Winmr Privacy Policy – Malaysian Member Personal Data Protection

Winmr takes the privacy and security of your personal data very seriously. We understand that the trust you place in us to keep your personal information is a great responsibility, and we are committed to protecting that privacy to the highest possible standard.

This Privacy Policy comprehensively describes the types of personal information we collect from winmr members, how we use that information, who we may share it with, and the security measures we take to protect your data.

The winmr platform fully complies with the requirements of Malaysia's Personal Data Protection Act 2010 (PDPA 2010) and internationally accepted data protection principles. We only process your personal data for legitimate and transparent purposes that will be clearly explained in this policy.

To provide our services effectively and comply with applicable legal requirements, winmr collects several categories of personal data from our members. The data collected is divided into the following categories:

We do not collect sensitive personal data such as medical information, religious beliefs or political views unless there is a specific legal requirement to do so.

Winmr collects your personal data through various channels as you interact with our platform. Our primary data collection methods are as follows:

• Account registration: Information you provide during the account registration process at winmr, including name, email and contact details.
• KYC Process: Identity verification documents you upload to complete the Know Your Customer process, enabling withdrawals and full platform access.
• Financial transactions: Information collected when you make deposits or withdrawals, including bank account details and payment methods.
• Platform usage: Data automatically generated when you play, browse, or use features on the winmr platform.
• Customer support interactions: Information you share when contacting our support team via live chat or email.
• Tracking technology: Cookies, web beacons, and similar technologies that automatically collect technical data while you browse the platform.

Winmr uses your personal data solely for legitimate and necessary purposes. We do not process your data for purposes unrelated to providing platform services without obtaining your prior consent. The primary purposes of data use are as follows:

• Account management: Creating, verifying and managing your member account on the winmr platform.
• Transaction processing: Processing deposits, withdrawals and other financial transactions securely and efficiently.
• Legal compliance: Fulfilling our obligations under PDPA 2010, anti-money laundering (AML) laws and other applicable compliance requirements.
• Fraud prevention: Identifying and preventing fraud, money laundering and platform abuse.
• Customer support: Providing accurate and effective technical support and troubleshooting to members.
• Platform improvements: Analyzing usage patterns to improve performance, usability and the overall winmr platform experience.
• Service communications: Sending you important notifications related to your account, transactions and security updates.
• Marketing (with consent): Sending promotional information, bonus offers and related content — only if you have consented to receive them.

Winmr does not sell, rent or share members' personal data to any third parties for commercial marketing purposes. Your personal information is only shared in the following limited situations, and solely for necessary purposes:

• Payment providers: Required financial information is shared with payment providers such as DuitNow, FPX, Touch 'n Go and banks to process your transactions.
• Technology service providers: Hosting, cybersecurity and technical infrastructure providers who help us operate the platform — bound by strict confidentiality agreements.
• Game providers: Minimum technical data required to enable games from third-party providers to function correctly on the winmr platform.
• Law enforcement authorities: When required by Malaysian law, court order, or official investigation by a competent government agency.
• Fraud prevention services: Information required to verify identity and prevent fraud or money laundering activities.

The security of your personal data is winmr's top priority. We have implemented multiple layers of technical and organizational security controls to protect your information from unauthorized access, loss, or accidental disclosure.

Key security measures we use include:

• 256-bit SSL encryption: All communication between your browser and winmr servers is protected with the highest level of SSL/TLS encryption.
• Data encryption at rest: Sensitive data such as financial information and identity documents is stored in encrypted form using modern encryption algorithms.
• Layered access control: Only staff granted specific authorization may access members' personal data, and every access is recorded for audit purposes.
• Continuous security monitoring: Active intrusion detection systems monitor our platform 24/7 to identify and respond to any threats.
• Periodic security assessments: Penetration testing and security audits are conducted regularly by independent security experts.
• Two-factor authentication (2FA): Additional security layers are available for all member accounts to prevent unauthorized access.

Winmr retains your personal data for the period necessary to fulfill the purpose of its collection or as required by applicable law. Our data retention policy is as follows:

• Active account data: Retained for as long as your account remains active on the winmr platform and for the required period following account closure.
• Financial transaction records: Retained for a minimum of seven (7) years in accordance with Malaysian financial and tax legal requirements.
• KYC Documents: Retained for the period specified by applicable anti-money laundering (AML) requirements.
• Platform activity logs: Retained for a reasonable period for security, dispute resolution, and compliance purposes.
• Support communication data: Customer support interaction records are kept for reference and service improvement purposes.

When your personal data is no longer needed and there is no legal obligation to retain it, winmr will securely delete or anonymize that data using appropriate methods.

Under the Malaysian Personal Data Protection Act 2010 and the privacy principles we uphold, you have the following rights regarding the personal data we hold:

• Right to access: You may request a copy of the personal data we hold about you at any time.
• Right to rectification: You may request that we correct any inaccurate or incomplete personal data.
• Right to withdraw consent: You may withdraw consent for data processing at any time, including for marketing communications.
• Right to object: You may object to the processing of your personal data for specific purposes, subject to applicable legal requirements.
• Right to erasure: In certain circumstances, you may request deletion of your personal data, subject to data retention obligations required by law.

To exercise any of these rights, please contact the winmr data privacy team via email at [email protected] or through our platform's live chat channel. We will process your request within the timeframe prescribed by applicable law.

The winmr platform uses cookies and similar tracking technologies to enhance your user experience and collect analytical data that helps us improve the platform. Cookies are small text files stored on your device when you visit our website.

The types of cookies we use include:

• Essential cookies: Required for core platform functions such as login sessions and security. These cookies cannot be disabled.
• Preference cookies: Storing your preferences such as interface language and display settings for a more personalized experience.
• Analytics cookies: Collecting data on how users interact with the platform for improvement purposes — processed in aggregate and without identifying individuals.
• Security cookies: Used to detect and prevent fraudulent activity and unauthorized access to your account.

You can control and manage cookies through your web browser settings. Please note that disabling certain cookies may affect the functionality and user experience of the winmr platform.

Winmr reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or related technological developments.

When we make material changes to this Privacy Policy, we will take the following steps to ensure you are informed:

• Updating the "Last Updated" date at the top of this document.
• Displaying clear notices on the winmr platform about changes made.
• Sending email notifications to all registered members for highly significant changes.

Your continued use of the winmr platform after any amendments to this Privacy Policy take effect is considered your acceptance of the updated privacy terms. If you do not agree with the amendments, please discontinue use of the platform and contact us to settle your account matters.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please do not hesitate to contact us. winmr's data privacy team is ready to assist you.

• Live Chat: The fastest way to get immediate assistance — available 24/7 on the winmr platform.
• Privacy Email: [email protected] — for privacy inquiries requiring written responses or involving documents.
• FAQ Page: Visit FAQs for answers to the most frequently asked privacy questions.