Privacy Policy 123win — Your Data, Our Responsibility

1. Introduction & Scope of Privacy Policy

This Privacy Policy is published by 123win ("We", "Platform") and applies to all users who access or use our services through the 123win website. We operate in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and are fully committed to protecting the privacy of every member.

By using the 123win platform, registering an account, or making any transaction, you agree to the collection and use of your information as described in this policy. If you do not agree with any part of this policy, please stop using our platform and contact our support team to close your account.

This Privacy Policy should be read together with our Terms and Conditions and Responsible Gaming Policy, all of which form the complete agreement between you and 123win.

2. Types of Personal Data We Collect

We collect various types of information depending on how you interact with the 123win platform. Below is a full breakdown of the data we may collect:

3. Purpose of Data Collection & Processing

Every piece of data we collect has a clear and legitimate purpose. We use your information for the following purposes:

• Account Management: Creating, verifying, and managing your member account, including the required KYC process.
• Transaction Processing: Processing deposits, withdrawals, and all financial activities within the platform securely and accurately.
• Platform Security: Detecting and preventing fraud, money laundering, unauthorised access, and any other suspicious activities.
• Legal Compliance: Fulfilling our obligations under PDPA 2010, anti-money laundering (AML) regulations, and KYC requirements set by regulatory authorities.
• Service Improvement: Analysing usage patterns to enhance the gaming experience, platform performance, and new feature development.
• Communication: Sending important account-related notifications, system updates, promotional offers (with your consent), and customer support responses.
• Responsible Gaming: Monitoring betting patterns to identify members who may need assistance and providing appropriate support.

We do not use your data for any purpose beyond what is stated above without first obtaining your additional consent.

4. Data Sharing & Disclosure

123win takes your trust seriously. We does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. However, there are certain situations where we need to share your information:

• Service Providers: Technical partners who help us operate the platform, such as payment service providers (FPX, Touch 'n Go, Boost), licensed game providers, and cloud infrastructure providers. All parties are bound by strict confidentiality agreements.
• Legal Authority: When required by court order, police investigation, or direction from a lawful regulatory authority in Malaysia.
• Fraud Prevention: Sharing information with fraud prevention agencies or other platforms in cases of suspected fraud or money laundering, in accordance with applicable laws.
• Business Transfer: If 123win is involved in a merger, acquisition, or asset sale, user data may be transferred as part of the business assets. You will be notified in advance should any such change occur.

5. Data Security Measures

Protecting your data is not merely a legal obligation for us — it is a core commitment we take very seriously. The following are the technical and organisational measures we have implemented:

• 256-bit SSL Encryption: All data transmitted between your browser and our servers is protected with industry-grade encryption. This means no one can intercept or read your information while in transit.
• Data Segregation: Financial data and personal data are stored in separate systems with strict access controls.
• Access Control: Only specifically authorised staff may access member personal data, and all access is logged for audit purposes.
• 24/7 Monitoring: An automated monitoring system operates around the clock to detect any intrusion attempts or abnormal activity.
• Regular Backups: Data is regularly backed up to a separate secure location to ensure service continuity.
• Security Assessment: Security audits and penetration testing are conducted regularly by independent security experts.

6. Cookies, Tracking & Similar Technologies

The 123win platform uses cookies and similar tracking technologies to enhance your experience and analyze platform usage. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login, session management, and security. These cookies cannot be disabled.
• Performance Cookies: Collecting anonymous information about how you use the platform to help us improve performance and user experience.
• Functional Cookies: Remembering your preferences such as language, display settings, and other personal configurations.
• Analytics Cookies: Helping us understand aggregate usage patterns for product development and platform optimisation.

You can manage your cookie settings through your browser at any time. However, disabling certain cookies may affect the functionality of some parts of the platform. By continuing to use 123win, you consent to the use of cookies as described above.

7. Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding the personal data we hold about you:

To exercise any of the above rights, contact our privacy team via Live Chat or support email. We will process your request within 14 business days. Please note that some requests may be subject to identity verification beforehand.

8. Data Retention Period

123win retains your personal data only for as long as necessary to fulfil the purposes stated in this policy or as required by Malaysian law.

• Active Account Data: Retained for the duration your account is active and for 7 years after account closure, in line with PDPA requirements and AML regulations.
• Transaction Records: Retained for a minimum of 7 years for financial and tax law compliance purposes.
• Activity Log: Retained for 12 months for security and fraud detection purposes.
• Communication Records: Retained for 3 years after your last interaction for reference and dispute resolution purposes.
• Marketing Data: Deleted as soon as you withdraw your marketing consent.

When data is no longer needed and there is no legal obligation to retain it, we will securely delete or anonymise it.

9. Children's Privacy

The 123win platform is strictly for adult users aged 18 years and above. We do not knowingly collect any personal data from individuals under the age of 18.

If we determine that we have collected data from a person under the age of 18, we will immediately take the following steps:

• Terminating the relevant account immediately.
• Deleting all data related to that individual from our systems.
• Returning any funds that may remain in that account through the appropriate channels.

10. Contact Us & Privacy Complaints

If you have any questions, concerns, or complaints regarding how we handle your personal data, we encourage you to contact us directly first.

You can reach our privacy team via:

• Live Chat: Available 24/7 directly within the 123win platform — the fastest way to get a response.
• Email: [email protected] — for more detailed inquiries or those requiring documentation.

We are committed to responding to all privacy-related enquiries within 72 hours. For more complex complaints, we will provide progress updates every 7 business days until the case is resolved.

If you are not satisfied with our response, you have the right to escalate your complaint to the Department of Personal Data Protection (JPDP) Malaysia as the regulatory body responsible under PDPA 2010.