Win77 Privacy Policy

This Privacy Policy ("Policy") is issued by Win77, the operator of the online gaming platform located at win77.casa ("the Platform", "Win77", "we", "us", "our"). It describes our practices regarding the collection, use, storage, disclosure, and protection of personal data belonging to users of our Platform ("you", "your", "Player", "Member", "Data Subject").

Win77 takes your privacy seriously. We operate within a framework of responsible data stewardship and are committed to handling personal information with transparency, integrity, and proportionality. This Policy applies to all personal data processed in connection with your registration, use of platform services, financial transactions, customer support interactions, and any other engagement with win77.casa.

This Policy should be read in conjunction with Win77's Terms & Conditions, which govern your use of the Platform and are incorporated herein by reference. In the event of any conflict between this Policy and the Terms & Conditions regarding data matters, this Policy shall prevail.

For the purposes of this Policy, the following terms shall have the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial data, and online identifiers such as IP address or device ID.
• "Processing" — any operation or set of operations performed on personal data, including collection, recording, storage, use, disclosure, transmission, alteration, or erasure.
• "Data Controller" — Win77, being the entity that determines the purposes and means of processing your personal data.
• "Data Processor" — any third party that processes personal data on behalf of Win77 under a contractual arrangement and subject to Win77's instructions.
• "Data Subject" — the natural person whose personal data is being processed (i.e., you, the Player or user of win77.casa).
• "Consent" — freely given, specific, informed, and unambiguous agreement by which you, as the Data Subject, signify your acceptance of the processing of your personal data.
• "Cookie" — a small data file placed on your device by a website to store information about your session, preferences, or behaviour on that site.
• "KYC" — Know Your Customer. The identity and address verification process undertaken by Win77 in accordance with applicable anti-money laundering and anti-fraud obligations.

Win77 collects personal data that is necessary and proportionate to operating a regulated online gaming platform. The categories of data collected are set out in the table below.

Win77 collects personal data through the following means:

4.1 Direct Submission

Information you actively provide when you register an account, complete KYC verification, process a deposit or withdrawal, contact customer support, participate in a promotion, or complete any other form or interaction on the Platform.

4.2 Automated Technical Collection

When you access win77.casa, our systems automatically collect certain technical data, including your IP address, device identifiers, browser fingerprint, session timestamps, and navigation data. This data is collected through server logs, session cookies, and standard web analytics mechanisms.

4.3 Third-Party Sources

Win77 may receive personal data from third-party sources in specific circumstances, including:

• Payment service providers (e.g., DuitNow, FPX, Touch 'n Go eWallet, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Connect) for transaction verification purposes.
• Identity verification and anti-fraud screening services engaged by Win77 for KYC compliance.
• Marketing and referral partners, where you have been referred to Win77 and provided consent for data sharing at source.
• Public registers and regulatory databases, where required for anti-money laundering screening.

Win77 processes personal data only for specified, explicit, and legitimate purposes. The primary purposes and their corresponding legal bases are as follows:

• Account Management: Creating, operating, and maintaining your Player Account; authenticating your identity at login; processing account settings. Legal basis: Performance of contract.
• Payment Processing: Processing deposits, withdrawals, and account credits; reconciling financial records; detecting and preventing payment fraud. Legal basis: Performance of contract; legal obligation.
• KYC & AML Compliance: Verifying your identity and age; conducting anti-money laundering screening; complying with applicable regulatory requirements. Legal basis: Legal obligation.
• Platform Operations: Delivering game services; maintaining platform stability and security; diagnosing and resolving technical issues. Legal basis: Performance of contract; legitimate interests.
• Customer Support: Responding to enquiries, complaints, and support requests; maintaining records of support interactions. Legal basis: Performance of contract; legitimate interests.
• Responsible Gambling: Monitoring gambling patterns to identify potential problem gambling behaviour; administering deposit limits and self-exclusion tools. Legal basis: Legal obligation; legitimate interests; vital interests.
• Fraud Prevention & Security: Detecting and investigating suspicious account activity; protecting against unauthorised access. Legal basis: Legitimate interests; legal obligation.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates where you have provided consent or where permitted under applicable law. Legal basis: Consent.
• Analytics & Platform Improvement: Analysing aggregated user behaviour to improve platform performance, game selection, and user experience. Legal basis: Legitimate interests.

Win77 does not sell, rent, or trade your personal data. We share personal data only in the following limited and necessary circumstances:

6.1 Service Providers (Data Processors)

Win77 engages third-party service providers who process personal data on our behalf under strict contractual obligations, including data processing agreements that prohibit unauthorised use of your data. Categories of service providers include:

• Payment processing providers (DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Connect, cryptocurrency payment processors)
• Identity verification and KYC screening service providers
• Cloud infrastructure and data hosting providers
• Customer support software providers
• Cybersecurity and fraud detection service providers
• Platform analytics providers (processing anonymised or pseudonymised data only)

6.2 Legal & Regulatory Disclosure

Win77 may disclose personal data to competent authorities, law enforcement agencies, regulatory bodies, or courts where required to do so by applicable law, court order, or legitimate governmental request. In the event of a credible money laundering or fraud investigation, Win77 is legally obligated to cooperate fully with relevant authorities and may be prohibited from notifying the affected account holder (tipping-off restrictions).

6.3 Business Transfers

In the event that Win77 undergoes a merger, acquisition, restructuring, or sale of substantially all of its assets, personal data held by Win77 may be transferred to the acquiring or successor entity as part of that transaction. Affected players will be notified of any such transfer and the applicable privacy terms of the successor entity.

Win77 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or for as long as is required by applicable legal, regulatory, or contractual obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active Account plus five (5) years following Account closure, to comply with anti-money laundering record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification or Account closure, whichever is later, in accordance with applicable regulatory requirements.
• Financial Transaction Records: Retained for a minimum of seven (7) years from the date of the transaction, consistent with financial record-keeping obligations.
• Customer Support Records: Retained for three (3) years from the date of the interaction, unless ongoing proceedings require longer retention.
• Technical & Log Data: Retained for up to twelve (12) months from the date of collection, unless required for an active investigation.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be attributed to any identifiable individual.

Win77 uses cookies and similar tracking technologies to enable essential platform functions, maintain session security, and analyse aggregated usage patterns for platform improvement. We do not use third-party behavioural advertising cookies or cross-site tracking technologies.

8.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function. These enable session management, authentication state, security tokens, and fraud prevention. You cannot opt out of strictly necessary cookies without ceasing use of the Platform.
• Functional Cookies: Store your preferences, such as language settings, display preferences, and session configurations, to provide a more personalised experience across visits.
• Analytics Cookies: Collect anonymised or pseudonymised data about how players interact with the Platform — pages visited, features used, session durations — to help us improve platform design and performance. These do not identify individual users.

8.2 Managing Cookies

You may control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Please be aware that blocking functional or analytics cookies may affect your experience on win77.casa. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

As a Data Subject, you are entitled to the following rights in relation to your personal data held by Win77. To exercise any of these rights, please contact Win77 at [email protected] with the subject line "Data Rights Request". Win77 will respond within 30 calendar days.

If you are a parent or guardian and believe that a minor has submitted personal data to Win77 without your consent, please contact us immediately at [email protected] so that we may investigate and take appropriate action.

Win77's platform infrastructure and certain service providers may be located in jurisdictions outside Malaysia. Where personal data is transferred internationally, Win77 ensures that appropriate safeguards are in place to maintain a standard of protection consistent with applicable data protection requirements.

Safeguards for international transfers may include contractual data processing agreements incorporating standard data protection clauses, transfer to jurisdictions recognised as providing an adequate level of data protection, and technical and organisational security measures appropriate to the nature of the data transferred.

Win77 implements a layered approach to data security, combining technical, organisational, and procedural measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. Key measures include:

• TLS 1.2 / 1.3 encryption for all data in transit between your device and win77.casa
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records
• Two-factor authentication (2FA) available for all Player accounts
• Role-based access controls ensuring staff access personal data only where strictly necessary for their function
• Regular third-party penetration testing and vulnerability assessments
• Intrusion detection and prevention systems monitoring for anomalous access patterns
• Staff privacy and data security training programmes
• Data breach response plan with defined incident notification timelines

Win77 may send you promotional communications, including information about new games, upcoming tournaments, exclusive bonus offers, and platform updates. Marketing communications are sent only where you have provided consent or where applicable law permits direct marketing to existing customers.

You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link included in any Win77 marketing email.
• Updating your notification preferences in the Account Settings section of your Player dashboard.
• Contacting Win77 support at [email protected] with a clear opt-out request.

Please note that opting out of marketing communications will not affect essential transactional communications, such as deposit confirmations, withdrawal processing updates, KYC notifications, or security alerts. These communications are necessary for the operation of your Account and cannot be disabled.

Win77 reserves the right to update or amend this Privacy Policy at any time. Any changes will be published on this page with an updated effective date. Where changes are material — meaning they significantly affect how we collect or use your personal data — Win77 will notify registered Players by email or via a prominent in-platform notice at least 14 days prior to the changes taking effect.

Your continued use of win77.casa following the effective date of any amended Policy constitutes your acceptance of the revised terms. If you do not agree to a material change, you may request Account closure under Section 12.1 of the Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or Win77's data practices, please contact our Data Protection team through the following channels:

Please include your Account username, the nature of your request or concern, and any relevant details to help us process your enquiry efficiently. For account security reasons, Win77 may ask you to verify your identity before fulfilling certain data rights requests.