Euwins Privacy Policy — Personal Data Protection for Malaysian Members

Euwins values the privacy of every individual who interacts with our platform. This Privacy Policy clearly and transparently explains how euwins — as data controller — collects, processes, stores, protects and, where applicable, discloses your personal data when you use our online casino and Sports Betting platform in Malaysia.

This policy applies to all euwins platform users, including registered members, website visitors, iOS and Android mobile app users, and anyone who contacts our support team via live chat, WhatsApp or email. It covers all services offered by euwins, including slots, live table games, baccarat, football betting, cricket, e-sports and virtual sports.

By registering an euwins account or continuing to use our platform after this Privacy Policy has been updated, you are giving your consent to the collection and processing of your personal data in accordance with the terms set out in this document. If you do not agree with any part of this policy, please stop using the platform and contact us to close your account.

Euwins only collects the personal data necessary to deliver platform services effectively and securely. The data we collect falls into several categories:

Euwins does not collect sensitive data such as your medical information, political views, or religious beliefs unless you voluntarily share it with our support team in a relevant context, and only with your explicit consent.

Euwins uses your personal data solely for the purposes stated and agreed upon at the time of collection. We will not use your data for any other purpose without informing you first and obtaining fresh consent where required. The following sets out the specific purpose for which each category of data is used:

• Account Management: Creating and maintaining your account, verifying your identity, processing logins, and enabling access to all euwins platform features including slots, baccarat, and Sports Betting.
• Transaction Processing: Processing deposits in MYR via Touch 'n Go eWallet, GrabPay, DuitNow, Boost, ShopeePay, and FPX; processing withdrawal of winnings to your chosen payment method; maintaining complete and accurate transaction records.
• Security & Fraud Prevention: Detecting and preventing unauthorized access, fraud, money laundering, and platform abuse. This includes monitoring for unusual activity patterns in your account.
• Customer Support: Enables euwins' Bahasa Malaysia support team to handle enquiries, resolve technical issues and manage your complaints effectively at all times.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and providing appropriate self-exclusion tools; enforcing the limits you set within your account.
• Legal Compliance: Fulfilling obligations required under applicable Malaysian law, including KYC and AML (Anti-Money Laundering) requirements.
• Marketing (with consent): Sending you information about euwins promotions, bonuses, and special offers that may interest you – only if you have given consent to receive marketing communications. You may withdraw this consent at any time.
• Platform Improvements: Analysing aggregated, anonymised usage data to understand how members interact with the euwins platform and make meaningful improvements to the user experience.

Euwins will never use your personal data to make automated decisions that have a serious impact on you without appropriate human review.

Euwins does not sell, rent, or disclose your personal data to third parties for their own marketing or commercial purposes. However, to keep the euwins platform running smoothly and securely, we may need to share certain data with a limited set of third-party categories:

• Payment Providers: Transaction information required for processing is shared with payment service providers such as Touch 'n Go, GrabPay, DuitNow, Boost, ShopeePay, and Malaysian banks via FPX, solely to process your deposits and withdrawals. All such providers are bound by confidentiality agreements and industry security standards.
• Game Providers: Limited account information required to activate gaming sessions is shared with internationally licensed game providers. These providers do not receive your full financial details and are bound by strict data protection agreements.
• Technology Infrastructure Providers: Companies providing cloud computing, cybersecurity and hosting services used by euwins may process your data as part of the services they deliver to us. All such vendors are selected on the basis of their security standards and are bound by contractual obligations.
• Legal Authorities: euwins may be required to disclose certain data to Malaysian authorities or law enforcement agencies when mandated by law, court order, or to prevent illegal activities such as fraud or money laundering.

In all cases above, only the minimum data necessary for the specific purpose is shared. euwins does not permit any third party to use your data for their own purposes unrelated to the services they provide to us.

Euwins invests seriously in security infrastructure to protect your personal data. The technical and organisational measures we have implemented include:

• 256-bit SSL Encryption: All communications between your browser or app and euwins servers are protected by 256-bit TLS/SSL encryption — the same standard used by Malaysia's leading financial institutions.
• Data-at-Rest Encryption: Sensitive data stored in the euwins database — including passwords (stored as hashes, not plain text) and financial information — is encrypted at rest.
• Strict Access Controls: Only euwins staff who require access to specific data to carry out their duties are permitted to do so. All access is logged and monitored.
• 24/7 Security Monitoring: Intrusion detection systems and security monitoring operate around the clock to identify and respond to any threats in real time.
• Regular Security Testing: euwins conducts regular penetration testing and security audits by independent third parties to identify and address vulnerabilities before they can be exploited.
• Two-Factor Authentication (2FA): The 2FA feature is available to all members to add an extra layer of security to your account. We strongly encourage all members to enable it.

While euwins takes all reasonable measures to protect your data, no security system can guarantee 100% protection against every possible threat. In the event of any security incident involving your data, euwins will notify you promptly in accordance with the procedures set out under PDPA 2010.

Euwins uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you browse our website or use the euwins app. The following are the types of cookies we use:

• Essential Cookies (Required): These cookies are required for the euwins platform to function properly. They include login session cookies, security cookies and cookies that store your language preferences. The platform cannot operate without them and they cannot be disabled.
• Performance & Analytics Cookies: We use analytics cookies to understand how members use the euwins platform – which pages are visited most, time spent in each section, and so on. This information is used in aggregated, anonymised form solely to improve the platform.
• Functional Cookies: These cookies allow the platform to remember your preferences, such as your chosen language, username (for the "remember me" function), and display settings, for a more personalised experience.
• Security Cookies: A dedicated cookie that helps detect and prevent fraudulent activity, including logins from unfamiliar locations or devices.

You can manage or delete cookies through your web browser settings. However, disabling essential cookies may affect the functionality of the euwins platform and could prevent you from logging in or completing transactions.

The euwins mobile app for iOS and Android uses technologies equivalent to cookies – including device identifiers and local storage – for the same purposes. You can manage these permissions through your device's privacy settings.

Euwins does not retain your personal data for longer than is necessary for the stated purposes or as required under Malaysian law. Our data retention policy is as follows:

• Active Account Data: For as long as your account remains active and you continue to use the euwins platform, your personal data will be retained to ensure uninterrupted service.
• Data After Account Closure: After you close your euwins account, your personal data records will be retained for a period of 7 years to comply with Malaysian legal obligations, including anti-money laundering (AML) requirements and financial record-keeping. After this period, your data will be securely deleted or anonymised.
• Financial Transaction Records: Deposit and withdrawal records in MYR, including records of Touch 'n Go eWallet, DuitNow, and FPX transactions, are retained for a minimum of 7 years in accordance with Malaysian financial regulatory requirements.
• Support Logs & Communications: Communication records with the support team are retained for 2 years after the last interaction.
• Marketing Data: If you withdraw your marketing consent, we will stop sending marketing communications immediately. However, your email address may be retained on a "do not contact" list to ensure we do not accidentally send you marketing messages in the future.

Once the retention period expires, data is securely deleted using methods that ensure it cannot be recovered. For data stored in physical form (such as copies of KYC documents), disposal is carried out using a certified document shredder.

As a data subject under the Personal Data Protection Act 2010, you have certain rights regarding your personal data held by euwins. We respect and facilitate the exercise of these rights:

• Right to Access: You have the right to request a copy of the personal data we hold about you. Access requests can be made through your account settings or by contacting support@euwins.xyz. We will respond within 21 business days.
• Right to Rectification: If the personal data we hold about you is inaccurate or outdated, you may request a correction at any time through the "Profile" section of your account or by contacting customer support.
• Right to Withdraw Consent: You may withdraw consent for marketing communications at any time via the "unsubscribe" link in our emails or through your account settings. Withdrawing consent will not affect any data processing carried out prior to the withdrawal.
• Right to Object to Processing: In certain circumstances, you have the right to object to the processing of your personal data, particularly for direct marketing purposes.
• Right to Information: You have the right to know how your data is used, who it is disclosed to, and how long it is retained – all of which is set out in this Privacy Policy.

To exercise any of the above rights, contact the euwins Data Protection Officer (DPO) by email at support@euwins.xyz with the subject line "PDPA Rights Request". Please include your full name, euwins account number, and a clear description of your request. We may need to verify your identity before processing the request.

Euwins strictly does not provide any services to individuals under the age of 18. Our platform does not knowingly collect or process the personal data of children or minors below the age of 18.

All prospective members are required to confirm that they are 18 years of age or older during the registration process. Additional age verification (KYC) is carried out to ensure compliance with this minimum age requirement. euwins uses industry-recognised age verification technology as part of our registration procedures.

Should euwins discover that personal data belonging to an individual under the age of 18 has been collected inadvertently, we will take immediate steps to delete that data, close the account in question, and where appropriate, report the incident to the relevant authorities.

Parents or guardians who have reason to believe that their underage child has registered for or used the euwins platform are urged to contact us immediately at support@euwins.xyz so that appropriate action can be taken without delay.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way euwins handles your personal data, please reach out to us through the following channels:

• Email (Privacy Enquiries): support@euwins.xyz – include "Privacy Enquiry" in your email subject line to speed up our response.
• 24/7 Live Chat: Use the live chat feature within the euwins platform for immediate assistance. Our Bahasa Melayu-speaking agents are available at any time.
• WhatsApp Support: Contact the euwins support team via WhatsApp for privacy-related enquiries that require an immediate response.

Euwins will endeavour to respond to all privacy-related enquiries within 14 business days of receipt. For more complex cases requiring internal investigation, we will keep you updated on progress within that timeframe.

Euwins reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, relevant Malaysian legislation, or new operational requirements. Whenever material changes are made, we will notify members via their registered email address or an in-platform notification at least 14 days before the changes take effect. The "Updated" date at the top of this document will indicate when the last amendment was made.