my3win Privacy Policy

1. Who We Are

This Privacy Policy ("Policy") is issued by my3win ("the Company", "we", "us", "our"), the operator of the online gaming platform accessible at my3win.co (the "Platform"). This Policy describes how my3win collects, processes, stores, shares, and protects personal data relating to registered Members and visitors to the Platform.

This Policy applies to all personal data processed in connection with your use of the my3win Platform, including data collected during account registration, gaming activity, payment transactions, customer support interactions, and your use of the my3win website and any associated mobile interfaces.

By registering an account on my3win, by continuing to use the Platform following the posting of a revised version of this Policy, or by otherwise interacting with us, you confirm that you have read and understood this Policy and you consent to the processing of your personal data in the manner described herein.

2. Personal Data We Collect

my3win collects only the personal data that is necessary to provide the Platform's services, comply with legal obligations, and protect the integrity of the gaming environment. The categories of personal data we may collect include:

2.1 Identity Data

• Full legal name (as it appears on your national identity card or passport)
• Date of birth (used for age verification — you must be 21 or older)
• National identification number (MyKad number) or passport number, where provided for KYC purposes
• Nationality and country of residence

2.2 Contact Data

• Malaysian mobile phone number (primary account identifier)
• Email address (where provided)
• Residential address (where provided for KYC or withdrawal verification)

2.3 Financial Data

• Payment method type (e.g. Touch 'n Go eWallet, DuitNow, FPX, bank name)
• Transaction amounts, dates, and reference numbers
• Wallet balance and bonus credit history
• Bank account name and account number, where provided for withdrawal processing

2.4 Gaming Activity Data

• Game history, bet amounts, win/loss records, and session durations
• Sports betting selections, odds accepted, and settlement records
• Lottery number selections and draw results
• Bonus and promotion usage history

2.5 Technical Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system, browser type and version
• Login timestamps, session durations, and access logs
• Cookie identifiers and similar tracking technology data (see Section 9)

3. How We Collect Your Data

my3win collects personal data through the following channels:

4. How We Use Your Personal Data

my3win uses your personal data strictly for the following purposes:

• Account management: Creating, maintaining, and securing your my3win account; authenticating your identity on each login; processing password resets
• Service delivery: Enabling access to games, processing bets, crediting winnings, and facilitating deposits and withdrawals
• Age and identity verification: Confirming that you are at least 21 years of age and verifying your identity in compliance with our KYC obligations
• Fraud prevention and security: Monitoring for suspicious activity, detecting duplicate accounts, preventing money laundering, and investigating abuse reports
• Responsible gaming: Monitoring gaming patterns to identify signs of problem gambling; implementing deposit limits, cool-off periods, or self-exclusion where indicated
• Legal compliance: Meeting obligations under applicable anti-money laundering (AML) frameworks, record-keeping requirements, and international gaming authority requirements
• Customer support: Responding to your enquiries, resolving disputes, and providing technical assistance
• Marketing communications: Sending promotional offers, bonus notifications, and product updates — only where you have consented to receive such communications
• Platform improvement: Analysing aggregated usage data to improve the my3win user experience, optimise navigation, and evaluate game performance

5. Legal Basis for Processing

my3win processes personal data on one or more of the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and my3win — i.e., operating your account and delivering gaming services
• Legal obligation: Processing required to comply with applicable laws, including AML obligations and age verification requirements
• Legitimate interests: Processing for fraud detection, security monitoring, Platform improvement, and responsible gaming monitoring, where these interests are not overridden by your data protection rights
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent — which you may withdraw at any time

6. Data Sharing & Disclosure

my3win does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Game studio providers: Licensed third-party game developers (e.g. Pragmatic Play, Evolution Gaming) receive pseudonymised player session data necessary to operate fair games and calculate outcomes
• Payment processors: Malaysian payment service providers (Touch 'n Go, DuitNow, FPX, Maybank, CIMB, Public Bank) receive transaction data necessary to process deposits and withdrawals
• KYC and identity verification providers: Third-party identity verification services that assist in confirming member identity and age
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory directive, my3win may disclose personal data to competent authorities
• Professional advisers: Lawyers, auditors, and insurers where necessary for the operation and protection of my3win's business, subject to confidentiality obligations

7. International Data Transfers

As my3win operates with game studio providers and technology partners located in various jurisdictions, personal data may be transferred to and processed in countries outside Malaysia. Where such transfers occur, my3win takes steps to ensure that appropriate safeguards are in place, which may include standard contractual clauses, data processing agreements with adequate data protection provisions, or transfers to jurisdictions recognised as providing an adequate level of data protection.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside your country of residence.

8. Data Retention

my3win retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention principles apply:

• Active accounts: Personal data is retained for the duration of your account with my3win and for a period of five (5) years following account closure, in compliance with AML record-keeping requirements
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship
• Transaction records: Retained for five (5) years from the date of the transaction
• Marketing data: Retained until you withdraw your consent or unsubscribe, after which it will be deleted within thirty (30) days
• Technical logs: Access logs and session data retained for ninety (90) days unless required for ongoing security investigations

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to an individual.

9. Cookies & Tracking Technologies

my3win uses cookies and similar tracking technologies on the Platform to provide core functionality, analyse usage, and — with your consent — deliver personalised content. The categories of cookies used are as follows:

You may manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies may affect the functionality of the Platform, including your ability to log in.

10. Your Data Rights

Subject to applicable law, you have the following rights in relation to your personal data held by my3win:

• Right of access: You may request a copy of the personal data we hold about you
• Right to rectification: You may request that we correct inaccurate or incomplete personal data
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the original purpose, subject to our legal retention obligations
• Right to restrict processing: You may request that we limit how we use your data in certain circumstances
• Right to data portability: Where processing is based on your consent or a contract, you may request your data in a structured, commonly used, machine-readable format
• Right to object: You may object to processing based on legitimate interests, including direct marketing
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing

To exercise any of the above rights, please contact us at the email address in Section 14. We will respond to all valid requests within thirty (30) calendar days. We may request proof of identity before processing your request.

11. Children's Privacy

The my3win Platform is strictly intended for adults aged 21 years and above. my3win does not knowingly collect personal data from persons under the age of 21. If we discover that personal data has been collected from a person under the age of 21, we will promptly close the associated account, delete the relevant personal data, and — where applicable — return or forfeit any funds in the account in accordance with our Terms & Conditions.

12. Security Measures

my3win implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• Hashed and salted password storage — plain-text passwords are never stored or accessible
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Multi-factor authentication for administrative access to data systems
• Regular security audits and penetration testing of Platform infrastructure
• Automated monitoring for unusual login activity and account access anomalies

While my3win takes all reasonable steps to secure your personal data, no online transmission or storage system can be guaranteed to be 100% secure. You are also responsible for maintaining the security of your own account credentials.

13. Policy Updates

my3win reserves the right to amend this Privacy Policy at any time. When material changes are made, we will post a notice on the Platform and update the "Last updated" date at the top of this document. Your continued use of the Platform following the posting of any revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how we handle your personal data.

14. Contact & Data Protection

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by my3win, please contact us through the following channels. Our team is available 24/7 via live chat on the Platform for urgent data matters.

Please include "Privacy Request" in the subject line of your email and provide sufficient detail for us to identify your account and the nature of your request. We aim to acknowledge all written privacy requests within five (5) business days and provide a full response within thirty (30) calendar days.