Winway Privacy Policy – Our Commitment to Your Data Security

1Privacy Policy Introduction and Scope

This Privacy Policy is issued by Winway ("we", "us") and applies to all users and members who access our website, mobile app, and any digital services provided under the Winway brand. By registering as a member or simply browsing our platform, you provide informed consent to the data collection and processing practices described in this document.

This Privacy Policy is prepared in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and relevant international data protection standards. We continually strive to ensure that every aspect of our data processing meets applicable legal requirements and adheres to industry best practices.

The scope of this policy covers all personal data collected directly from you, data generated through your use of our platform, and data received from legitimate third parties in the context of providing our services to you.

2Types of Personal Data We Collect

Winway collects various types of personal data depending on how you interact with our platform. In general, the data we collect falls into three main categories:

Data Categories	Data Examples	Collection Method
Identity Data	Full name, date of birth, identity card number, KYC selfie photo	Account registration, KYC process
Contact Data	Email address, phone number, residential address	Registration form, profile updates
Financial Data	Bank account number, bank name, deposit and withdrawal records	Payment processing, transaction verification
Usage Data	Game history, betting records, login timestamps, game preferences	Platform activity is automatically
Technical Data	IP address, device type, operating system, app version, cookie data	Our system automatically

Winway does not collect personal data considered sensitive, such as health information, religious beliefs, or political views, unless expressly required by law or for specific compliance purposes related to responsible gaming.

3Purpose of Personal Data Use

Winway only uses your personal data for legitimate and stated purposes. The following are the primary purposes for which your data is processed:

• Account Management: To create, verify, and manage your member account, including the required identity verification (KYC) process.
• Service Provision: To process deposits, withdrawals, and other financial transactions securely and efficiently through your chosen payment method.
• Platform Security: To detect and prevent fraud, money laundering, unauthorised access, and activities that violate our terms of service.
• Customer Support: To handle your enquiries, complaints, and support requests efficiently via 24/7 Live Chat or email.
• Legal Compliance: To fulfil applicable legal and regulatory obligations, including reporting to authorities as required by law.
• Service Improvement: To analyse usage patterns for the purpose of improving the interface, platform performance, and overall member experience.
• Marketing Communications: To send relevant promotional offers, bonuses, and updates — only to members who have given their consent to receive them.

4Information Sharing with Third Parties

Winway does not sell or disclose your personal information to third parties for their own commercial purposes. However, in the course of delivering our services, we may share your data with the following parties within limited and controlled circumstances:

• Payment Processors: Payment service providers such as FPX, DuitNow, Touch 'n Go eWallet, Boost, and GrabPay required to process your financial transactions.
• Technology Service Providers: Hosting companies, cloud infrastructure, and analytics services that assist us in the technical operation of the platform — subject to strict confidentiality agreements.
• KYC Service Providers: A third-party identity verification platform that helps us verify member identities for legal compliance purposes.
• Regulatory Authority: Regulatory bodies, law enforcement agencies, or courts when we are legally required to do so.
• Third-Party Game Providers: Casino and sports game providers that supply game content on the winway platform, within the scope required for game operations.

All third parties we engage are required to comply with data protection standards equivalent to our own. We are not responsible for the privacy practices of third parties that fall outside our control and contractual relationship.

5Cookies and Tracking Technologies

Winway uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

You can control or disable certain cookies through your web browser settings. Please note that disabling certain cookies may affect the functionality of the Winway platform. For more information on managing cookies, please refer to your web browser's help documentation.

6Data Security Measures

Winway implements a range of robust technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction.

• 256-bit SSL Encryption for all data in transit between your device and our servers.
• Encryption of data at rest for sensitive information stored in our databases.
• Two-Factor Authentication (2FA) available for all member accounts as an additional layer of security.
• Real-time security monitoring uses a sophisticated threat detection system.
• Role-based access control that ensures only authorised personnel can access sensitive data.
• Regular security audits by independent third parties to identify and address system vulnerabilities.
• Staff security training that is comprehensive and conducted regularly for all employees handling member data.

While we take all reasonable measures, no security system can guarantee absolute protection. You also play an important role in keeping your account secure by using a strong password, enabling 2FA, and never sharing your login credentials with anyone.

7Your Rights Regarding Personal Data

As a Winway member, you have certain rights regarding your personal data under applicable data protection laws. Winway is committed to facilitating the exercise of these rights in a prompt and hassle-free manner.

To submit any request relating to your data rights, please contact our support team via 24/7 Live Chat or send an email to [email protected]. We will process your request within 14 working days. For complex cases or high volumes of requests, this period may be extended up to 30 days with prior notice to you.

8Data Retention Period

Winway retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable laws and regulations. The following are general guidelines on data retention periods:

• Active Account Data: Retained for the duration your account remains active and open.
• KYC and Identity Verification Data: Retained for a minimum of 5 years after account closure in accordance with anti-money laundering legal requirements.
• Financial Transaction Records: Retained for 7 years for accounting, tax, and regulatory compliance purposes.
• Support Communication Logs: Retained for 3 years for reference and resolution of any disputes that may arise.
• Usage and Analytics Data: Retained for 2 years before being anonymised or deleted.
• Inactive Account: Data is updated to minimum retention after 12 months of inactivity, prior to formal account closure.

When data is no longer needed and there is no legal obligation to retain it, Winway will delete or anonymise that data in a secure and irreversible manner.

9Privacy of Children and Minors

The Winway platform is exclusively for individuals aged 18 and above. Winway does not intentionally collect, store, or process any personal data from individuals under the age of 18.

We apply age verification procedures during registration and the KYC process to ensure that only eligible adults can fully access our platform. Should we discover that personal data of a minor has been collected inadvertently, we will immediately take steps to delete that data and close the relevant account.

10Amendments to This Privacy Policy

Winway reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, the services we offer, or applicable legal requirements. Any significant amendments will be communicated to you via:

• Email notice sent to the email address registered with your account.
• Notices prominently displayed on the winway platform home page.
• In-app notification pop-ups in the Winway mobile app upon next login.

It is your responsibility to review this Privacy Policy periodically. Continued use of the platform after any amendments take effect will be considered acceptance of the latest version of the Privacy Policy. The most recent effective date will always be displayed at the top of this document.

The version history of this Privacy Policy is available upon request. The current version is Version 2.4, effective 1 January 2026.

11Contact Us for Privacy Matters

If you have any questions, concerns, or complaints regarding this Privacy Policy or how Winway handles your personal data, please do not hesitate to contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the chat icon on the Winway platform — average response time under 3 minutes.
• Email: [email protected] — we will respond within 1 to 2 business days.

We take all feedback seriously and are committed to resolving every privacy-related enquiry in a professional, transparent, and timely manner.