winmr Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how winmr ("Company", "we", "us", "our"), the operator of the online gaming platform at winmr.app and all associated subdomains and mobile interfaces (collectively, the "Platform"), collects, uses, stores, shares, and protects personal data relating to registered players, prospective players, and visitors to the Platform ("you", "User", "Player").

We are committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection legislation and international gaming authority standards. By registering an Account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions, which are incorporated by reference. Capitalised terms used but not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

winmr is the data controller in respect of personal data collected through the Platform. As data controller, winmr determines the purposes and means by which personal data is processed. For all privacy-related queries, you may contact us via the support channels described in Section 14 of this Policy.

Where winmr engages third-party service providers to process personal data on its behalf (for example, payment processors or analytics providers), those providers act as data processors under contract with winmr. They are prohibited from using your data for any purpose other than the specific services they provide to us.

3. Categories of Personal Data We Collect

3.1 Registration and Identity Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (for age verification — must confirm 21+)
• Registered mobile phone number
• Residential address
• Account username and hashed password

3.2 KYC Verification Documents

• Scanned copy or photograph of MyKad (Malaysian identity card) or equivalent government-issued photo identification for non-Malaysian residents
• Proof of residential address (utility bill, bank statement, or equivalent) where required
• Proof of payment method ownership (for certain withdrawal methods)

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records including amounts, timestamps, and payment method identifiers
• Wallet balance history and bonus credit records
• Payment method type and partial account identifiers (e.g., last four digits of a bank account — full card or account numbers are not stored on winmr servers)

3.4 Gameplay and Activity Data

• Game session logs including games played, bet amounts, outcomes, and session duration
• Sportsbook wager records including markets, odds, and settlement outcomes
• Responsible gaming tool usage — deposit limits set, session reminder configurations, and self-exclusion history

3.5 Technical and Device Data

• IP address and geolocation data derived therefrom
• Device type, operating system version, and browser type
• Session access timestamps and login history
• Cookies and similar tracking technologies (see Section 9)

3.6 Communications Data

• Live chat transcripts between you and the winmr support team
• Email correspondence with winmr
• Feedback and complaints submitted through the Platform

4. How We Collect Your Data

winmr collects personal data through the following means:

• Direct submission: Data you provide during registration, KYC verification, deposit and withdrawal requests, and communications with the support team.
• Automated collection: Technical data collected automatically when you access the Platform — IP address, device identifiers, session logs, and cookie data.
• Third-party verification services: Identity and age verification data returned by KYC service providers when we submit documents for automated or assisted verification.
• Payment processors: Transaction confirmation data returned by payment gateways upon successful deposit or withdrawal processing.

5. Purpose and Legal Basis for Processing

We process your personal data for the following purposes and on the following legal bases:

• Contract performance: To operate your Account, process deposits and withdrawals, deliver gaming services, and provide customer support — necessary for performance of the contract between you and winmr.
• Legal obligation: To perform KYC identity and age verification, implement anti-money laundering controls, maintain transaction records, and respond to lawful regulatory requests.
• Legitimate interests: To detect and prevent fraud, abuse, and account security breaches; to monitor platform performance and fix technical issues; to analyse aggregate gameplay data for product improvement.
• Consent: To send you promotional communications about winmr offers where you have explicitly opted in to receive such communications. You may withdraw consent at any time by contacting support.

6. Data Sharing and Disclosure

6.1 Service Providers

winmr shares personal data with carefully selected third-party service providers who process data on our behalf solely for the purposes described in Section 5. These include payment processors, KYC verification providers, platform hosting and infrastructure providers, analytics services, and live chat support tools. All service providers are bound by data processing agreements prohibiting independent use of your data.

6.2 Regulatory and Legal Disclosure

winmr may disclose personal data to regulators, law enforcement agencies, courts, or other governmental authorities where required to do so by applicable law, court order, or regulatory directive — including obligations under anti-money laundering legislation. We will only disclose the minimum data necessary to satisfy the specific legal requirement.

6.3 No Sale of Data

winmr does not sell, rent, or trade your personal data to third-party marketers, data brokers, or any entity for commercial exploitation. Your data is used exclusively to operate the Platform and comply with legal obligations.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of winmr's business assets, personal data held by winmr may be transferred to the successor entity. You will be notified of any such transfer and the privacy practices of the successor entity before the transfer takes effect.

7. International Data Transfers

The winmr Platform serves players primarily in Malaysia. Some of our service providers — particularly cloud infrastructure and payment processing providers — may process data in jurisdictions outside Malaysia. Where such transfers occur, winmr ensures that appropriate safeguards are in place, including contractual protections equivalent to those required under applicable data protection law, to ensure your data receives a consistent standard of protection regardless of where it is processed.

8. Data Retention

We retain personal data for as long as your Account is active and for a period thereafter as required by applicable legal and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, as required by anti-money laundering regulations.
• Transaction records are retained for a minimum of five (5) years from the date of each transaction.
• KYC documents are retained for the period required by the applicable gaming authority's regulatory guidelines.
• Gameplay session logs are retained for a minimum of three (3) years for dispute resolution and audit purposes.
• Communications data (live chat transcripts, emails) is retained for two (2) years or longer if relevant to an ongoing dispute or investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data lifecycle management procedures.

9. Cookies and Tracking Technologies

9.1 Types of Cookies Used

• Strictly necessary cookies: Required for the Platform to function — session authentication, security tokens, and load balancing.
• Performance cookies: Collect anonymous aggregated data about how players use the Platform — page load times, error rates, and navigation patterns — to help us identify and fix performance issues.
• Functionality cookies: Remember your preferences such as language settings and table layout preferences across sessions.
• Analytics cookies: Used with analytics platforms to understand aggregate user behaviour patterns. Data collected through analytics cookies is anonymised and not linked to individual account identities.

9.2 Managing Cookies

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will impair the functionality of the winmr Platform and may prevent you from maintaining a logged-in session. Disabling analytics or performance cookies does not affect your ability to access any Platform feature.

10. Security Measures

winmr implements layered technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. These measures include:

• TLS 1.3 encryption for all data transmitted between your device and our servers
• Encryption at rest for sensitive data stored in our databases
• Cryptographic hashing of Account passwords — plain-text passwords are never stored
• Role-based access controls restricting employee access to personal data on a need-to-know basis
• Intrusion detection systems and 24/7 security monitoring
• Regular third-party security audits and penetration testing
• Automatic session expiry for idle login sessions

While we implement industry-standard security measures, no internet-based platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, winmr will notify affected users and relevant regulatory authorities in accordance with applicable legal requirements and within the timeframes prescribed.

11. Your Data Rights

Depending on applicable data protection law, you may have the following rights in respect of your personal data held by winmr:

• Right of access: Request a copy of all personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of your personal data in circumstances where we no longer have a lawful basis for retaining it and no overriding legal obligation requires retention.
• Right to restriction: Request that we restrict the processing of your data in certain circumstances — for example, while the accuracy of data you have contested is verified.
• Right to data portability: Request a machine-readable copy of personal data you have provided to us, where processing is based on consent or contract performance.
• Right to object: Object to processing based on our legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact the winmr support team via the channels in Section 14. We will respond to verified requests within 30 days. Identity verification may be required before we process requests affecting personal data.

12. Children and Minors

The winmr Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under 21. If we discover or are notified that personal data has been collected from a person under 21, that Account will be immediately closed, data will be deleted to the extent not required for regulatory retention purposes, and funds will be handled in accordance with our Terms & Conditions and applicable regulatory requirements. If you believe a minor has registered an Account on the Platform, please notify us immediately via support.

13. Updates to This Privacy Policy

winmr reserves the right to update this Privacy Policy at any time. Material changes — including changes to the categories of data collected, the purposes for which data is used, or new data sharing arrangements — will be communicated to registered Players via the email address on record or via a prominent on-Platform notice at least seven (7) days before the change takes effect. Your continued use of the Platform following the effective date of any update constitutes acceptance of the revised Policy. The current version of this Policy is always available on this page with the effective date clearly displayed.

14. Contact Us

For questions, requests, or complaints relating to this Privacy Policy or the handling of your personal data by winmr, please contact us via:

• Live Chat: Available 24/7 through the winmr Platform — accessible after logging in to your Account.
• Email: [email protected]

We aim to acknowledge all privacy-related requests within 3 business days and resolve them within 30 calendar days. If you are not satisfied with our response to your privacy request, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.