Privacy Policy winboc — Personal Data Protection for Malaysia Members

Winboc collects various types of personal data from members to ensure the platform operates safely, efficiently, and in compliance with regulatory requirements. We collect only what is genuinely necessary and nothing more.

In addition to data you provide directly during registration, we also collect data automatically when you use our platform. This includes information about the device you use, how you interact with the platform, and the timestamp of each session. This data is used solely for security purposes and service improvement.

Every piece of data we collect has a clear purpose. winboc never uses member data for purposes not stated in this policy without first obtaining your additional consent.

• Account Management: Verifying your identity, processing registration, and managing your account over time, including profile information updates.
• Transaction Processing: Securely and accurately verifying and processing all deposits, withdrawals, and financial transactions in your account.
• Platform Security: Detecting and preventing fraudulent activity, money laundering, unauthorized access, and any security threats that may affect you or the platform.
• Legal Compliance: Meeting regulatory requirements, including KYC and AML (Anti-Money Laundering) obligations set by the relevant authorities.
• Service Communications: Sending important notifications regarding your account, transactions, security updates, and changes to the terms of service.
• Product Improvement: Analyzing aggregated and anonymized usage patterns to improve platform features, user experience, and game offerings.
• Responsible Marketing: Sending relevant promotional information and special offers, subject to the communication preferences you set in your account settings.

You may opt out of marketing communications at any time via the notification settings in your account. However, security and transaction notifications cannot be disabled as they are essential to protecting your account.

Winboc does not sell, rent, or disclose your personal data to third parties for their own marketing purposes. Data sharing only occurs in limited, specific circumstances as outlined below:

• Payment Service Providers: Required financial data is shared with approved payment providers such as FPX, Touch 'n Go, and other e-wallet providers to process your transactions.
• Technology Service Providers: Technical partners who help us operate the platform, including cloud computing and cybersecurity services, are bound by strict confidentiality agreements.
• Regulatory Authority: When required by Malaysian law or a valid authority directive, we are obligated to disclose certain information without prior notice to you.
• Independent Identity Verification: Third-party KYC service providers that assist us in verifying member identities, subject to strict data processing agreements.

In the event of a company merger, acquisition, or sale of business assets, members' personal data may be transferred as part of those business assets. In such situations, we will notify you in advance and ensure that equivalent data protection standards continue to be maintained.

Protecting your personal data is a responsibility we take very seriously. Winboc invests in industry-grade security infrastructure to keep your data safe from unauthorized access, loss, or misuse at all times.

• All data transmitted between your device and the winboc servers is protected by 256-bit SSL/TLS encryption, consistent with the standards used by leading banking institutions.
• Data is stored in data centres protected by multi-layered physical access controls, 24/7 monitoring, and automated backup systems.
• Internal access to members' personal data is restricted to staff who require it to perform their duties, with strict monitoring of every access.
• Winboc performs regular security testing and independent audits to identify and address any system vulnerabilities before they can be exploited.
• Two-factor authentication (2FA) is available for all member accounts and is strongly recommended to be enabled for added protection.

Your personal data is retained for as long as necessary to fulfil the purpose for which it was collected, or as required by Malaysian law. Financial transaction records are kept for a minimum of 7 years in accordance with legal requirements. After the defined retention period, data will be securely deleted or anonymised.

The Winboc platform uses cookies and similar tracking technologies to enhance your experience, ensure session security, and understand how members use our platform. This is standard practice in the technology industry.

• Essential Cookies: Required for core platform functions such as maintaining your login session, processing transactions, and ensuring security. These cookies cannot be disabled.
• Performance Cookies: Collecting anonymous statistical data on how members interact with the platform, helping us identify and improve areas that need enhancement.
• Preference Cookies: Storing your personal preferences such as language, display settings, and game preferences so you don't have to reconfigure them every time you log in.
• Security Cookies: Used to detect and prevent suspicious activity, protecting your account from unauthorised access and cyberattacks.

You can manage your cookie settings through your web browser at any time. However, disabling essential cookies may affect platform functionality. For more information on managing cookies in popular browsers, refer to your browser's help documentation.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have certain rights regarding your personal data held by Winboc. We fully respect these rights and provide straightforward mechanisms for you to exercise them.

Winboc strictly does not accept registrations from individuals under the age of 18. Our platform is not designed or intended for children or minors, and we do not knowingly collect any personal data from them.

• All prospective members are required to confirm that they are 18 years of age or older during the registration process.
• Winboc conducts KYC checks to verify member age, including requesting official identification documents where necessary.
• If we discover that personal data of a minor has been collected inadvertently, we will delete that data immediately and close the account in question.
• Parents or guardians who suspect their child has registered without permission are encouraged to contact us immediately through official Winboc support channels.

Winboc reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform improvements. We are committed to being transparent about any changes made.

• The "Last Updated" date at the top of this document will be revised whenever material changes are made.
• For significant changes, 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 Winboc platform after the effective date of any changes constitutes acceptance of the amended terms.
• Previous versions of this Privacy Policy are available upon request from our Data Protection team for reference purposes.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, do not hesitate to contact us. The Winboc Data Protection team is ready to assist you.

• Live Chat Platform: The fastest way to get a response — available 24/7 directly within the Winboc platform after logging in.
• Official Email: [email protected] — for written enquiries requiring documentation or an official written response.
• Response Time: We aim to respond to all privacy enquiries within 3 business days, and to formal requests under PDPA within 21 business days.

If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP), the regulatory body responsible under PDPA 2010.