Privacy Policy wingiler

1. Definitions & Scope of the Privacy Policy

This Privacy Policy is a legal agreement between you ("User", "Member") and wingiler ("we", "company", "platform"). This document describes the practices of collecting, processing, using and protecting personal information carried out by wingiler in the context of providing online gambling services to eligible users who are 21 years of age and above.

The scope of this policy covers all your interactions with the wingiler platform, including access via the website, mobile applications (where available), communications with the customer support team, and any participation in promotions, contests or membership programmes organised by wingiler.

This policy applies together with the wingiler Terms & Conditions and Responsible Gambling Policy, both of which form the complete agreement between you and our platform.

2. Personal Information We Collect

In operating the wingiler platform, we collect various categories of personal information depending on the nature of your interaction with us:

a) Information you provide directly:

• Identity information: full name, identity card number (MyKad) or passport, date of birth, gender and nationality;
• Contact information: email address, mobile phone number, mailing address;
• Proof of identity: copies of identification documents uploaded during the account verification process (KYC);
• Financial information: e-wallet details (Touch 'n Go, Boost, ShopeePay), bank account number for FPX, or relevant crypto wallet information (USDT, BTC, ETH);
• Password: stored in cryptographic hash form — we never store passwords in plain text.

b) Information collected automatically:

• IP address, device type, operating system and web browser used;
• Access log data including date, time and pages visited;
• Country-level geolocation data (not precise location);
• Records of game activity, betting and transactions;
• Cookie and user session information.

3. Purpose of Data Collection & Processing

wingiler processes your personal information only for legitimate purposes that have been stated in advance. The following are the main purposes for data collection:

• Account registration & verification: confirming your identity and verifying that you meet the minimum age requirement of 21 years;
• AML/KYC compliance: fulfilling legal obligations related to the prevention of money laundering and terrorism financing;
• Transaction processing: processing deposits and withdrawals through supported payment methods securely;
• Account management: maintaining records of your activity, account balance, bonuses and VIP eligibility;
• Support service provision: enabling our 24/7 support team to assist you effectively;
• Platform security: detecting fraudulent activity, unauthorised access attempts and suspicious behaviour;
• Communications: sending transaction notices, important updates and relevant promotional information (you may unsubscribe from marketing communications);
• Regulatory compliance: meeting international licensing requirements under which wingiler operates.

4. Disclosure of Information to Third Parties

wingiler does not sell or commercialise your personal data to any third party. However, in certain circumstances, your information may be shared with the following parties:

• Payment service providers: transaction processors that enable deposits and withdrawals via DuitNow, FPX and e-wallets to be processed securely;
• Game service providers: software developers such as PG Soft, Pragmatic Play, JILI and Spribe that require session data to operate games;
• Regulatory authorities: licensing bodies or law enforcement agencies that require your information lawfully under applicable law;
• Technology service providers: cloud infrastructure, analytics and cybersecurity providers bound by strict confidentiality agreements.

5. Cookies & Tracking Technologies

The wingiler website uses cookies and similar tracking technologies to improve user experience and ensure platform security. The cookies we use fall into several categories:

• Essential cookies: required for basic website functions such as login session verification, basket management and security settings — cannot be disabled;
• Performance cookies: collect information on how users interact with the website so we can improve the overall user experience;
• Functional cookies: store your preferences such as language, region and display settings to provide a more personalised experience;
• Analytics cookies: allow us to understand usage patterns, identify underperforming pages and improve platform performance.

You can manage cookie settings through your web browser. However, disabling certain cookies may affect platform functionality. Login sessions, for example, require an active session cookie to work correctly.

6. International Data Transfers

As an online gambling platform operating under international licensing, wingiler may transfer your personal information to servers located in countries other than Malaysia. Such transfers are only carried out under the following circumstances:

• The recipient country provides an adequate level of data protection as assessed independently;
• The transfer is protected by standard contractual clauses or equivalent protective mechanisms;
• You have given explicit consent for the transfer, or the transfer is necessary for the performance of an agreement between you and wingiler.

wingiler always ensures that any cross-border data transfer complies with applicable data protection laws and that your information receives equivalent protection wherever it is stored or processed.

7. Personal Data Retention Period

wingiler retains your personal information for as long as necessary to fulfil the purposes of collection stated in this policy, unless a longer retention period is required or permitted by law. Specifically:

• Active account data: retained for as long as your account remains active and has not been closed;
• Transaction data & financial records: retained for a minimum of seven (7) years to meet regulatory compliance obligations and audit requirements;
• KYC records & identity verification: retained for the duration of the active account and up to five (5) years after account closure;
• Customer support communication logs: retained for three (3) years for reference and dispute resolution purposes;
• Access log data: retained for twelve (12) months for security purposes.

Once the specified retention period has ended, your data will be securely deleted or anonymised so that it can no longer be linked to a specific individual.

8. Your Rights as a Data Subject

As a wingiler user, you have certain rights regarding your personal information. We fully respect these rights and are committed to facilitating their exercise:

9. Data Security Measures

wingiler implements various appropriate technical and organisational measures to protect your personal information from unauthorised access, loss, destruction or accidental disclosure. These measures include:

• Data encryption in transit: all communications between your device and our servers are protected using TLS 1.3 protocol;
• Role-based access control: only authorised staff with a legitimate job requirement may access your personal data;
• Two-factor authentication (2FA): available for your account as an additional security layer;
• Continuous security monitoring: intrusion detection systems and operational log monitoring active at all times;
• Regular security audits: vulnerability assessments and penetration testing carried out periodically by independent parties;
• Staff training: all staff who handle personal data receive comprehensive data protection training.

Although we take all reasonable precautions, no security system is perfect. In the event of a data breach affecting your rights or freedoms, we will notify you and the relevant authorities within the timeframe required by applicable law.

10. Notification of Privacy Policy Changes

wingiler reserves the right to update or modify this Privacy Policy from time to time in response to changes in law, regulatory requirements or business practices. Whenever significant changes are made:

• A clear notice will be displayed on the wingiler homepage or on this policy page;
• Members with active accounts will be notified via their registered email;
• The "Updated" date at the top of this document will be updated to reflect the latest version;
• Previous versions of the policy will be archived and can be requested through our support team.

Your continued use of the wingiler platform after the effective date of such changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you have the right to close your account before the changes take effect.

11. Contact Us Regarding Privacy

If you have any questions, concerns or complaints about how wingiler handles your personal information, we encourage you to contact us directly:

• Privacy email: [email protected] (subject: "Privacy Policy Enquiry")
• Live chat: available 24/7 via the support widget on our website in Malay and English
• Response time: we aim to respond to all privacy-related enquiries within a reasonable time

We take every privacy complaint seriously and will conduct a thorough investigation and provide you with a meaningful response.