Privacy Policy Winbox2 – Your Data, Our Responsibility

1 Introduction and Scope of This Policy

Winbox2 ("we", "Platform") takes seriously our responsibility to protect the privacy of every individual who uses our services. This Privacy Policy ("Policy") describes the types of information we collect from you, how it is used, with whom it is shared, and the steps we take to keep it secure.

This policy applies to all users of the winbox2 platform, including website visitors, registered members, and winbox2 mobile app users. It covers all your interactions with our platform — from browsing the website to financial transactions and gaming activity.

We comply with Malaysia's Personal Data Protection Act 2010 (PDPA), which governs how companies in Malaysia collect, store and process individuals' personal data. Any changes to relevant legislation will be reflected in updates to this Privacy Policy.

2 Types of Information We Collect

2.1 Information You Provide Directly

During the registration process and your use of the winbox2 platform, you provide us with the following information directly:

• Identity information: Full name as per official documents, date of birth, national identification card number or passport number.
• Contact information: Email address, mobile phone number, and current residential address.
• Financial information: Bank account details, e-wallet account numbers, and records of deposit and withdrawal transactions.
• Verification documents: Copies of identity documents, proof of address and other information submitted during the KYC process.
• Communications: Any messages, complaints or feedback you send to the winbox2 customer support team.

2.2 Information Collected Automatically

When you use the winbox2 platform, our systems automatically collect technical information to ensure the platform operates smoothly and securely:

• Device data: Device type, operating system, phone model, screen resolution, and unique device identifier.
• Network data: IP address, estimated geographic location, internet service provider (ISP) name, and connection type.
• Activity data: Pages visited, session duration, games played, bets placed, and interaction timestamps.
• Cookie and tracking technology data: Session information, user preferences and website analytics data.

3 How We Use Your Information

The personal data we collect is used for the following purposes, all of which are necessary to deliver a quality and secure winbox2 service:

Purpose of Use	Data Type	Legal Basis
Account registration and management	Identity, contact	Contract performance
Identity verification (KYC)	Identity, documents	Legal obligation
Processing deposits & withdrawals	Financial, identity	Contract performance
Fraud prevention & security	All categories	Legitimate interests
Customer support	Contact, communications	Contract performance
Marketing & promotions	Contact, activity	Your consent
Analytics & platform improvement	Technical, activity	Legitimate interests
Responsible gaming	Gaming activity	Legal obligation

Winbox2 will not use your personal data for any purpose other than those stated above without first obtaining your consent. Should we wish to use your data for a new purpose that differs from the original purpose of collection, we will inform you and seek your consent where required by law.

4 Sharing Information with Third Parties

Winbox2 does not sell, rent, or disclose your personal data to third parties for their own commercial purposes. However, there are certain situations where we need to share your information with others in order to provide winbox2 services:

4.1 Trusted Service Providers

We work with carefully selected third-party service providers to help us operate the platform, including payment providers and financial transaction processors, gaming platform and casino software providers, analytics companies that help us understand platform usage, and cloud service providers for secure data storage. All these service providers are bound by strict confidentiality agreements and may only use your data for the purposes we specify.

4.2 Legal Requirements

Winbox2 may be required to disclose your personal data to government authorities or law enforcement agencies when mandated by Malaysian law or a valid court order. This includes investigations related to fraud, money laundering, or other financial crimes. In such situations, we will comply with legal requirements while endeavouring to protect your privacy rights to the extent permitted.

5 Data Security and Protection Measures

Winbox2 continuously invests in cybersecurity infrastructure to ensure member personal data is always protected. The security measures we implement include:

• Encryption of data in transit: All data transmitted through the winbox2 platform is protected by TLS 1.3 protocol and 256-bit SSL encryption.
• Encryption of data at rest: Sensitive data stored in our databases, including financial information and KYC documents, is encrypted using the AES-256 algorithm.
• Strict access controls: Access to member personal data within winbox2's internal systems is restricted to staff with a legitimate business need only, and every access is logged for audit purposes.
• 24/7 monitoring: Our security monitoring system operates around the clock to detect and respond to any threats or unusual activity in real time.
• Regular security testing: Winbox2 conducts regular penetration testing and security audits by independent security experts to identify and address any vulnerabilities before they can be exploited.
• Two-factor authentication (2FA): Winbox2 offers 2FA options for all member accounts to add an extra layer of security to the login process.

While we take all reasonable steps to protect your data, no digital security system can be guaranteed 100% risk-free. In the event of a data breach involving your information, we will notify you within the timeframe required by applicable law and take immediate steps to contain and remediate the situation.

6 Use of Cookies and Tracking Technologies

The winbox2 platform uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions correctly. Cookies are small text files stored on your device when you visit our website.

6.1 Types of Cookies We Use

• Essential cookies: Required for core platform functions such as login authentication and session management. These cookies cannot be disabled without affecting platform functionality.
• Performance cookies: Collects information about how you use the platform to help us improve our services — for example, which pages are visited most frequently.
• Functional cookies: Saves your preferences such as language, region and display settings so you don't need to reconfigure them each time you log in.
• Analytics cookies: Used for internal analytics purposes to understand usage patterns and continuously improve the winbox2 platform.

You can manage or delete cookies through your web browser settings at any time. Please note that disabling certain cookies may affect the functionality and user experience of the winbox2 platform.

7 Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 and winbox2's policy, you have the following rights regarding your personal data:

To exercise any of the above rights, please contact the winbox2 data protection team via email or live chat. We will process your request within 30 business days of receipt. In complex situations, this period may be extended to up to 60 days, with notice provided to you.

8 Data Retention Period

Winbox2 retains your personal data only for as long as necessary to fulfil the purposes stated in this Privacy Policy or as required by applicable law. Our general data retention guidelines are as follows:

• Active account data: Retained for the duration your account is active and for 7 years after account closure to meet financial and legal compliance requirements.
• Financial transaction records: Retained for a minimum of 7 years from the transaction date, in line with Malaysia's anti-money laundering legal requirements.
• KYC documents: Retained for the period required by applicable law, typically 5 to 7 years after the business relationship ends.
• Support communication logs: Retained for 3 years for reference and quality control purposes.
• Cookie and analytics data: Session data expires automatically when you log out of the platform; aggregated analytics data is retained for 2 years.

Once the applicable retention period expires, your personal data will be securely deleted or anonymised so that it can no longer be linked to you personally.

9 Links to Third-Party Platforms

The winbox2 platform may contain links or integrations with third-party services such as payment service providers and partner gaming platforms. This Privacy Policy applies solely to the winbox2 platform and does not cover the privacy practices of those third parties.

Winbox2 is not responsible for the content, privacy policies, or practices of any third-party websites or services. We encourage you to read the Privacy Policy of each third-party platform you use in connection with winbox2 services to understand how they handle your personal data.

10 Child Protection

The winbox2 platform is strictly for individuals aged 18 and above. We do not intentionally collect any personal data from minors under the age of 18. Should we discover that we have collected personal data from someone under 18 without valid age verification, we will take immediate steps to delete that information from our systems and close the associated account.

If you believe a child has registered a winbox2 account without authorisation, please contact our support team immediately so that appropriate action can be taken.

11 Amendments to This Privacy Policy

Winbox2 reserves the right to amend this Privacy Policy from time to time to reflect changes in our practices, new legal requirements, or improvements in how we protect your data. Any material amendments will be communicated to members via an in-platform notice or email to your registered address at least 14 days before the changes take effect.

The last updated date of this Privacy Policy is always displayed at the top of this document. Your continued use of the winbox2 platform after any amendment takes effect will be considered your acceptance of the revised Privacy Policy.

12 Contact Us for Privacy Enquiries

If you have any questions, concerns, or wish to exercise any of your personal data rights, the winbox2 Data Protection Officer (DPO) team is ready to assist you. You can reach us via:

• Email: [email protected]
• Live chat: Available 24/7 on the winbox2 platform
• Customer support: Through the "Contact Us" section in the winbox2 app

We are committed to responding to all privacy-related enquiries within 5 business days. For formal personal data rights requests, the processing period is up to 30 business days.

If you are not satisfied with our response, you have the right to file a complaint with Malaysia's Department of Personal Data Protection (JPDP), the relevant regulatory body under the Personal Data Protection Act 2010.