Privacy Policy of winmy19

1Introduction

This Privacy Policy ("Policy") is published by winmy19 ("the Company", "We", "Us", or "Our"), the operator of the online gaming and sports betting platform accessible at winmy19.cam ("the Platform"). This Policy applies to all Users ("You", "Your") who access, register on, or otherwise interact with the Platform.

winmy19 is committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection laws and regulations. This Policy explains what personal data we collect, the purposes for which it is used, with whom it may be shared, how long it is retained, and what rights you have in relation to it.

By using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree to the data practices described here, please do not use the Platform. This Policy should be read in conjunction with our Terms & Conditions.

2Definitions

For the purposes of this Privacy Policy, the following terms shall carry the meanings assigned below:

• "Personal Data" means any information that relates to an identified or identifiable natural person.
• "Data Controller" means winmy19, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" means any third party that processes personal data on behalf of winmy19 under a written agreement.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, and deletion.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data.
• "KYC" means Know Your Customer — the identity and eligibility verification process required for account registration and financial transactions.
• "Cookies" means small text files stored on your device by the Platform's web server to enable functionality and analytics.
• "User" / "You" means any individual who accesses or uses the winmy19 Platform.

3Data We Collect

winmy19 collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Email address and mobile phone number
• Residential address (including city — e.g., Kuala Lumpur, Penang, Johor Bahru, Shah Alam, Petaling Jaya)
• Government-issued identification document number (e.g., Malaysian NRIC, Passport)
• Username and encrypted password

3.2 Financial & Transaction Data

• Bank account details (name, account number) used for deposits and withdrawals
• E-wallet identifiers (e.g., registered mobile number for Touch 'n Go eWallet or Boost)
• Deposit amounts, withdrawal requests, and transaction histories in MYR
• Bonus and promotional credit histories

3.3 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps, pages visited, and features used
• Game activity logs, betting histories, and session durations

3.4 Communications Data

• Records of support interactions (live chat transcripts, email correspondence)
• Survey responses and feedback submitted through the Platform
• Marketing communication preferences

3.5 KYC Verification Documents

• Scanned or photographed copies of identification documents submitted for verification purposes
• Proof of address documentation
• Source of funds documentation where required by our compliance obligations

4How We Collect Your Data

winmy19 collects personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to a survey.
• Automatically — through cookies, log files, and analytics tools when you browse or use the Platform.
• From third-party payment providers — transaction confirmation data is received from our integrated payment partners (e.g., DuitNow, FPX, Maybank) to verify and reconcile your transactions.
• From identity verification services — where we use third-party KYC or age-verification providers to assist with regulatory compliance.
• From fraud prevention services — to identify and prevent fraudulent activity on the Platform.

5Purposes of Data Processing

winmy19 processes your personal data for the following specific purposes:

6Legal Basis for Processing

winmy19 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws, including KYC, AML, and responsible gambling regulations.
• Legitimate interests: Processing carried out for fraud prevention, platform security, and internal analytics, where these interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, where you have provided explicit opt-in consent. You may withdraw this consent at any time by updating your account communication preferences or contacting our support team.

7Data Sharing & Third Parties

winmy19 does not sell or rent your personal data to any third party. We may share your data with the following categories of recipients only to the extent necessary and under appropriate data protection agreements:

• Payment processors and banking partners — including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, and Hong Leong Bank — for the purpose of processing your financial transactions.
• Identity verification and KYC service providers — to confirm your identity and age in compliance with regulatory requirements.
• Fraud prevention and AML screening services — to detect and prevent illicit financial activity.
• IT infrastructure and cloud hosting providers — who host Platform data under strict security and confidentiality obligations.
• Regulatory and law enforcement authorities — where disclosure is required by applicable law, court order, or regulatory directive.
• Game content providers — limited technical identifiers may be shared with licensed game studios to deliver their content and maintain fair-play audit trails.

All third-party data processors engaged by winmy19 are contractually required to implement appropriate technical and organisational security measures and to process personal data only for the specified purpose and duration.

8Data Retention Periods

winmy19 retains personal data only for the period necessary to fulfil the purpose for which it was collected, subject to any minimum retention periods imposed by applicable law. The following general retention schedule applies:

• Active account data: Retained for the duration of your account and for a period of 5 years following account closure, to meet AML and regulatory audit requirements.
• KYC documents: Retained for a minimum of 5 years from the date of verification or account closure, in accordance with applicable financial regulations.
• Transaction records: Retained for 7 years from the date of the transaction for financial and regulatory compliance purposes.
• Support and communications records: Retained for 2 years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Technical and usage logs: Retained for 12 months from the date of creation, after which they are anonymised or deleted.
• Marketing consent records: Retained until you withdraw consent, plus an additional period as required to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised.

9Cookies & Tracking Technologies

winmy19 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device by your web browser. They do not contain executable code and cannot access other files on your device.

We use the following categories of cookies:

You may adjust your browser settings to refuse cookies or to be notified when cookies are being set. Please note that disabling essential cookies may impair your ability to use certain features of the Platform, including account login and transaction processing.

10Data Security

winmy19 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit TLS encryption for all data transmitted between your device and our servers.
• Encryption at rest for sensitive data categories, including KYC documents and financial records.
• Role-based access controls ensuring that staff can only access personal data required for their specific function.
• Regular security audits and penetration testing conducted by independent third-party security specialists.
• Multi-factor authentication requirements for all administrative access to systems containing personal data.
• Incident response procedures to identify, contain, and notify affected Users of any data breaches in a timely manner.

While winmy19 takes all reasonable precautions, no data transmission over the internet or electronic storage system is entirely immune to risk. You are responsible for maintaining the security of your own account credentials and for notifying us immediately if you suspect unauthorised access to your account.

11Minors & Age Restrictions

The winmy19 Platform is strictly intended for use by persons aged 21 years and above. We do not knowingly collect or process personal data from individuals under the age of 21. Age verification is a mandatory component of our KYC process, and accounts where age verification cannot be satisfactorily completed will not be activated.

If winmy19 becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the relevant account and take appropriate steps to delete the data in question. If you believe that a minor's data has been submitted to us, please contact our support team without delay.

12Your Data Rights

Subject to applicable law, you have the following rights in relation to personal data held by winmy19:

• Right of Access: You may request a copy of the personal data we hold about you, along with information on how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data. Minor corrections (such as updating your contact number) can be made directly through your account settings.
• Right to Erasure: You may request deletion of personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where processing is unlawful. Note that certain data may be subject to mandatory retention periods under applicable law.
• Right to Restriction of Processing: You may request that we limit processing of your data while a dispute or correction request is under review.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request that we provide your data in a structured, commonly used, and machine-readable format.
• Right to Object: You may object to processing based on our legitimate interests or for direct marketing purposes. Objections to direct marketing will be actioned immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred prior to withdrawal.

To exercise any of these rights, please contact our Data Privacy team via email at [email protected] (plain text — not a clickable link). We will acknowledge your request within 5 business days and aim to fulfil it within 30 calendar days. Complex requests may require an extension of up to a further 60 days, of which you will be notified.

13International Data Transfers

Where personal data is transferred to data processors or infrastructure providers located outside Malaysia, winmy19 ensures that appropriate safeguards are in place to maintain the equivalent level of data protection required under this Policy.

Such safeguards may include standard contractual clauses, binding corporate rules, or adherence to internationally recognised data protection frameworks. winmy19 does not transfer personal data to jurisdictions that do not provide an adequate level of protection without ensuring contractual protections are in place.

14Changes to This Privacy Policy

winmy19 reserves the right to update or revise this Privacy Policy at any time. When material changes are made, we will notify registered Users via a prominent in-Platform notification and, where appropriate, by email to the registered address on file.

The effective date at the top of this Policy will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to remain informed of how your data is protected. Your continued use of the Platform following the publication of any revision constitutes your acceptance of the updated Policy.

15Contact Us

For any questions, concerns, or requests related to this Privacy Policy or your personal data, please contact our Data Privacy team through the following channels:

• Live Chat: Available on the Platform 24 hours a day, 7 days a week. Our agents respond in English.
• Email: [email protected] — please include "Privacy Request" in the subject line for faster routing.
• Office Location: Kuala Lumpur, Malaysia.

All privacy-related correspondence is handled confidentially. We aim to acknowledge receipt of all formal data subject requests within five (5) business days. Players located in Malaysia may also direct complaints to the relevant national data protection authority if they believe their data protection rights have been violated.