Privacy Policy surewin — Transparent Player Data Protection in Malaysia

This Privacy Policy is issued by surewin ("we", "Platform") and applies to all users who register, browse, or use any part of the surewin platform, including the surewin.plus website and the surewin mobile app.

We comply with Malaysia's Personal Data Protection Act 2010 (PDPA) and international data protection standards in handling users' personal information. Every piece of data we collect has a clear purpose, and we do not collect more than is genuinely necessary to provide our services to you.

By registering or continuing to use the surewin platform, you acknowledge that you have read and understood this Privacy Policy. If you disagree with any part of this policy, you are advised to discontinue use of the platform.

Surewin collects various categories of personal data required for different purposes. The following are the main categories of data we collect:

Your personal data is collected through several channels when you interact with the surewin platform:

• Account Registration: Information you provide when registering a new account, including your name, email, and contact details.
• KYC Process: Identity documents and financial information submitted during identity verification to enable withdrawals.
• Gaming Activity: Game records, total betting amounts, wins, and losses are automatically generated by the platform system.
• Financial Transactions: Information related to deposits, withdrawals, and payment history processed through third-party payment providers.
• Platform Usage: Technical data collected automatically, such as IP address, device type, web browser, and usage patterns via cookies.
• Customer Support: Information you provide when contacting our support team via Live Chat or email.
• Promotions & Contests: Data voluntarily submitted when you participate in surewin promotions or rewards programmes.

Surewin uses your personal data for the following purposes, each supported by a valid legal basis:

• Service Provision: Enables you to access the platform, play games, make deposits, and withdraw your winnings.
• Identity Verification (KYC): Verifies player identity to meet compliance requirements and prevent fraud.
• Payment Processing: Manages deposit and withdrawal transactions securely through authorised payment providers.
• Account Security: Detects and prevents unauthorised access, fraud, and suspicious activity.
• Legal Compliance: Meets reporting requirements, anti-money laundering (AML) obligations, and other legal requirements.
• Platform Improvement: Analyses usage patterns to improve user experience and platform performance.
• Service Communications: Sends important notifications regarding your account, transactions, and platform updates.
• Marketing (with consent): Sends promotional information and special offers that you have agreed to receive.

Surewin does not sell, rent, or trade your personal information to any third party for their own marketing purposes. However, we share necessary data with selected third parties in the following circumstances:

• Payment Providers: Required transaction details are shared with FPX, e-wallet, and other payment gateway providers to process your deposits and withdrawals.
• Game Providers: Basic account data is shared with licensed game providers to enable access to games in our lobby.
• KYC Services: Identity verification documents are sent to recognised KYC service providers for verification purposes only.
• Authorities: Data is shared with law enforcement agencies or regulatory bodies when required by law or court order.
• Analytics Services: Non-personally identifiable usage data is shared with analytics providers to help us understand platform usage patterns.

All third parties we work with are required to comply with strict data protection policies and are not permitted to use your data for any purpose other than what has been agreed upon with surewin.

Surewin takes comprehensive security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL Encryption for all data transmitted between your device and surewin's servers.
• Encryption of data at rest for all sensitive information stored in our databases.
• Role-based access control to ensure only authorized personnel can access specific data.
• Regular security audits by independent third parties to identify and address any vulnerabilities.
• 24/7 Monitoring on systems to detect any suspicious activity or intrusion attempts.
• Two-factor authentication (2FA) for staff access to internal systems containing player data.

Your personal data is retained for as long as necessary for the purposes for which it was collected, or as required by law. Generally, active account records are kept for the duration of the active account plus 5 years after account closure for legal compliance purposes.

Under Malaysia's Personal Data Protection Act 2010, you have the following rights regarding your personal data held by surewin:

To exercise any of the rights above, please contact our privacy team via 24/7 Live Chat within the platform or email us at [email protected]. We will verify your identity before processing any data-related requests.

Surewin uses cookies and similar tracking technologies to enhance your experience on the platform. Cookies are small text files stored on your device when you browse our website.

We use the following types of cookies:

• Essential Cookies: Required for core platform functions such as login, game sessions, and security. Cannot be disabled.
• Preference Cookies: Saves your preferences such as language, theme, and display settings for a more personalised experience.
• Analytics Cookies: Helps us understand how players use the platform so we can continuously improve it. Data is collected anonymously.
• Security Cookies: Helps us identify suspicious usage patterns and protect your account from unauthorised access.

You can manage cookie settings through your web browser. However, disabling essential cookies may affect platform functionality. Continued use of the surewin platform is considered your consent to the use of cookies as described above.

As a digital platform utilizing cloud infrastructure and international service providers, your personal data may be transferred to and stored on servers located outside Malaysia. Such transfers only occur when:

• The recipient country has a level of data protection equivalent to or exceeding Malaysia PDPA requirements.
• Adequate contractual safeguards have been put in place between surewin and the data recipients.
• The transfer is necessary to carry out the agreement between you and surewin, or is made at your own request.

Surewin ensures that all cross-border data transfers are handled in compliance with strict data protection standards, and receiving parties are required to provide equivalent protection for your data.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, please contact us through the following channels:

• 24/7 Live Chat: Available directly within the surewin platform — the fastest way to get a response.
• Privacy Email: [email protected] — for detailed data-related enquiries, please include "Privacy Enquiry" in the email subject line.

We are committed to responding to all privacy-related enquiries within 5 working days. For data access or deletion requests, processing may take up to 14 working days depending on the complexity of the request.