AsiaWin Privacy Policy – Your Personal Data Protection

1 Introduction & Scope of This Policy

AsiaWin is an online betting platform operating and serving users in Malaysia. We understand that your trust is our most valuable asset, and protecting your personal data is an absolute priority in every operational decision we make.

This Privacy Policy describes in detail:

• The types of personal information we collect from you.
• Our purposes and legal basis for processing that information.
• Who may receive your information and under what circumstances.
• How long we retain your data and the security measures we have in place.
• The rights you hold and how to exercise them.

This Policy applies to all registered users, website visitors, and anyone who interacts with the AsiaWin platform through any of our official channels.

2 Personal Data We Collect

We only collect data that is strictly necessary to provide you with a safe, seamless, and personalised service. Below are the categories of data we collect:

3 How We Use Your Data

The personal data we collect is used solely for the following purposes. We do not use your data for any other purpose without first obtaining your additional consent:

• Account Management: Creating, verifying and maintaining your account so you can access the platform smoothly and securely.
• Transaction Processing: Processing your deposits, withdrawals and any financial transactions made on the platform accurately and securely.
• Identity Verification (KYC): Meeting legal requirements related to identity verification and anti-money laundering in accordance with applicable regulations.
• Customer Support: Responding to enquiries, resolving complaints and providing the technical support you need.
• Platform Security: Detecting and preventing fraud, account abuse and suspicious activity to protect all users.
• Service Improvement: Analysing aggregated usage patterns to improve overall platform performance, usability and quality.
• Responsible Gaming: Monitoring betting patterns to identify signs of problem gambling and providing appropriate assistance or limits as needed.
• Marketing Communications: Sending offers, promotions and updates — only to users who have given explicit consent to receive them.

4 Legal Basis for Data Processing

Every personal data processing activity we carry out has a valid legal basis under Malaysia's Personal Data Protection Act 2010 (PDPA). The primary bases we rely on are:

• Contract Fulfilment: Processing required to provide you with asiawin platform services in accordance with the Terms and Conditions you agreed to.
• Legal Obligation: Processing required to comply with legal obligations such as KYC, AML (anti-money laundering) and tax reporting.
• Legitimate Interest: Processing for platform security, fraud prevention and usage analytics purposes necessary for responsible business operations.
• Consent: Processing for direct marketing and promotional communications — where you may withdraw your consent at any time.

5 Data Sharing & Disclosure

AsiaWin does not sell or disclose your personal data to third parties for their own commercial purposes. However, we may share your data in the following limited circumstances:

• Payment Service Providers: Financial information required to process your deposits and withdrawals is shared with trusted and licensed payment providers.
• Technology Service Providers: Cloud infrastructure providers, email services and customer support partners that help us operate the platform — all bound by strict data protection agreements.
• Regulatory Body: Information required by regulatory authorities, law enforcement agencies or courts as mandated by law.
• Fraud Prevention: Information required by fraud prevention service providers to protect the platform and all its users.

All third parties that receive your personal data are required to comply with data protection standards equal to or exceeding our own, and are prohibited from using that data for any purpose other than those specified.

6 Data Retention Period

We only retain your personal data for as long as necessary to fulfil the original purpose for which it was collected, or as required by applicable law.

• Active Account Data: Retained for the duration that your account remains active on the AsiaWin platform.
• KYC & Identity Data: Retained for at least 7 years after account closure in accordance with Malaysia's AML legal requirements.
• Financial Transaction Records: Retained for 7 years in accordance with accounting and tax legal requirements.
• Communication Logs: Support chat and email records are retained for 2 years for quality control and dispute resolution purposes.
• Technical Data: Server logs and technical data are retained for 12 months for security and troubleshooting purposes.

Upon expiry of the retention period, your data will be securely deleted or permanently anonymised so that it can no longer be associated with you.

7 Data Security Measures

We continuously invest in the latest security infrastructure to ensure your personal data is protected at all times. Our technical and organisational measures include:

• 256-bit SSL/TLS encryption for all data in transit.
• Encryption at rest for sensitive information stored in our databases.
• Role-based access control (RBAC) — each staff member can only access the data required for their specific role.
• 24/7 security monitoring with an active intrusion detection system (IDS).
• Regular penetration testing conducted by independent third-party security experts.
• Regular encrypted data backups stored at geographically separate locations.
• Mandatory cybersecurity training for all staff who handle user data.

8 Cookies & Tracking Technologies

The asiawin website uses cookies and similar tracking technologies to enhance your experience and help us understand how our platform is used. Below are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login session management and security. Cannot be disabled as the platform will not function properly without them.
• Performance Cookies: Collecting anonymous information on how visitors use our website to help us improve performance and user experience.
• Functional Cookies: Saving your preferences such as language and display settings so you do not need to reconfigure them on every visit.
• Marketing Cookies: Used only with your consent to personalise ads and offers relevant to your interests.

You can manage or disable cookies through your web browser settings at any time. Please note that disabling certain cookies may affect the functionality of some parts of the platform.

9 Cross-Border Data Transfers

In certain circumstances, your personal data may be transferred to or processed in countries other than Malaysia, particularly when we use international cloud infrastructure service providers.

When cross-border data transfers occur, we ensure adequate protection through:

• Standard data processing agreements binding service providers to equivalent data protection standards.
• Selecting providers that operate in regions with recognised data protection standards.
• Additional technical measures such as end-to-end encryption for highly sensitive data.

10 Child Protection

The asiawin platform is strictly for users aged 18 and above. We do not knowingly collect or process personal data from individuals under 18 years of age.

If we detect or are notified that a person under 18 years of age has registered or used our platform, we will immediately close the account, delete all associated personal data, and take appropriate action.

If you believe that someone under the age of 18 has used our platform, please notify our customer support team immediately.

11 How to Exercise Your Data Protection Rights

To exercise any of the data protection rights described in this document, you may:

• Log in to your asiawin account and navigate to the "Privacy Settings" section in your profile for general requests.
• Contact our customer support team via live chat, available 24 hours a day, 7 days a week.
• Submit a written request to our Data Privacy Officer via the platform's official email.

We will process your request within 30 calendar days of receipt. In complex cases, this period may be extended with prior notice to you. We do not charge any fees for processing reasonable data rights requests.

12 Changes to This Privacy Policy

AsiaWin 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:

• In-app or on-site notifications on asiawin.
• Emailed to your registered email address at least 14 days before the changes take effect.
• Update the "Last Updated" date at the top of this document.

Continued use of the asiawin platform after any changes to the Privacy Policy take effect constitutes your acceptance of the updated terms. If you do not agree with the changes, you have the right to close your account and discontinue use of the platform.

Previous versions of this Privacy Policy are available upon request from our customer support team for reference purposes.