Win111 Privacy Policy – Data Protection Malaysian Member Personal

This Privacy Policy ("Policy") is published by win111 ("we", "win111", or "Platform") and applies to all users and registered members of the win111 platform in Malaysia. It explains how we collect, store, use, and protect your personal information when you use win111's services.

Win111's services cover the official win111 website, a sports betting platform encompassing the Malaysia Super League, EPL, Thomas Cup badminton, MPL Malaysia e-sports, Live Casino, slots, poker, jackpot, and all related support services including customer support and financial processing via DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, and FPX.

Win111 fully complies with Malaysia's Personal Data Protection Act 2010 (PDPA). We are committed to ensuring that all personal data processing is carried out lawfully, fairly, and transparently in accordance with applicable Malaysian legal requirements.

Win111 collects various categories of personal data depending on how you interact with our platform. Below are full details of the data we collect and the sources from which it is collected:

Win111 does not collect sensitive data such as health information, biometric data, or political views unless required by law for specific identity verification purposes. We also do not directly collect credit card data — all payments are processed through certified third-party payment gateways.

Win111 uses the personal data collected for the following legitimate purposes, all of which are necessary for the provision of our online sports betting and casino services:

• Account Management: Creating, verifying, and maintaining your win111 account, including two-factor identity verification via SMS to your Malaysian phone number.
• Service Provision: Allowing you to place bets on Malaysia Super League, EPL, badminton, MPL e-sports, and all other sports, as well as access Live Casino games, slots, and poker on win111.
• Financial Transaction Processing: Processing deposits and withdrawals via DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, and FPX, and maintaining complete MYR transaction records.
• Security & Fraud Prevention: Detecting and preventing fraudulent activity, money laundering, multiple account ownership, and other security threats to the win111 platform.
• Legal Compliance: To fulfil Malaysian legal obligations, including PDPA requirements, anti-money laundering laws (AMLA), and directives issued by competent authorities.
• Service Communications: Sending important notifications regarding your account, changes to win111's Terms & Conditions or Privacy Policy, and critical security updates.
• Marketing (With Consent): Sending you information about win111 promotions, bonuses, and offers via email or SMS — only if you have given your consent to receive marketing communications.
• Product Improvement: Analysing win111 platform usage patterns on an aggregate basis to better understand the needs of Malaysian players and improve the overall user experience.

Win111 does not sell, rent, or distribute members' personal data to third parties for their own marketing purposes under any circumstances. However, to deliver win111's services effectively, we may share certain data with the following categories of third parties, subject to strict confidentiality and data protection agreements:

• Payment Service Providers: Payment gateways and digital wallet providers such as Boost, ShopeePay, GrabPay, and FPX processors, strictly for the purpose of processing deposits and withdrawals. They receive only the minimum data required to complete transactions and are governed by their own privacy policies and Bank Negara Malaysia regulations.
• Technology Service Providers: Cloud infrastructure providers, identity verification service providers, and cybersecurity solution vendors who assist us in operating the win111 platform. All such providers are bound by data processing agreements that prohibit them from using win111 member data for any other purpose.
• Regulatory Authorities & Law Enforcement: win111 will disclose personal data to Malaysian authorities when required by court order, legal investigation, or regulatory compliance obligations. This includes cooperating with enforcement agencies in financial crime and anti-money laundering investigations.
• Auditors & Professional Advisors: Accounting firms, law firms, and business advisors bound by professional confidentiality, who receive only the data necessary to perform their services for win111.

In all data-sharing instances described above, win111 ensures that receiving parties have adequate data protection measures in place and use the data solely for the specified purposes.

Win111 continually invests in security infrastructure to protect the personal data of our Malaysian members. The technical and organisational measures we have in place include:

• Data Encryption in Transit: All communications between your browser or app and win111's servers are secured using TLS 1.3 with SSL 256-bit encryption — the same standard used by banking institutions.
• Stored Data Encryption: Sensitive information such as member passwords is stored using strong one-way hashing algorithms. win111 does not store passwords in plain text.
• Role-Based Access Control: Internal access to win111 member data is restricted on a least-privilege basis — staff can only access the data required to perform their specific duties.
• Continuous Security Monitoring: win111 systems are monitored 24/7 to detect suspicious activity, intrusion attempts, or usage anomalies that may indicate a security threat.
• Two-Factor Authentication: win111 offers and encourages the use of two-factor authentication (2FA) on all member accounts as an added layer of security beyond usernames and passwords.
• Regular Security Audits: win111 conducts regular security assessments and penetration testing by independent third parties to identify and address potential security vulnerabilities.

Win111 retains member personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy, or as required by applicable Malaysian law. The following is a guide to our data retention periods:

• Active Account Data: Retained for as long as your win111 account remains active. This data is necessary to provide you with uninterrupted service.
• Financial Transaction Records: Retained for a minimum of 7 years after the transaction date, as required under Malaysian financial and tax laws. This covers all MYR deposit and withdrawal records processed via DuitNow, Touch 'n Go, GrabPay, and other payment methods.
• Betting Records: Sports and casino betting history is retained for 5 years for the purposes of dispute resolution, auditing, and legal compliance.
• Support Communication Records: Customer support conversations are retained for 2 years from the date of last interaction.
• Technical Log Data: System and security logs are retained for 12 months for security and incident investigation purposes.
• Inactive Accounts: If a win111 account has been inactive for 12 consecutive months, we may archive or delete non-critical data while retaining any records required by law.

Once the applicable retention period has elapsed, your personal data will be securely deleted or anonymised in accordance with win111's established data management procedures.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data held by win111. We are committed to respecting and facilitating the exercise of these rights:

To exercise any of the rights above, please contact the win111 privacy team by emailing support@win111.biz stating the right you wish to exercise and your account details. We will verify your identity before processing any data-related request to protect the security of your account.

Win111 uses cookies and similar tracking technologies to enhance the user experience on our platform and for analytics purposes. The following are the types of cookies we use:

You can manage and delete cookies through your browser settings. However, disabling essential cookies may affect the win111 platform's functionality and your ability to log in or use our services fully.

The win111 platform is not intended for individuals under the age of 18, and we do not knowingly collect personal data from children or minors below this age. Account registration on win111 is strictly permitted only for individuals who are 18 years of age or older.

Win111 takes child protection very seriously. Should we discover that personal data belonging to an individual under the age of 18 has been collected inadvertently, we will take immediate steps to delete that data and close the account in question.

Win111 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, applicable Malaysian legal requirements, or technological developments that affect how we handle personal data.

When we make material changes to this Privacy Policy, we will notify you through one of the following methods:

• Displaying a clear notice on the win111 platform's main page for at least 14 days before the changes take effect.
• Sending notifications via email to the email address registered to your win111 account.
• Updating the "Last Updated" date shown at the top of this Privacy Policy.

Continued use of the win111 platform after an updated Privacy Policy takes effect constitutes your acceptance of the changes. We encourage you to review this page periodically to stay informed about how we protect your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or how win111 handles your personal data, please reach out to us through the channels below. The win111 privacy team will respond within 2 business days for general enquiries, and within 21 days for formal data rights requests:

You also have the right to lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP) if you believe win111 has processed your personal data in a manner that violates the Personal Data Protection Act 2010. We encourage you to contact us first before filing a formal complaint so we can address your concerns directly and promptly.