Privacy Policy — Winace99

This Privacy Policy ("Policy") describes how Winace99 ("we", "us", "the Operator", "Winace99") collects, uses, stores, and shares personal data in connection with your use of the Winace99 platform accessible at winace99.cam, including all associated gaming services, account management features, payment processing functions, and customer support channels (collectively, the "Services").

Winace99 is committed to handling personal data responsibly, transparently, and in compliance with applicable data protection legislation. By creating an Account, accessing the platform, or using any of the Services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference into the overall agreement between you and Winace99.

For the purposes of this Privacy Policy, the following definitions shall apply:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly. This includes name, identification number, contact details, financial information, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, deletion, or any combination thereof.
• "Data Controller" means Winace99, being 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 Winace99 under a written data processing agreement, including payment processors, KYC verification providers, and analytics services.
• "Consent" means any freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data, which may be given by ticking a checkbox, submitting a registration form, or other clear affirmative action.
• "Account" means the personal registered account held by a User on the Winace99 platform.
• "KYC" means Know Your Customer — the identity and age verification process conducted by Winace99 to comply with applicable legal obligations.

Winace99 collects the following categories of personal data in the course of providing the Services. Collection is limited to what is necessary for the specific purposes described in this Policy:

Winace99 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data (beyond responsible gambling information provided voluntarily), or biometric data, except where required by applicable KYC regulations.

Winace99 collects personal data through the following means:

• Direct Submission: Information you provide when registering an Account, completing KYC verification, submitting a deposit or withdrawal request, contacting our support team, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the platform, including cookies, session tracking, IP logging, and device fingerprinting. See Section 9 for further details on cookies.
• Third-Party Sources: Identity verification and fraud screening information provided by our KYC verification partners and payment processors. Winace99 only receives data from third parties where you have given appropriate consent or where we have a legitimate legal basis for doing so.
• Publicly Available Sources: In limited circumstances, Winace99 may verify information against publicly available registers or databases for the purposes of fraud prevention or regulatory compliance.

Winace99 processes personal data only where there is a lawful basis to do so. The following table sets out our primary processing purposes and the corresponding legal basis for each:

• Account Registration & Management: Processing is necessary for the performance of the contract between you and Winace99, including maintaining your Account, processing transactions, and delivering the Services.
• Identity & Age Verification (KYC): Processing is required to comply with legal obligations applicable to online gaming operators, including anti-money laundering regulations and age restriction requirements (21+ minimum age).
• Fraud Prevention & Security: Processing is based on Winace99's legitimate interest in preventing fraud, protecting the integrity of the platform, and safeguarding the security of player accounts and funds.
• Financial Transactions: Processing is necessary for the performance of the contract and compliance with financial record-keeping obligations.
• Customer Support: Processing is based on the performance of the contract and Winace99's legitimate interest in delivering effective player support.
• Marketing Communications: Processing is based on your consent, which may be withdrawn at any time. Winace99 will only send promotional emails, SMS, or push notifications where you have opted in to receive such communications.
• Legal Compliance: Processing may be necessary to comply with applicable laws, regulations, court orders, or binding directions from regulatory authorities.

Winace99 does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial purposes. We share personal data with third parties only in the following circumstances, and only to the extent necessary for the specified purpose:

• Payment Processors: Your financial data is shared with verified payment processing partners — including providers supporting Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and cryptocurrency networks — solely for the purpose of executing your deposit and withdrawal instructions. These processors are contractually bound to handle your data securely and in accordance with applicable standards.
• KYC & Identity Verification Providers: Identity and age verification data may be shared with specialist KYC service providers for the purpose of confirming your eligibility to use the Services. These providers operate under strict data processing agreements with Winace99.
• Fraud Prevention Services: Technical and transaction data may be shared with fraud screening and anti-money laundering service providers to identify and prevent suspicious activity.
• Analytics Providers: Anonymised and aggregated usage data may be shared with analytics service providers to help us understand platform performance and improve the user experience. No personally identifiable information is transmitted in this context.
• Legal & Regulatory Authorities: Winace99 may disclose personal data to law enforcement agencies, regulatory bodies, courts, or other official authorities where required to do so by applicable law or where necessary to protect the rights, property, or safety of Winace99, its players, or others.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of Winace99's assets, personal data held by Winace99 may be transferred to the acquiring entity, subject to equivalent data protection commitments.

Winace99 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any applicable legal, regulatory, accounting, or reporting obligations. The following general retention principles apply:

• Account Data: Retained for the duration of your Account relationship with Winace99 and for a minimum period of five (5) years following Account closure, in accordance with applicable anti-money laundering record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction to comply with financial regulatory obligations.
• KYC Documentation: Retained for the period required under applicable AML regulations, which is typically five (5) years from the end of the business relationship.
• Marketing Consent Records: Retained until you withdraw your consent or for the period necessary to demonstrate compliance with applicable data protection rules.
• Customer Support Communications: Retained for a period of up to three (3) years to facilitate dispute resolution and service quality reviews, unless a longer retention period is required for regulatory reasons.

Upon the expiry of the applicable retention period, Winace99 will securely delete or anonymise your personal data so that it can no longer be attributed to you as an identifiable individual.

Winace99 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Winace99 platform.
• Encrypted storage of sensitive personal and financial data at rest.
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent security specialists.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Incident response procedures to detect, investigate, and notify affected parties of any personal data breach in accordance with applicable legal requirements.

Winace99 uses cookies, web beacons, pixel tags, and similar tracking technologies to operate the platform, enhance your experience, and gather analytical data. By continuing to use the platform, you consent to the use of cookies in accordance with this section.

The following categories of cookies are used on the Winace99 platform:

• Strictly Necessary Cookies: Essential for the operation of the platform, including maintaining your login session, remembering your cart during a transaction, and ensuring security features function correctly. These cookies cannot be disabled without impairing core platform functionality.
• Functional Cookies: Enable the platform to remember your preferences, such as your chosen language, preferred payment method, and game history, to provide a more personalised experience.
• Analytical Cookies: Used to collect anonymised data about how visitors interact with the platform, including pages visited, session duration, and error events. This information helps us improve the platform over time.
• Security Cookies: Used for fraud detection and prevention purposes, including identifying unusual access patterns or suspicious login activity.

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality and performance of the Winace99 platform. Most browsers allow you to refuse or delete cookies via the browser's privacy or security settings menu.

Subject to applicable data protection legislation, you hold the following rights in respect of your personal data held by Winace99. To exercise any of these rights, please contact our support team using the details in Section 14.

• Right of Access: You have the right to request a copy of the personal data Winace99 holds about you, together with information about how it is being used.
• Right to Rectification: You have the right to request correction of any personal data that is inaccurate or incomplete.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to Winace99's overriding legal obligations to retain certain records.
• Right to Restriction: You may request that Winace99 restricts the processing of your personal data in certain circumstances, for example while a dispute as to its accuracy is resolved.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you may request that we provide your personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Object to Marketing: You may opt out of receiving marketing communications from Winace99 at any time by contacting our support team or updating your Account notification preferences.

Winace99 will respond to all data rights requests within a reasonable period and in accordance with applicable legal requirements. We may request proof of identity before processing a data rights request to ensure your information is not disclosed to an unauthorised party.

The Winace99 platform is strictly intended for adults aged 21 years and above. Winace99 does not knowingly collect personal data from any individual below the age of 21. Age verification is a mandatory component of the KYC process, and any Account found to be registered by or used by a person under the age of 21 will be immediately closed and all associated balances will be withheld pending investigation.

If you believe that a minor has registered an Account on the Winace99 platform, please contact our support team at the earliest opportunity so that the Account can be reviewed and closed. We take the protection of minors seriously and are committed to preventing underage access to gambling services.

The Winace99 platform may display references to third-party payment providers, game software providers, or other service partners. Where interactions with these services involve the transfer of personal data — such as initiating a Touch 'n Go eWallet transaction or a DuitNow payment — the relevant third party's own privacy policy will govern the processing of your data by that party.

Winace99 is not responsible for the privacy practices or content of any third-party service, and we encourage you to review the privacy policies of all third-party services you interact with in connection with your use of the Winace99 platform.

Winace99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable legislation, or operational requirements. Where material changes are made, we will publish the updated Policy on the platform and update the "Last Updated" date at the top of this page.

Where required by applicable law, we will provide advance notice of significant changes via email or a prominent notification on the platform. Your continued use of the Winace99 platform following the publication of any amendment to this Policy constitutes your acceptance of the updated terms. If you do not accept the changes, you should stop using the platform and close your Account.

The current version of this Policy is always accessible at winace99.cam/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Winace99, please contact our support team using the details below. All privacy-related communications should be submitted in English for prompt handling.

• Live Chat: Available 24 hours a day, 7 days a week via the Winace99 platform. Average response time under 2 minutes.
• Email: [email protected] — responses within 4 hours during peak periods.

For requests to exercise your data rights — including access, correction, or deletion requests — please include your registered Account username, the nature of your request, and sufficient information to allow us to verify your identity before processing the request.