Privacy Policy winnow44

1 Introduction & Our Commitment

Winnow44 understands that your trust depends not only on the quality of the games and services we offer, but also on how we handle the personal information you entrust to us. Privacy is not merely a legal obligation for winnow44 — it is a core value we uphold in every operational and technology decision we make.

This Privacy Policy transparently and honestly explains how we collect, store, process, and protect your personal data when you use the Winnow44 platform. It also outlines your rights as a data subject and how to exercise those rights.

Winnow44 operates as a fully responsible personal data controller over the management of your data. We comply with Malaysia's Personal Data Protection Act 2010 (PDPA) and all applicable related legislation. If you have any doubts or questions after reading this document, our team is available via live chat or our support email.

2 Types of Personal Data We Collect

Winnow44 collects various types of personal data depending on how you interact with our platform. Below is a comprehensive overview of the data categories we collect:

There are also situations where we may collect data you provide voluntarily, such as information shared when contacting customer support, responses to satisfaction surveys, or participation in promotional programmes. Such data is only collected with your knowledge and consent.

3 How We Use Your Personal Data

Every use of your personal data by winnow44 has a legitimate and specific purpose. We never use your data beyond the purposes stated below:

• Account management — Creates, verifies, and manages your account, including the login process and identity verification.
• Transaction processing — Securely and accurately processes deposits, withdrawals, and all financial activity on the platform.
• KYC & AML Compliance — Fulfils identity verification and anti-money laundering requirements as mandated by the relevant authorities.
• Platform security — Detects and prevents fraud, unauthorised access, system abuse, and activities that violate the terms of service.
• Service improvements — Analyses usage patterns to improve user experience, platform performance, and the range of games offered.
• Customer support — Addresses enquiries, resolves complaints, and provides necessary technical assistance.
• Marketing communications — Sends information about promotions, bonuses, and the latest offers — only to members who have given their consent.
• Legal compliance — Fulfils legal obligations and responds to legitimate requests from regulatory authorities.

Winnow44 only processes your data where a valid legal basis exists — whether on the grounds of a contractual agreement, a legal obligation, the platform's legitimate interests, or your explicit consent.

4 Data Sharing & Disclosure

Winnow44 does not sell, rent, or trade your personal data to any third party for commercial purposes. However, there are limited situations where we may need to share your data with certain parties:

• Payment service providers — Financial institutions, banks, and e-wallet providers that process your transactions. They receive only the data necessary to complete the relevant transaction.
• Platform technology providers — Game software companies that provide game titles within the winnow44 platform. Data sharing is kept to a minimum and is subject to strict confidentiality agreements.
• Cloud service providers — Server infrastructure and data storage managed by trusted third-party providers, all bound by comprehensive data protection agreements.
• Legal authorities — Law enforcement agencies, courts, or regulatory bodies when we are required to do so under applicable law.
• Business transfers — In the event of a merger, acquisition, or asset sale, user data may be transferred as part of that transaction, with appropriate notice provided to you.

5 Data Storage & Security Measures

The security of your data is Winnow44's top priority. We implement multiple layers of technical and organisational protection to keep your personal data safe at all times:

• Encryption of data in transit — All communications between your device and winnow44 servers are protected by TLS 1.3 protocol and 256-bit SSL encryption.
• Encryption of data at rest — Sensitive data such as financial information and KYC documents is encrypted at rest within our database.
• Strict access controls — Only staff with a legitimate business need are permitted to access personal data, and all access is logged and audited on a regular basis.
• Regular security testing — Our platform undergoes regular penetration testing and security audits conducted by independent third parties.
• 24/7 Monitoring — Our threat detection system operates around the clock to identify and respond to any security threats promptly.

Data retention period: winnow44 retains your personal data for as long as necessary to fulfil the purpose of collection or as required by law. Generally, active account records are kept for the duration of the account's activity plus 7 years after account closure for legal compliance purposes. Data that is no longer required will be securely deleted or anonymised.

6 Cookies & Tracking Technologies

Winnow44 uses cookies and similar tracking technologies to enhance the user experience, analyse platform traffic, and ensure essential functions run smoothly. The following are the types of cookies we use:

• Essential cookies — Required for core platform functions such as login verification and session security. These cookies cannot be disabled.
• Performance cookies — Collects information on how you use the platform (e.g. pages visited frequently, time spent) to help us improve our services.
• Functional cookies — Remembers your preferences such as language, display settings, and personal choices to deliver a more personalised experience.
• Analytics cookies — Used by trusted third-party analytics tools to understand usage patterns in an aggregated and anonymised manner.

You can manage your cookie preferences through your web browser settings at any time. Please note that disabling certain cookies may affect the functionality or user experience of the Winnow44 platform.

7 Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010, you have the following rights regarding your personal data held by Winnow44:

To exercise any of the above rights, contact our privacy team via live chat or support email. We will respond to your request within 30 calendar days from the date of receiving the request. In complex cases, this period may be extended up to 60 days with appropriate notice.

8 Children's Data Protection

The winnow44 platform is strictly for individuals aged 18 years and above. We do not knowingly collect or process personal data of individuals under the age of 18. All account registrations require age verification during the KYC process.

If we discover that personal data belonging to a child has been collected without our knowledge, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on our platform, please contact us immediately so that appropriate action can be taken.

9 Links to Third-Party Sites

The winnow44 platform may contain links to third-party websites or services in certain contexts. Please note that this Privacy Policy applies solely to the winnow44 platform. winnow44 is not responsible for the privacy practices or content of any third-party websites you may access through links on our platform.

We encourage you to read the privacy policy of every website you visit independently, especially before providing any personal information to them. The presence of third-party links on our platform does not mean we endorse or vouch for their privacy practices.

10 Privacy Policy Amendments

Winnow44 reserves the right to amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or improvements in how we protect your data. Any amendments will be published on this page with the latest update date.

For material amendments — those that significantly affect your rights or how we process your data — we will notify you via in-platform notification or your registered email at least 14 days before the changes take effect. Continued use of the platform after the effective date of any amendment constitutes your acceptance of the updated policy.

11 Contact Us About Privacy

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, we encourage you to reach out to us through the following channels:

• 24/7 Live Chat — The fastest way to get an immediate response from our support team, available around the clock.
• Privacy Email — [email protected] specifically for enquiries related to data protection and your privacy rights.
• FAQ Page — Visit FAQ page for answers to the most frequently asked questions regarding privacy and account security.

Our privacy team is committed to responding to all enquiries within 5 business days. For requests related to the exercise of data rights, we will provide an acknowledgement within 3 business days and fulfil the request within 30 days.