Privacy Policy SureWin Bet – Malaysia Player Data Protection

This Privacy Policy describes the personal data collection and processing practices carried out by SureWin Bet ("we", "Platform") in relation to all users who access or use our website, mobile app, or any services we offer.

This Policy applies to all personal information you provide to us when registering, making deposits, using betting services, contacting our support team, or simply browsing the surewin bet platform.

By using our platform, you agree to the terms of this Privacy Policy. If you disagree with any part of this policy, please contact us or discontinue use of the platform. We always strive to ensure this policy is easy to understand for all Malaysian users.

We collect various categories of data depending on how you interact with the surewin bet platform:

We only collect data that is strictly necessary to provide our services. We do not collect sensitive data such as health information, religious beliefs, or political views unless required by applicable law.

The data we collect is used solely for the following purposes:

• Account management: Creating, verifying, and managing your member account at surewin bet.
• Transaction processing: Processing deposits, withdrawals, and all other financial activities securely and accurately.
• Legal compliance: Meeting KYC, AML (anti-money laundering), and other mandatory regulatory requirements.
• Platform security: Detecting and preventing fraud, illegal activity, or unauthorized access to your account.
• Service improvement: Understanding how users interact with the platform to improve the overall experience.
• Communication: Sending important notifications related to your account, security, and promotions (if you have consented).
• Customer support: Assisting in resolving inquiries, complaints, and technical issues you report.

We do not use your data for automated decision-making that could significantly affect you without appropriate human review.

Under Malaysia's PDPA, surewin bet processes your personal data on the following valid legal bases:

• Your consent – when you register and agree to our terms, you provide consent for us to process the data required to deliver our services.
• Contract performance – processing necessary to fulfil the agreement between you and surewin bet, such as payment processing.
• Legitimate interest – processing for platform security, fraud prevention, and service improvement purposes that do not infringe on your fundamental rights.
• Legal obligation – compliance with regulatory requirements, court orders, or directions from the relevant authorities.

Surewin bet does not sell or transfer your personal data to third parties for commercial gain. However, we may share your data in the following limited circumstances:

• Service providers: Third-party companies that assist us in operating the platform, such as payment processors, cloud service providers, and identity verification firms. All such vendors are bound by confidentiality agreements and may only use data for the purposes we specify.
• Legal requirement: When required by Malaysian law or a directive from a lawful authority, we may need to disclose certain information to regulatory bodies or law enforcement agencies.
• Interest protection: In cases involving fraud, crime prevention, or the protection of other users' safety, necessary information may be shared with the appropriate parties.
• Business transfers: In the event of a merger, acquisition, or asset sale involving surewin bet, user data may be transferred as part of that transaction, subject to equivalent privacy protections.

In all data sharing cases, we ensure that adequate protection standards are in place and that your data is not used for purposes beyond the stated scope.

Surewin bet continuously invests in security infrastructure to ensure your personal data remains protected at all times. Our technical and organisational security measures include:

• 256-bit SSL encryption for all data communications between your device and our servers.
• Encrypted password storage using irreversible hashing algorithms.
• Role-based access control (RBAC) ensuring staff can only access the data necessary for their specific duties.
• 24/7 security monitoring by automated threat detection systems and our internal security team.
• Regular security audits by independent auditors to identify and address system vulnerabilities.
• Two-factor authentication (2FA) available for all member accounts as an additional layer of protection.

While we take all reasonable precautions, no system is 100% immune to cyber threats. In the event of a data breach affecting you, we will notify you and the relevant authorities within the timeframe required by law.

We only retain your personal data for as long as necessary for the purposes stated in this policy or as required by law. The general principles we follow:

• Active account data: Retained for as long as your account is active and for an additional 7 years after account closure for legal compliance and financial accountability purposes.
• Financial transaction records: Retained for a minimum of 7 years in accordance with Malaysian financial law requirements.
• Customer support logs: Retained for 2 years after the case is resolved.
• Technical data and activity logs: Retained for 12 months for security and troubleshooting purposes.
• Marketing data: Retained until you withdraw consent or request deletion.

Once the retention period expires, data will be permanently deleted or anonymised using secure procedures.

Under Malaysia's PDPA and surewin bet's policy, you have the following rights regarding your personal data:

Surewin bet uses cookies and similar tracking technologies to enhance platform functionality and user experience. The types of cookies we use are as follows:

• Essential cookies: Required for core platform functions such as login, session management, and security. These cookies cannot be disabled.
• Performance cookies: Collecting information on how users engage with our platform to help us improve our services. All data is collected anonymously.
• Functionality cookies: Remembering your preferences such as language, display settings, and login details for a smoother experience.
• Analytics cookies: Helping us understand overall platform usage patterns through privacy-compliant analytics tools.

You can manage cookie settings through your web browser. However, disabling certain cookies may affect platform functionality. We do not use third-party advertising cookies that track your activity outside the surewin bet platform.

The surewin bet platform is strictly for users aged 18 years and above. We do not knowingly collect, process, or store personal data of individuals under the age of 18.

If we discover that personal data of a minor has been collected without our knowledge, we will take immediate steps to delete that data and close the associated account. Parents or guardians concerned about their child's use of the platform are encouraged to contact us without delay.

Surewin bet reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or technological developments. Any material amendments will be communicated to members via:

• Notices displayed on the platform's home page.
• Email to registered members (for significant changes).
• Updates the "Last Updated" date at the top of this page.

Continued use of the surewin bet platform after any amendments take effect constitutes your acceptance of the updated policy. We encourage you to review this page periodically.

If you have any questions, concerns, or complaints regarding how surewin bet handles your personal data, please contact our Data Protection Officer via:

• Live Chat: Available 24/7 directly on the platform – select the "Privacy & Data" category
• Email: [email protected] – state "Privacy Inquiry" in the email subject line
• Response time: Within 3 business days for general inquiries; 30 days for formal data rights requests

If you are not satisfied with our response, you have the right to file a complaint with the Department of Personal Data Protection under Malaysia's Ministry of Communications and Digital.