Privacy Policy winrm — Data Protection & Member Information

1 Introduction

Winrm deeply values the trust you place in us when you register and use our online gaming platform. This Privacy Policy has been carefully crafted to clearly and transparently explain how we manage the personal information you share with winrm throughout your use of our services.

This document forms part of the overall agreement between you and winrm, and should be read alongside our Terms and Conditions and Responsible Gaming Policy. By using the winrm platform, you agree to the collection and use of your information as described in this Privacy Policy.

Winrm is committed to protecting your privacy at all times. We never sell or disclose your personal information to third parties without your consent, except in specific situations required by law or necessary to deliver our services to you.

2 Information Collected

Winrm collects your personal information from several sources to ensure our services operate smoothly, securely, and meet the needs of every member. The following are the categories of information we collect:

A. Information You Provide Directly

• Full name as shown on official identity document
• Date of birth and gender
• Email address and mobile number
• Residential address
• Account password (stored in encrypted form)
• Identity document information (MyKad, passport) for the KYC process
• Payment method information (bank account number, e-wallet)

B. Information Collected Automatically

• IP address and network information
• Device type, operating system, and browser version
• Login history and in-platform activity
• Cookie data and similar tracking technologies
• Game history and financial transactions
• Access time and location (based on IP)

C. Information From Trusted Third Parties

• Identity verification information from KYC service providers
• Payment processing data from trusted payment gateways
• Fraud prevention information from third-party security systems

Below is a summary of the types of data collected and their purposes:

3 How We Use Your Data

The data winrm collects is used solely for legitimate purposes directly related to the delivery of our platform services. We will not use your data for any other purpose without obtaining your consent first.

The primary uses of your data by winrm are as follows:

• Account management — Creates, verifies, and maintains your member account, including required KYC processes.
• Transaction processing — Manages your deposits, withdrawals, and financial transaction history securely and accurately.
• Service delivery — Enables access to all games, promotions, and platform features you use.
• Platform security — Detects and prevents fraud, hacking, account abuse, and activities that violate the Terms and Conditions.
• Legal compliance — Fulfills anti-money laundering (AML), counter-terrorism financing (CFT), and applicable regulatory requirements.
• Customer Support — Provides technical assistance and addresses your inquiries across all available support channels.
• Important communications — Sends security notifications, account updates, and relevant promotional information (you may opt out of marketing communications at any time).
• Platform improvement — Analyzes usage patterns in aggregate and anonymized form to improve the overall gaming experience.

4 Information Sharing

Winrm does not sell, rent, or disclose your personal information to third parties for their own marketing or commercial purposes. However, there are limited situations in which we may need to share your data with certain parties:

• Trusted service providers — Third parties we engage to support platform operations, such as payment processors (DuitNow, FPX, Touch 'n Go), KYC providers, and technology infrastructure. All such vendors are bound by strict confidentiality agreements.
• Regulatory Authority — When required by law or by the directive of a competent authority such as Bank Negara Malaysia, the Royal Malaysia Police, or a relevant government agency.
• Fraud prevention — With systems or industry bodies that help identify and prevent fraudulent activity across online gambling platforms.
• Business transfer — In the event of a merger, acquisition, or sale of winrm assets, user data may be transferred as part of that transaction with appropriate notice given to members.

In all of the data sharing situations above, winrm ensures that data recipients are bound by security and confidentiality standards equivalent to or stricter than those we uphold ourselves.

5 Data Security

Winrm invests seriously in cybersecurity infrastructure to keep your personal data safe from both external and internal threats. The security measures we have implemented include:

• 256-bit SSL/TLS encryption for all data communications between the platform and users
• Multi-layered firewall systems and intrusion detection (IDS/IPS) active 24/7
• Sensitive data encryption in the database using AES-256
• Role-based access control (RBAC) for winrm internal staff
• Regular security audits and penetration testing by independent experts
• Real-time suspicious activity monitoring system with automated alerts
• Regularly tested disaster recovery and data backup procedures

Although winrm takes every reasonable step to protect your data, no digital security system can be guaranteed 100% secure. You also play an important role in keeping your account safe by using a strong, unique password and never sharing your login credentials with anyone.

6 Cookies & Tracking Technologies

Winrm uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small data files stored on your device that help the platform remember your preferences and ensure certain functions run smoothly.

Types of cookies winrm uses:

• Essential Cookies — Required for core platform functions such as login sessions, security, and navigation. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies — Collects information on how members use the platform (pages visited, time spent) to help us improve our services.
• Functional Cookies — Saves your preferences such as language and display settings to deliver a more personalized experience.
• Security Cookies — Helps detect and prevent fraudulent activity and protects your account from unauthorized access.

You can control or block cookies through your browser settings. Please note that blocking certain cookies may affect the functionality or performance of the winrm platform. For more information on managing cookies, please refer to your browser's help documentation.

7 Your Rights as a Member

As a winrm member, you have certain rights regarding your personal information that we fully respect. These rights are as follows:

• Right to Access — You have the right to obtain a copy of the personal information we hold about you.
• Right to Rectification — You have the right to request correction of any information that is inaccurate or incomplete.
• Right to Erasure — You may request the deletion of your personal data, subject to applicable legal retention obligations.
• Right to Restriction of Processing — You may request that we restrict how we process your data in certain circumstances.
• Right to Data Portability — You have the right to receive your personal data in a machine-readable format for transfer to another service provider.
• Right to Object — You may object to the processing of your data for specific purposes such as direct marketing.
• Right to Withdraw Consent — You may withdraw consent you have previously given at any time without affecting processing that has already taken place.

To exercise any of the above rights, please contact the winrm Data Protection team via email at [email protected], stating the type of request. We will process your request within 14 working days and may require identity verification before processing certain requests.

8 Data Retention Period

Winrm retains your personal information for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law in Malaysia.

• Active account data — Stored for the duration of your active account and for the required period following account closure.
• Financial transaction records — Stored for a minimum of 7 years in accordance with anti-money laundering legislation and the Income Tax Act.
• KYC records and identity verification — Stored for 5 years after the business relationship ends or as required by regulatory obligations.
• Support communication logs — Stored for 3 years for record-keeping and dispute resolution purposes.
• Security log data — Stored for 12 months for the purposes of security incident investigation.

Once the relevant retention period has expired, winrm will securely delete or destroy your data using methods that ensure it cannot be recovered.

9 Third-Party Links & Services

The winrm platform may contain links to or be integrated with certain third-party services such as payment gateways, game providers, and identity verification systems. This Privacy Policy applies solely to the winrm platform and does not cover the privacy practices of any third party.

Although winrm carefully selects third-party partners and ensures they maintain adequate privacy standards, we are not responsible for the data collection practices carried out by those third-party entities on their own platforms. You are encouraged to read the privacy policy of each third party you interact with.

10 Amendments to the Privacy Policy

Winrm reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, technology used, legal requirements, or other operational reasons. Any material amendments will be communicated to you via your registered email or an in-platform notification at least 7 days before the amendments take effect.

The "Last Updated" date at the top of this document will always reflect the latest version of the Privacy Policy currently in effect. We recommend you review this page periodically. Continued use of the winrm platform after any amendments are published will be considered your acceptance of the updated policy.

11 Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or how winrm handles your personal data, our team is ready to assist you through the following channels:

• Support Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week
• Supported Languages: Bahasa Malaysia & English

Our Data Protection Team will endeavour to respond to all inquiries within 3 working days. For more complex requests such as data deletion or data portability applications, processing may take up to 14 working days.