prevention and detection services where we have reasonable grounds to suspect fraudulent activity.
• Business Transfers: In the event of a merger, acquisition, or sale of the Platform, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

International Data Transfers

Some of our service providers and technology partners may process your personal data in countries outside Malaysia. Where such international transfers occur, mywin161 ensures that adequate safeguards are in place to protect your data, including:

• Transfers to countries that provide an equivalent level of data protection as recognised by relevant regulatory frameworks.
• Contractual clauses that impose data protection obligations on the recipient entities equivalent to those applicable under this Policy.
• Reliance on the legitimate interests or legal obligations legal bases where such transfers are necessitated by regulatory compliance requirements, such as AML obligations.

You may request further information regarding our international transfer safeguards by contacting us at [email protected].

Data Retention

We retain personal data for as long as necessary to fulfil the purposes described in this Policy, including meeting our legal, regulatory, and contractual obligations. The following general retention periods apply:

• Account data and KYC documents: Retained for a minimum of 5 years following account closure to comply with AML record-keeping obligations.
• Transaction records: Retained for a minimum of 7 years for financial regulatory compliance purposes.
• Customer support communications: Retained for 3 years for quality assurance and dispute resolution.
• Marketing preferences and consent records: Retained for the duration of the account relationship and for a reasonable period thereafter as evidence of consent status.
• Technical and usage logs: Typically retained for 12 months for security and fraud monitoring purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with you.

Data Security

mywin161 implements a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit AES encryption for data stored at rest and TLS 1.2+ encryption for all data transmitted between your device and our servers.
• Role-based access controls ensuring that employees and contractors can only access personal data necessary for their specific function.
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent third-party security firms.
• Multi-factor authentication requirements for all administrative access to production systems.
• Comprehensive employee data protection training and strict internal data handling policies.
• Incident response procedures that include prompt notification of affected users in the event of a data breach involving their personal data.

While we take reasonable steps to protect your data, no electronic transmission or storage system is entirely immune to risk. You are responsible for maintaining the security of your own account credentials and should notify us immediately at [email protected] if you suspect any unauthorised access to your account.

Cookies & Tracking Technologies

mywin161 uses cookies and similar technologies (such as web beacons and session tokens) to operate the Platform, maintain your session, and improve your experience. The types of cookies we use are as follows:

• Strictly Necessary Cookies: Essential to the basic operation of the Platform, including session management, authentication, and security functions. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences, language settings, and other personalisation choices to provide a consistent experience across sessions.
• Analytical Cookies: Collect aggregated, anonymised data about how users interact with the Platform — including pages visited, time spent, and error reports — to help us improve service quality. We do not use third-party advertising network analytical cookies.
• Responsible Gambling Cookies: Track session duration and betting patterns specifically to support our responsible gambling monitoring and intervention obligations.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality. For further details on how to manage cookies, refer to your browser's help documentation.

Your Rights as a Data Subject

As a data subject, you have the following rights in relation to your personal data held by mywin161. We will respond to all valid requests within 30 days of receipt, unless the request is complex or voluminous, in which case we may extend this period by a further30 days with prior notification.