win125 Privacy Policy

1. Introduction

win125 ("win125", "we", "us", "our") operates the online gaming platform accessible at https://win125.app ("Platform"). This Privacy Policy ("Policy") describes how win125 collects, uses, discloses, stores, and protects the personal data of individuals who register accounts, access, or otherwise interact with the Platform ("you", "Player", "User").

win125 is committed to safeguarding your personal data in accordance with applicable international data protection standards and the requirements of its gaming licensing framework. By registering an account on or using the win125 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside the win125 Terms & Conditions. In the event of any inconsistency, the Terms & Conditions shall prevail to the extent necessary to resolve the inconsistency.

2. Personal Data We Collect

win125 collects personal data in the following categories, depending on how you interact with the Platform:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification details (e.g. MyKAD number or passport number) collected during account registration and KYC verification.
• Contact Data: Email address, mobile phone number, and residential address.
• Financial Data: Payment method details (e.g. e-wallet identifiers, bank account details), transaction history, deposit and withdrawal records, and MYR balance information. win125 does not store full card numbers or sensitive authentication data.
• Technical Data: IP address, browser type and version, device identifiers, operating system, referring URLs, session timestamps, and pages visited on the Platform.
• Gameplay Data: Betting history, game participation records, wagering amounts, wins and losses, and bonus usage across all win125 products including slots, live casino, sportsbook, jackpots, and Lucky Bingo.
• Communications Data: Records of your communications with win125 customer support, including chat logs, emails, and support ticket contents.
• Verification Data: Copies of identification documents and proof of address submitted for KYC purposes, and source-of-funds documentation where required by win125's licensing obligations.

3. How We Use Your Personal Data

win125 uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your win125 player account, including processing deposits and withdrawals in MYR and managing your account balance.
• Identity & Age Verification: To verify your identity, confirm that you are at least 21 years of age, and comply with Know Your Customer (KYC) obligations under win125's international gaming licence.
• Service Delivery: To provide you with access to all win125 Platform products, including live casino games, slots, the sportsbook, jackpots, and Lucky Bingo, and to personalise your experience where applicable.
• Legal & Regulatory Compliance: To comply with anti-money laundering (AML) regulations, gaming licensing requirements, responsible gaming obligations, and any applicable law or regulatory direction.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, account takeovers, and other security threats. win125 may use automated systems to flag unusual account behaviour for manual review.
• Customer Support: To respond to your enquiries, process complaints, and resolve disputes efficiently.
• Responsible Gaming: To monitor gameplay patterns that may indicate problem gambling behaviour and to administer self-exclusion, deposit limit, and cooling-off requests in accordance with our responsible gaming framework.
• Marketing Communications: Where you have provided explicit consent, to send you promotional communications about win125 offers, bonuses, and new product features. You may opt out of marketing communications at any time via your account settings.
• Platform Improvement: To analyse aggregated usage data and improve the performance, security, and functionality of the win125 Platform.

4. Legal Basis for Processing

win125 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions, including providing gaming services and processing financial transactions.
• Legal Obligation: Processing required to comply with applicable legal obligations, including KYC requirements, AML regulations, and gaming licensing mandates.
• Legitimate Interests: Processing carried out for win125's legitimate business interests, including fraud prevention, platform security, and internal analytics, where such interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, and informed consent, primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

win125 does not sell your personal data to third parties. win125 may share your personal data with the following categories of recipients in the following circumstances:

• Payment Processors: Financial institutions and payment service providers (including Touch 'n Go eWallet, Boost, DuitNow, Maybank, and CIMB) as necessary to process deposits and withdrawals on your behalf.
• Identity Verification Providers: Third-party KYC and identity verification services engaged by win125 to verify player identity and age as required by our licensing obligations.
• Game Technology Providers: Third-party gaming software providers and live dealer studio operators who supply the games available on the win125 Platform. These providers may receive limited gameplay data necessary for game functionality and fairness certification.
• Regulatory Authorities: Gaming licensing authorities, financial intelligence units, law enforcement agencies, and other regulatory bodies where disclosure is required by applicable law, court order, or regulatory direction.
• Fraud Prevention Services: Third-party fraud detection and AML screening services used to protect the integrity of the Platform and comply with applicable financial crime regulations.
• Professional Advisers: Legal, accounting, and auditing firms engaged by win125 under confidentiality obligations where necessary for business operations.

All third-party data processors engaged by win125 are contractually required to maintain the confidentiality and security of your personal data and to use it only for the purpose for which it was disclosed.

6. Cookies & Tracking Technologies

win125 uses cookies and similar tracking technologies on the Platform to enhance functionality, maintain session state, and analyse Platform usage. The following categories of cookies may be used:

• Strictly Necessary Cookies: Required for the operation of the Platform, including authentication, session management, and security functions. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings and preferred game categories, to personalise your experience on win125.
• Analytical Cookies: Used to collect aggregated, anonymised data about how players navigate and use the Platform. This data helps win125 understand usage patterns and improve the Platform's performance and design.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent you from accessing certain features of the win125 Platform.

7. Data Retention

win125 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the following specific retention periods:

• Active Account Data: Retained for the duration of your account's active status plus a minimum of 5 years following account closure, as required by our international gaming licence and AML compliance obligations.
• KYC & Identity Documents: Retained for a minimum of 5 years following the end of the business relationship, in compliance with applicable AML regulations.
• Transaction Records: Financial transaction records including deposit and withdrawal history are retained for a minimum of 7 years for regulatory compliance purposes.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications, whichever is earlier.
• Support Communications: Retained for up to 3 years following resolution of the relevant support interaction.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with win125's data destruction procedures.

8. Data Security

win125 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the win125 Platform.
• Encryption of sensitive personal data at rest within win125's systems.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular internal security reviews and third-party penetration testing of the Platform's infrastructure.
• Multi-factor authentication requirements for access to internal systems containing personal data.

While win125 takes all reasonable steps to protect your data, no data transmission over the internet or storage system can be guaranteed to be 100% secure. In the event of a data breach that is likely to result in risk to your rights and freedoms, win125 will notify you and the relevant regulatory authority in accordance with applicable legal requirements.

9. Your Data Protection Rights

Subject to applicable law and win125's regulatory obligations, you have the following rights with respect to your personal data:

• Right of Access: You may request a copy of the personal data win125 holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: In certain circumstances, you may request deletion of your personal data. Note that this right may be limited where win125 is required to retain data under applicable legal or regulatory obligations.
• Right to Restrict Processing: You may request that win125 restrict the processing of your personal data in certain circumstances.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you may request a copy of your personal data in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please submit a written request to [email protected]. win125 will respond to valid requests within 30 days of receipt. We may require proof of identity before processing rights requests.

10. Children's Privacy

The win125 Platform is strictly intended for adults aged 21 years and above. win125 does not knowingly collect personal data from individuals under the age of 21. If win125 becomes aware that personal data has been submitted by a person under 21, the relevant account will be immediately closed, all associated data will be deleted, and the matter may be referred to the relevant licensing authority.

If you are a parent or guardian and believe that a person under 21 in your care has registered an account on win125, please contact us immediately at [email protected].

11. International Data Transfers

win125 may transfer your personal data to third-party processors and service providers located outside Malaysia. Where such transfers occur, win125 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that which applies within win125's licensing jurisdiction. These safeguards may include contractual data protection clauses with the relevant recipients.

By using the win125 Platform, you consent to the transfer of your personal data to processors in jurisdictions outside Malaysia where necessary for the provision of the Platform's services.

12. Changes to This Privacy Policy

win125 reserves the right to amend this Privacy Policy at any time. Where amendments are material, win125 will notify registered players via email to their registered address or through an in-platform notification prior to the changes taking effect. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Continued use of the win125 Platform following notification of an amended Policy constitutes your acceptance of the revised terms.

13. Contact & Data Controller Information

win125 is the data controller responsible for your personal data. For any queries, requests, or complaints relating to this Privacy Policy or win125's data processing practices, please contact:

• Email: [email protected]
• Subject Line for Data Requests: "Privacy Request – [Your Registered Email]"
• Response Time: Within 30 days for data rights requests; within 24 hours for general privacy queries

If you are not satisfied with win125's response to a privacy complaint, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.