won99a Privacy Policy

This Privacy Policy ("Policy") is issued by the won99a Platform ("won99a," "we," "us," "our") and applies to all personal data processed in connection with your registration, use, and interaction with the won99a website accessible at won99a.app and all associated sub-pages, services, and applications (collectively, the "Platform").

By registering an Account on won99a or continuing to use the Platform after the effective date of this Policy, you acknowledge that you have read, understood, and accepted the data practices described herein. This Policy should be read together with the won99a Terms and Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

This Policy applies to all registered Account holders and unregistered visitors who access the Platform from any location, including — but not limited to — players based in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Ipoh, Kota Kinabalu, and all other regions within Malaysia.

For the purposes of applicable data protection legislation, won99a is the data controller in respect of all personal data collected through the Platform. won99a determines the means and purposes of personal data processing as described in this Policy.

Queries relating to the identity of the data controller, or requests to exercise data subject rights as described in Section 11, may be directed to the won99a support team as set out in Section 15 of this Policy.

won99a collects the following categories of personal data in connection with the operation of the Platform:

Category	Examples of Data Collected
Identity Data	Full legal name, date of birth, government-issued ID number (e.g., Malaysian MyKad or passport number), nationality
Contact Data	Email address, mobile phone number, residential address
Account Data	Username, hashed password, account preferences, responsible gaming settings
Financial Data	Deposit and withdrawal transaction records, payment method identifiers (e.g., e-wallet account references), account balance history
Technical Data	IP address, device type and operating system, browser type and version, session timestamps, geolocation data (city/country level)
Usage Data	Pages visited, games played, bets placed, session durations, in-platform navigation paths
Communications Data	Customer support chat transcripts, complaint records, feedback submissions

won99a does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, and we ask that you refrain from providing such information voluntarily through the Platform.

won99a collects personal data through the following channels:

• Directly from you — when you register a won99a Account, complete identity verification, make a deposit or withdrawal, contact customer support, or submit any form on the Platform;
• Automatically through technology — through cookies, web beacons, server logs, and similar tracking technologies when you browse or interact with the Platform (see Section 8 for details);
• From third parties — from identity verification service providers, fraud detection systems, payment processors (such as Touch 'n Go eWallet, Boost, Maybank, CIMB, and Public Bank), and analytics service providers operating on our behalf.

won99a processes personal data on the following legal bases, as applicable to each processing activity:

• Contractual necessity — processing required to perform the won99a Account agreement with you, including Account registration, deposit and withdrawal processing, and service delivery;
• Legal obligation — processing required to comply with applicable laws including anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and gaming regulatory obligations;
• Legitimate interests — processing conducted for the legitimate interests of won99a, including fraud prevention, Platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights;
• Consent — where you have provided explicit consent, for example, to receive promotional communications from won99a. You may withdraw consent at any time.

won99a uses the personal data collected for the following purposes:

• Creating, managing, and maintaining your won99a Account, including processing your won99a login and authenticating your identity;
• Processing deposits, withdrawals, and other financial transactions;
• Complying with KYC, AML, and other regulatory obligations, including verifying your age (minimum 21 years) and identity;
• Monitoring for fraud, money laundering, prohibited activity, and breaches of the won99a Terms and Conditions;
• Providing responsible gaming tools including deposit limit administration, session monitoring, cooling-off enforcement, and self-exclusion;
• Personalising your Platform experience, including game recommendations and promotion eligibility assessments;
• Communicating with you regarding Account status, security alerts, transaction confirmations, and support responses;
• Sending promotional communications where you have consented to receive them;
• Analysing Platform usage to improve service performance, user experience, and product development.

won99a does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Personal data may be disclosed to the following categories of third parties, strictly as necessary and subject to appropriate data protection safeguards:

• Payment processors — Touch 'n Go eWallet, Boost, Maybank, CIMB, Public Bank, and other approved payment channels, for the purpose of processing deposits and withdrawals;
• Identity verification and KYC providers — third-party service providers that assist won99a in verifying the identity and age of Account holders;
• Fraud prevention and security providers — companies that provide fraud scoring, device fingerprinting, and AML transaction monitoring services;
• Game content suppliers — live casino studios and slot game providers may receive limited session and betting data necessary to deliver their games within the Platform;
• Regulatory and law enforcement authorities — where required by applicable law, court order, or regulatory request, won99a will disclose personal data to the competent authority;
• Professional advisers — legal, audit, and compliance advisers bound by confidentiality obligations where disclosure is necessary to obtain professional advice.

All third-party data processors engaged by won99a are contractually required to process personal data only on won99a's instructions and in accordance with applicable data protection standards.

The won99a Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session after won99a login, and gather analytics data. The categories of cookies used on won99a are as follows:

• Strictly necessary cookies — essential for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional cookies — store your preferences such as language settings and game history to provide a personalised experience on won99a.
• Analytics cookies — collect aggregated, anonymised data on how players use the Platform to inform product improvements. No personally identifiable information is included in analytics reporting.
• Marketing cookies — used only where you have consented to receive personalised promotional content. These track campaign effectiveness and can be disabled at any time through your browser settings.

You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair the functionality of the won99a Platform, including your ability to complete won99a login and maintain an active session.

won99a retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Account and identity data — retained for the duration of your won99a Account relationship and for a minimum of five (5) years following Account closure, to satisfy AML record-keeping requirements;
• Transaction and financial data — retained for a minimum of five (5) years from the date of the relevant transaction, as required by applicable financial and gaming regulations;
• Technical and usage data — retained for up to twenty-four (24) months from the date of collection, unless a longer period is required for fraud investigation or regulatory compliance;
• Communications data — customer support records and complaint files are retained for a minimum of three (3) years from the date of the communication.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to an identified individual.

won99a implements a range of technical and organisational security measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. Key measures include:

• SSL/TLS encryption for all data transmitted between your device and won99a servers;
• Encryption of sensitive data fields (including financial records and identity documents) at rest;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Automated anomaly detection and intrusion prevention systems monitoring the Platform infrastructure;
• Regular security audits and vulnerability assessments conducted by independent security specialists.

Notwithstanding the above, no data transmission over the internet or storage system can be guaranteed to be 100% secure. In the event of a personal data breach that is likely to affect your rights and freedoms, won99a will notify you in accordance with applicable regulatory requirements.

Subject to applicable law and won99a's regulatory obligations, you have the following rights in respect of your personal data held by won99a:

To exercise any of the above rights, please contact the won99a support team as described in Section 15. won99a will respond to all valid data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further sixty (60) days, with notice provided to you.

The won99a Platform is strictly for individuals aged 21 years and above. won99a does not knowingly collect personal data from persons under the age of 21. If won99a becomes aware that personal data has been collected from an individual below the minimum age, such data will be deleted and the associated Account suspended immediately.

If you have reason to believe that a minor has registered or is attempting to use a won99a Account, please notify won99a immediately via the contact details in Section 15 of this Policy.

As won99a operates with the support of internationally located service providers — including game content studios, fraud prevention platforms, and infrastructure providers — personal data may be transferred to and processed in jurisdictions outside Malaysia. Where such transfers occur, won99a ensures that appropriate safeguards are in place, including standard contractual clauses or equivalent mechanisms, to protect your personal data to a standard equivalent to that required under applicable Malaysian data protection law.

won99a reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or Platform operations. Material changes will be communicated to registered Account holders via the email address associated with their won99a Account prior to the effective date of the change, where reasonably practicable.

The "last updated" date at the top of this page reflects the most recent revision. It is your responsibility to review this Policy periodically. Continued use of the won99a Platform following any amendment constitutes acceptance of the revised Policy.

For any questions about this Privacy Policy, to exercise your data subject rights, or to submit a privacy-related complaint, please contact won99a through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week, within the Platform after won99a login

won99a aims to respond to all privacy enquiries within five (5) business days. If you are not satisfied with won99a's response to your complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction.