Privacy Policy Winnow44 — Your Privacy Preferences We

1Introduction & Scope of This Policy

Welcome to the winnow44 Privacy Policy. This document explains in detail how winnow44 ("we", "Platform" or "winnow44") collects, processes, stores and protects your personal data ("you" or "member") when you use our platform at winnow44.top.

This policy applies to all users who visit, register for, or use any service provided by winnow44, including casino games, sports betting, slots, the VIP programme, and all other features available on the platform. It also covers data collected through the winnow44 mobile app if you access it via your device.

Winnow44 is committed to complying with Malaysia's Personal Data Protection Act 2010 (PDPA) and relevant international data protection standards. We understand that your trust is our most valuable asset, and we do not take our responsibility to protect your privacy lightly.

2Personal Data We Collect

Winnow44 only collects data that is genuinely necessary to provide you with a safe, transparent, and satisfying service. We do not collect excessive or irrelevant information. Below are the categories of data we collect and their purposes:

We collect this data through several channels: information you provide directly during registration, data collected automatically as you use the platform, and in some cases, from legitimate third-party sources such as identity verification service providers for KYC purposes.

3How We Use Your Data

Every piece of data we collect has a clear and legitimate purpose. Winnow44 does not use your data for unrelated purposes without your consent. Here is how we use the data collected:

• Account management: Processing registration, verifying your identity through KYC, and maintaining your account securely.
• Transaction processing: Processing deposits and withdrawals accurately and promptly using your preferred payment method.
• Customer support: Providing assistance when you contact our support team, including resolving complaints and inquiries.
• Platform security: Detecting and preventing fraud, money laundering, unauthorised access and other suspicious activities.
• Service improvement: Analysing usage patterns in aggregate to improve platform features, speed and overall experience.
• Marketing communications: Sending information about promotions, bonuses and new offers — only if you have given your consent.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling and offering appropriate self-control tools.
• Legal compliance: Meeting reporting and compliance obligations to the relevant authorities as required by law.

The legal bases we rely on to process your data include the performance of a contract (to provide the services you request), legal obligations (for KYC and AML compliance), our legitimate interests (for platform security), and your consent (for marketing communications).

4Data Sharing & Disclosure

Winnow44 does not sell your personal data. Full stop. However, there are limited situations where we need to share data with certain parties in order to provide our services to you:

• Payment service providers: Required transaction details are shared with payment processors such as FPX, Touch 'n Go, GrabPay and Malaysian banks to process your deposits and withdrawals.
• KYC service providers: Your identity data may be processed by registered and certified third-party identity verification providers to verify the authenticity of your documents.
• Game software providers: Minimum required game data is shared with game platform providers for technical purposes and to ensure game integrity.
• Legal authority: We will disclose data to the relevant authorities such as the Royal Malaysia Police, Bank Negara Malaysia or other regulatory bodies when required by a valid court order or law.
• Professional advisors: Lawyers, accountants or auditors bound by professional confidentiality obligations in specific situations requiring expert advice.

All third parties who receive your data are required to comply with data protection standards equal to or higher than those of winnow44, and they are only permitted to process your data for purposes agreed upon contractually.

5Data Security Measures

Winnow44 continuously invests in the latest security infrastructure to ensure your personal data is protected against unauthorised access, loss, misuse, or disclosure. The technical and organisational security measures we implement include:

• Transit encryption: All communications between your browser and the winnow44 platform are secured by TLS 1.3 protocol with 256-bit SSL encryption — making interception by unauthorised parties virtually impossible.
• Storage encryption: Sensitive data, including financial information and identity documents, is stored in encrypted format within our databases.
• Role-based access control: Only staff with legitimate work requirements are granted access to member data, and all access is logged and monitored.
• Two-factor authentication: winnow44's internal systems are protected by multi-factor authentication to prevent unauthorised access even in the event of a password breach.
• Periodic security auditing: We conduct regular penetration testing and security assessments by independent third parties to identify and patch vulnerabilities.
• Real-time threat monitoring: Our intrusion detection system operates 24 hours a day to detect and respond to cyber threats as swiftly as possible.

While we take all reasonable precautions, no online system can be guaranteed 100% secure. We encourage you to also take responsibility for protecting your account by using a strong password, enabling two-factor authentication, and not sharing your login details.

6Cookies & Tracking Technologies

Winnow44 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored in your browser when you visit our website.

Types of cookies we use:

• Essential cookies: Required for core platform functions such as login verification, session management, and security. These cookies cannot be disabled as the platform will not function without them.
• Preference cookies: Saving your preferences such as language, display theme and other settings so you do not need to reconfigure them each time you log in.
• Analytics cookies: Helping us understand how users interact with the platform — which pages are visited most, how long users stay, and where they encounter issues. This data is used in aggregate form without identifying individuals.
• Security cookies: Used to detect suspicious activity, prevent fraud, and protect the integrity of your account.

You can manage and delete cookies through your browser settings. However, disabling certain cookies may affect the functionality and your experience on the winnow44 platform. We recommend keeping essential and preference cookies enabled for the best experience.

7Your Rights as a User

Under Malaysia's Personal Data Protection Act and the privacy principles we adhere to, you have the following rights regarding your personal data:

To exercise any of the above rights, contact the winnow44 data protection team via live chat or our support email. We will respond to your request within 30 business days. We may require identity verification before processing your request to ensure the security of your data.

8Data Retention Period

Winnow44 only retains your personal data for as long as necessary to fulfil the purposes stated in this policy or as required by applicable laws and regulations.

• Active account data: Retained for as long as your account is active and in use on the winnow44 platform.
• KYC records and financial transactions: Retained for a minimum of 7 years after the last transaction, in line with Malaysia's anti-money laundering legal requirements.
• Support communication logs: Retained for 3 years for reference and dispute resolution.
• Technical data and security logs: Retained for 12 months for fraud detection and platform security purposes.
• Marketing data: Retained until you withdraw your consent or request deletion.

When data is no longer needed and there is no legal obligation to retain it, winnow44 will securely delete or anonymise that data using industry-approved methods.

9Changes to This Privacy Policy

Winnow44 reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or improvements to the services we offer.

When we make material changes to this policy, we will:

• Updating the "Last Updated" date at the top of this page
• Sending a notification to your registered email address for significant changes
• Displaying a clear notice on the winnow44 platform within a reasonable timeframe

We encourage you to review this page periodically to ensure you are always informed of how we protect your data. Continued use of the platform after any changes are published constitutes your acceptance of the updated Privacy Policy.

10Contact Our Data Protection Team

If you have any questions, concerns or complaints regarding how winnow44 handles your personal data, or if you wish to exercise any of your privacy rights, we are ready to listen and assist you.

You may reach the winnow44 data protection team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the chat button at the bottom right corner of the platform
• Support Email: [email protected] — response within 24–48 business hours
• Help Centre: Visit the page FAQ us for answers to frequently asked questions about privacy and security

Winnow44 is committed to handling all privacy complaints seriously and transparently. If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia or the relevant regulatory body.

This Privacy Policy was last updated in January 2026 and supersedes all previous versions of the winnow44 Privacy Policy. This document forms part of the overall winnow44 privacy compliance framework together with Terms and Conditions and Responsible Gaming Policy us.