Euwin Privacy Policy – Malaysia Member Data Protection

1 Introduction

Euwin ("we", "us", or "the Company") respects the privacy of all users who access and use our platform at euwin.vin. This Privacy Policy is established to clearly and transparently explain how we handle your personal information — from how we collect it to how we protect and destroy it when it is no longer needed.

As an online gaming platform serving users in Malaysia, euwin complies with Malaysia's Personal Data Protection Act 2010 (PDPA) and international data protection best practices. We understand that your trust is our most valuable asset, and we take this responsibility seriously.

This policy applies to all personal data collected through the euwin website, the euwin mobile app, customer support services, and any other official euwin communication channels. Please read this document carefully in its entirety. If you have any questions, our team is available via 24/7 Live Chat.

2 Data Collected

Euwin collects various types of information to enable us to provide safe, personalized, and responsible services. The following are the categories of data we collect:

a) Identity Information

• Full name as stated in official documents.
• National ID number (MyKad) or passport number.
• Date of birth for age verification.
• Current residential address.
• Registered mobile phone number.
• Active email address.

b) Financial Information

• Bank account name and number for withdrawal processing.
• Digital wallet information (Touch 'n Go, GrabPay, Boost, and others).
• Deposit and withdrawal records for compliance and audit purposes.

c) Platform Usage Data

• Login records including date, time, and IP address.
• Game history and wagering activity.
• Account setting preferences and interactions with platform features.
• Communication records with the customer support team.

d) Technical Data

• Type and version of web browser used.
• Device type, operating system, and screen resolution.
• IP address and estimated geographic location.
• Cookie data and similar tracking technologies (see Section 5).

3 How We Use Your Data

Every piece of data we collect has a clear and legitimate purpose. euwin uses your personal information for the following purposes:

Euwin will not use your data for any purpose other than those stated above without first obtaining your explicit consent. For marketing communications, you may withdraw your consent at any time through your account settings or by contacting our support team.

4 Data Sharing with Third Parties

Euwin does not sell your personal data. However, in operating the platform, we need to share certain information with trusted third parties in limited and controlled circumstances:

• Payment Providers: Information required to process deposits and withdrawals is shared with certified and licensed payment providers. All such providers are bound by strict confidentiality agreements.
• KYC Service Providers: To verify member identity for anti-money laundering (AML) compliance purposes, we use licensed third-party identity verification services.
• Platform Technology Provider: Game software providers and technical infrastructure providers receive only the minimum data required to deliver their services to us.
• Legal Authorities: euwin will disclose personal data to the relevant authorities if required by law, court order, or a legitimate official investigation.

All third parties that receive data from euwin are required to uphold data protection standards equivalent to our own, and are not permitted to use that data for any purpose other than what has been agreed upon.

5 Cookies & Tracking Technologies

The euwin website uses cookies and similar tracking technologies to enhance user experience, maintain session security, and understand how members use our platform.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login authentication and session security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Helps us understand which pages are visited most and how users navigate the platform, enabling us to make continuous improvements.
• Functionality Cookies: Saves your preferences such as language, display theme, and other settings to personalise your experience.
• Analytics Cookies: Used to analyze aggregate usage patterns for service improvement purposes. This data cannot be used to personally identify you.

You can manage cookie settings through your web browser. However, disabling certain cookies may affect the functionality and user experience of the euwin platform.

6 Data Security

Euwin continually invests in the latest security infrastructure to ensure your personal data is always protected. The technical and organizational measures we employ include:

• Data Encryption in Transit: All communications between your browser and euwin's servers are secured using TLS 1.3 protocol with 256-bit SSL certificates.
• Stored Data Encryption: Sensitive information stored in our database is encrypted using AES-256, one of the strongest encryption standards available.
• Strict Access Controls: Only euwin staff who require access to specific data to carry out their duties are permitted to do so, in accordance with the principle of least privilege.
• 24/7 Monitoring: Our systems are monitored around the clock to detect any suspicious activity or unauthorised access attempts.
• Regular Security Testing: euwin conducts regular penetration testing and vulnerability assessments to identify and address potential security risks before they can be exploited.
• Two-Factor Authentication (2FA): Members are encouraged and staff are required to use 2FA for all account access.

7 Your Rights

As a euwin member and data subject under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data:

• Right of Access: You have the right to request a copy of the personal data we hold about you at any time.
• Right to Rectification: If the personal data we hold about you is inaccurate or outdated, you have the right to request a correction.
• Right to Erasure: Under certain circumstances, you have the right to request that we delete your personal data. This is subject to our legal obligations to retain certain records.
• Right to Object to Processing: You have the right to object to the processing of your data for direct marketing purposes at any time.
• Right to Data Portability: You have the right to receive your personal data in a machine-readable format for transfer to another platform.
• Right to Withdraw Consent: Where data processing is based on your consent, you have the right to withdraw that consent at any time.

To exercise any of the above rights, please contact the euwin support team via Live Chat or email at [email protected]. We will process your request within 30 calendar days of receipt.

8 Data Retention

Euwin retains your personal data for as long as it is needed for the purposes stated in this Privacy Policy, or as required by applicable law. The following are our general data retention guidelines:

• Active account data: Retained for as long as your account is active and for a reasonable period after account closure.
• Financial Transaction Records: Retained for a minimum of seven (7) years in accordance with Malaysia's financial and tax legal requirements.
• KYC Records: Retained for a minimum of five (5) years after the business relationship ends, in line with AML compliance requirements.
• Support Communication Records: Retained for two (2) years for reference and service improvement purposes.
• Technical logs: Retained for ninety (90) days for security and technical troubleshooting purposes.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised so that it can no longer be associated with you as an identifiable individual.

9 Cross-Border Data Transfer

In the course of its operations, euwin may need to transfer your personal data to servers or service providers located outside Malaysia. Whenever data is transferred across borders, we ensure protection equivalent to that provided in Malaysia through the following measures:

• Legally binding data processing agreements with all overseas service providers.
• Selection of service providers operating in countries or regions with recognised data protection standards.
• Use of approved standard contractual clauses to ensure consistent data protection.
• Periodic assessments of the data protection practices of third-party service providers.

Euwin always prioritizes the use of service providers that store data within the Asia-Pacific region where such options are available and practical, in order to minimize risks associated with cross-border data transfers.

10 Changes to the Privacy Policy

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

• A prominent notice on the euwin.vin homepage at least seven (7) days before the changes take effect.
• Notification email to your registered email address for significant changes.
• A pop-up notice in your account when you log in for the first time after the changes take effect.

The "Last Updated" date at the top of this page will be updated whenever changes are made. We encourage you to review this page periodically to stay informed about how we protect your information. Continued use of the euwin platform after any changes take effect constitutes your acceptance of the updated Privacy Policy.

11 Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or how euwin handles your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 on the euwin platform — the fastest way to get an immediate response from our team.
• Privacy Email: [email protected] — include "Privacy Inquiry" in your email subject line for faster processing.
• Response Time: We aim to respond to all privacy inquiries within 72 hours and resolve more complex cases within 30 calendar days.

For matters relating to your data rights under Malaysia's PDPA that cannot be resolved through our support channels, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia.