WinClub Privacy Policy – Malaysia Member Data Protection

WinClub collects various types of personal information from members to enable the platform to operate safely and efficiently. We only collect data that is strictly necessary and do not gather any information beyond what is needed for the stated purposes.

The types of personal data WinClub collects are as follows:

• Registration Information: Full legal name as per identity card, Malaysian mobile number, email address, and date of birth during the WinClub account registration process.
• Identity Information (KYC): A copy of MyKad or a valid identity document when required for identity verification prior to processing certain withdrawals.
• Financial Information: Payment method details used, including e-wallet account numbers (Touch 'n Go eWallet, DuitNow, GrabPay, Boost, ShopeePay) or FPX information for Maybank2u and CIMB Clicks, for the purpose of processing deposits and withdrawals.
• Transaction Records: Complete history of deposits, withdrawals, bets, winnings, and losses on the WinClub platform for each member account.
• Technical Data: IP address, browser type, device operating system, access logs, and platform usage data collected automatically when you use WinClub.
• Communication Data: Records of conversations with the WinClub support team via live chat, email, or other communication channels, retained for quality assurance and dispute resolution purposes.

Some of this data is provided directly by you to WinClub — for example, when completing the registration form or contacting customer support. Technical data is collected automatically through standard tracking technologies such as cookies and server logs while you use the WinClub platform.

WinClub uses the personal data it collects solely for legitimate purposes directly related to providing online entertainment platform services to members in Malaysia. The following are the primary purposes for which WinClub uses your data:

WinClub will not use your personal data for any purpose not stated above without first obtaining your explicit consent. If you no longer wish to receive promotional communications from WinClub, you may withdraw your consent at any time through your account settings or by contacting our support team.

From time to time, WinClub may use anonymised and aggregated data (i.e. data that cannot be linked to any individual) for business analysis, industry reporting, or general research into Malaysian gaming trends. Such data is not considered personal data and is not subject to this privacy policy.

WinClub takes its responsibility to protect members' personal data from unauthorised access seriously. As a non-negotiable general rule, WinClub does not sell, rent, or share member personal data with third parties for marketing purposes under any circumstances.

However, in the course of normal platform operations, WinClub may share limited personal data with the following categories of third parties, and strictly for the purposes stated:

• Payment Service Providers: Malaysian e-wallet platforms such as Touch 'n Go eWallet, DuitNow, GrabPay, Boost, and ShopeePay, as well as banks via FPX (Maybank2u, CIMB Clicks), receive the transaction data necessary to process your deposits and withdrawals. These providers maintain their own privacy and security policies, which must comply with Malaysian financial industry standards.
• Technical Service Providers: Companies providing the server infrastructure, cloud services, platform analytics, and cybersecurity tools used by WinClub. These providers are bound by strict data confidentiality agreements and are only permitted to use data for the purpose of delivering services to WinClub.
• Game Providers: Game providers supplying slots, live casino, and virtual sports to the WinClub platform may receive session data required to run games correctly. This data is typically limited to session identifiers and wager amounts – not members' full personal information.
• Legal Authorities: WinClub will disclose members' personal data to the police, regulatory bodies or courts when required by Malaysian law or a valid court order. In such situations, WinClub will endeavour to notify the member concerned prior to disclosure, unless prohibited by law.

In the event of a business merger, acquisition or sale of WinClub's assets to another entity, members' personal data may form part of the transferred assets. In such situations, WinClub will notify members via email or an in-platform notification before the transfer takes place, and you have the right to request deletion of your personal data prior to the transfer being carried out.

WinClub continuously invests in industry-grade security infrastructure to ensure members' personal data is protected at all times. Our approach to data security is multi-layered and comprehensive – going well beyond mere minimum legal compliance.

The key technical and organisational measures WinClub uses to protect member data are as follows:

• Data Encryption in Transit: All communications between your device and the WinClub platform are protected with 256-bit TLS/SSL encryption. This means that data transmitted — including passwords, payment details, and personal information — is fully encrypted and cannot be read by any party that intercepts the connection.
• Data Encryption at Rest: Sensitive member data stored in WinClub's databases — including passwords, identification numbers, and financial details — is stored in encrypted format using industry-recognised encryption algorithms.
• Strict Access Controls: Access to member personal data within WinClub's systems is restricted using the principle of least privilege. Only staff with a legitimate operational need who have passed background checks are permitted to access sensitive member data.
• Two-Factor Authentication (2FA): WinClub provides a two-factor authentication option for account log-ins to add an extra layer of protection. We encourage all members to enable this security feature.
• Continuous Security Monitoring: WinClub's security monitoring system operates 24 hours a day to detect any unusual activity, intrusion attempts, or unauthorised access to member data.
• Regular Security Testing: WinClub conducts regular penetration testing and security audits by independent security experts to identify and address any vulnerabilities in our systems.

You also play an important role in keeping your WinClub account secure. Make sure you use a strong, unique password for your WinClub account, never share your password with anyone, and log out after every session — especially when using a shared device.

WinClub uses cookies and similar tracking technologies to enhance the user experience, maintain platform security and understand how members use our services. Cookies are small text files stored on your device when you visit the WinClub platform.

The following are the types of cookies used by WinClub:

• Essential Cookies (Required): These cookies are essential for the basic functionality of the WinClub platform – including maintaining your login session, remembering wallet details, and ensuring transaction security. Without them, the WinClub platform cannot function properly and they cannot be disabled.
• Analytics Cookies: Used to gather information on how members use the WinClub platform – pages visited, time spent, navigation patterns, and buttons clicked. This data is used solely for platform improvements and does not contain any personally identifiable information.
• Security Cookies: Helps WinClub detect suspicious activity, prevent fraud and protect member accounts from unauthorised access. These cookies form part of WinClub's layered security system.
• Preference Cookies: Remembers your preferences on the WinClub platform — such as display language and game preferences — to deliver a more personalised experience on your next visit.

You can manage and control cookies through your web browser settings. Most modern browsers allow you to view, delete or block cookies from any website. Please note, however, that disabling essential cookies may significantly affect the functionality of the WinClub platform and you may be unable to log in or use certain features.

As a WinClub member whose personal data is processed by us, you hold certain rights under Malaysia's Personal Data Protection Act 2010 (PDPA). WinClub fully respects and facilitates the exercise of these rights. Below are your rights and how to exercise them:

WinClub retains members' personal data only for as long as necessary to fulfil the purpose for which it was collected or to meet applicable legal requirements. Our data retention policy is based on the principle of minimum retention — data will not be kept longer than necessary.

The following are the general data retention period guidelines applied by WinClub:

• Active Account Information: Personal data of members with an active WinClub account is retained for the duration of active membership and for a period following account closure, for the purpose of resolving any disputes or claims that may arise.
• Financial Transaction Records: Complete records of deposits, withdrawals and betting history are retained for a minimum period of 7 years from the date of the transaction. This is an AML (anti-money laundering) compliance requirement and a Malaysian tax law obligation that cannot be reduced.
• KYC Documents: Copies of identity verification documents (MyKad and related documents) are retained for a minimum period 5 years after the verification date or after account closure, whichever is later.
• Support Communication Logs: Records of live chat and email conversations with WinClub customer support are retained for 2 years for quality assurance purposes and as a reference in the event of a dispute.
• Technical Data & Access Logs: Technical data such as IP logs and platform access logs are retained for 90 days before being automatically deleted, unless required for an ongoing security investigation.

Once the relevant retention period has ended, WinClub will securely delete or anonymise the personal data in question. The deletion process uses methods that ensure the data cannot be recovered or re-identified after deletion.

If you request the closure of your WinClub account, your data will not be deleted immediately — it will be retained for the minimum retention periods specified above for legal compliance purposes. This is a non-negotiable requirement even upon member request, as it constitutes WinClub's legal obligation as a recognised financial platform.

This WinClub Privacy Policy reflects our genuine commitment to protecting the personal data of every member in Malaysia. We recognise that privacy is not merely a legal obligation — it is a fundamental right of every individual, and one that WinClub takes seriously across every aspect of our platform's operations.

If you have any questions, concerns, or complaints regarding this Privacy Policy, how WinClub handles your data, or wish to exercise any of your privacy rights, please contact us through the following channels:

• Privacy Email: support@winclub-bangla.com – use the subject line "Data Privacy Inquiry" for a faster and more directed response.
• Live Chat: Accessible directly within the WinClub platform – for general privacy enquiries, our support team is available 24 hours a day.
• Response Time: General privacy inquiries will be responded to within 3 to 5 business days. Formal privacy rights requests will be processed within 14 business days as required under Malaysia's PDPA.

WinClub also encourages members to report any concerns about data security or potential privacy breaches they may notice. All such reports will be taken seriously and investigated promptly, with remedial action carried out without delay. Members who report valid security vulnerabilities will be recognised and appreciated by WinClub.