Privacy Policy
— How winbkx Handles Your Data

This Privacy Policy (hereinafter referred to as "the Policy" or "this Policy") issued by winbkx (hereinafter referred to as "winbkx", "the Platform", "we", "us", or "our") and applies to all personal data collected, processed, stored, and transferred in connection with your use of the winbkx online casino and sports betting platform atwinbkx.cam, including any associated mobile applications, sub-domains, and digital services.

winbkx recognises that the privacy and security of your personal information is paramount. This Policy describes, in clear and accessible terms, what personal data winbkx collects from users (including registered players across Malaysia — from Kuala Lumpur to Johor Bahru, Penang, Petaling Jaya, and Shah Alam), the purposes for which that data is processed, the circumstances under which it may be disclosed to third parties, and the rights you hold as a data subject.

By registering an account with winbkx or otherwise accessing and using the platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not accept this Policy, you must not create an account or use the winbkx platform.

The following definitions apply throughout this Privacy Policy:

winbkx collects the following categories of personal data from users of the platform, to the extent necessary to deliver our services and comply with legal obligations:

3.1 Account Registration Data

• Full legal name (as it appears on government-issued identification)
• Date of birth (for age verification — players must be aged 21 or above)
• Email address
• Malaysian mobile phone number
• Username and encrypted password
• Preferred language and communication preferences

3.2 Identity Verification (KYC) Data

• Copy of Malaysian MyKad, passport, or other government-issued photo identification
• Proof of residential address (e.g., utility bill, bank statement)
• Source-of-funds documentation where required by anti-money laundering obligations
• Selfie or biometric verification data where applicable to the KYC procedure

3.3 Financial Transaction Data

• Deposit and withdrawal transaction records (amounts, dates, payment methods)
• Payment instrument details (e-wallet identifiers for Touch'n Go eWallet, Boost, GrabPay; masked bank account numbers for DuitNow/FPX/Maybank/CIMB/Public Bank; cryptocurrency wallet addresses for USDT TRC20)
• MYR balance history and transaction ledger entries

3.4 Gaming & Activity Data

• Wager history, game session records, and betting patterns
• Bonus credit usage and wagering progression
• Sports betting selections (including EPL, Liga Super Malaysia, UFC, and other markets)
• Responsible gambling tool settings (deposit limits, loss limits, self-exclusion status)

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookie identifiers and similar tracking technology data (see Section 10)

3.6 Communications Data

• Content of live chat conversations and support email exchanges
• Records of complaints and their resolution
• Marketing preference settings and communication opt-in/opt-out history

winbkx collects personal data through the following mechanisms:

• Directly from you: Information you provide during account registration, KYC submission, deposit and withdrawal requests, support interactions, and completion of responsible gambling self-assessment tools.
• Automatically: Technical and device data is collected automatically when you access the winbkx platform, via cookies, server logs, and similar tracking technologies embedded in the platform infrastructure.
• From third-party payment processors: When you complete a deposit or withdrawal via Touch 'n Go eWallet, DuitNow, FPX, or any other supported payment method, the relevant payment provider may share transaction confirmation data with winbkx for reconciliation purposes.
• From identity verification partners: winbkx may use authorised third-party KYC verification services to cross-reference the identity documents you submit against official government or credit reference databases.
• From fraud prevention services: winbkx may receive risk signals and fraud indicators from third-party fraud prevention partners as part of our security and anti-moneylaundering procedures.

winbkx processes personal data for the following specific and legitimate purposes:

winbkx processes personal data on the basis of one or more of the following legal grounds, depending on the purpose for which the data is processed:

• Contractual necessity: Processing is required to fulfil our obligations under the account registration agreement and to deliver the services you have requested — including processing deposits via DuitNow or FPX, settling your wagers, and operating your loyalty tier benefits.
• Legal obligation: Processing is required to comply with applicable laws and regulations, including KYC, AML, and responsible gambling obligations imposed by the jurisdictions in which winbkx operates.
• Legitimate interests: Processing is necessary for winbkx's legitimate interests in preventing fraud, maintaining platform security, and improving our services, where these interests are not outweighed by your privacy rights.
• Consent: Where we send you marketing communications or use non-essential cookies, we do so on the basis of your explicit, informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

winbkx does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly for the purposes described in Section 5:

• Payment processors and financial institutions: Entities such as Touch 'n Go eWallet, Boost, GrabPay, DuitNow payment network participants, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, and cryptocurrency exchange partners — solely to process your deposit and withdrawal transactions.
• KYC and identity verification providers: Authorised third-party services used to verify the authenticity of your identity documents and satisfy our legal due-diligence requirements.
• Fraud prevention and risk management services: Third-party services that assist winbkx in detecting and preventing fraudulent activity, account takeovers, and money-laundering attempts.
• Technology and infrastructure providers: Cloud hosting, content delivery, and platform technology suppliers operating under data processing agreements that prohibit them from using your data for any purpose other than providing services to winbkx.
• Regulatory and law enforcement authorities: winbkx may be legally required to disclose personal data to government authorities, law enforcement agencies, or regulatory bodies in response to a lawful request, court order, or legal obligation.
• Professional advisers: Lawyers, auditors, and consultants who are bound by professional confidentiality obligations and who require access to data in the course of providing services to winbkx.

winbkx retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. The following indicative retention periods apply:

• Account and KYC data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in accordance with anti-money-laundering record-keeping requirements.
• Financial transaction records: Retained for a minimum of seven (7) years following the date of each transaction, as required by applicable financial record-keeping regulations.
• Gaming activity records: Retained for a minimum of three (3) years following the date of each session or wager, for dispute resolution and responsible gambling monitoring purposes.
• Support communications: Retained for three (3) years from the date of the last interaction, for quality assurance and dispute resolution.
• Marketing preference records: Retained for the duration of your account and for two (2) years following opt-out, to prevent re-contacting you contrary to your stated preferences.
• Technical and device data (including server logs): Typically retained for thirteen (13) months, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any individual.

winbkx implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Key measures include:

• Encryption in transit: All data transmitted between your device and the winbkx platform is encrypted using TLS 1.2 or higher (256-bit SSL).
• Encryption at rest: Sensitive personal data stored in winbkx databases is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorised personnel on a role-based, need-to-know basis. All internal access is logged and periodically audited.
• Two-factor authentication (2FA): Available to all registered players and mandatory for platform administrators.
• Penetration testing: winbkx commissions independent security assessments of its platform infrastructure on a regular basis.
• Incident response: winbkx maintains a documented data breach response plan. Affected data subjects and relevant authorities will be notified in accordance with applicable legal timeframes in the event of a confirmed breach.

winbkx uses cookies and similar tracking technologies (including web beacons and local storage) to provide and improve the platform, enable essential functionality, and (where consent is given) to personalise the experience and deliver relevant promotional communications.

The cookies used on the winbkx platform fall into the following categories:

• Strictly necessary cookies: Essential for the operation of the platform, including session management, authentication, and security. These cookies cannot be disabled without impairing core platform functionality.
• Functional cookies: Remember your preferences (such as preferred language, deposit method defaults, and responsible gambling limit settings) to improve your experience on subsequent visits.
• Analytics cookies: Used — with your consent — to collect aggregated and anonymised data about how players use the platform, enabling winbkx to identify areas for improvement.
• Marketing cookies: Used — with your explicit consent — to deliver personalised promotional content about winbkx bonuses and platform updates. You may withdraw this consent at any time through your account settings or by contacting support.

You can manage your cookie preferences through your browser settings. Note that disabling certain categories of cookies may affect the functionality of the winbkx platform.

As a data subject, you hold the following rights in respect of your personal data held by winbkx, subject to applicable legal conditions and exemptions: