Interwin Privacy Policy – Malaysian Player Data Protection

1Introduction

Interwin ("we", "platform", or "Interwin") operates under the domain interwin.wine and provides online entertainment services to players in Malaysia. We take the privacy of our players' personal data very seriously.

This Privacy Policy explains how Interwin collects, uses, discloses, transfers, and stores your information when you use our platform — whether via web browser, mobile app, or any other access channel provided by Interwin.

This policy is prepared in accordance with Personal Data Protection Act 2010 (PDPA) Malaysia, which is the primary legislation governing the processing of personal data in a commercial context in Malaysia. Interwin is committed to complying with all provisions of the PDPA and internationally recognised data protection principles.

2Categories of Personal Data We Collect

Interwin collects various types of personal data depending on how you interact with our platform. The following are the main categories of data we may collect:

We do not collect sensitive data such as health information, criminal records, or religious beliefs unless specifically required by applicable Malaysian law.

3How We Collect Your Data

Interwin collects your personal data through several means:

• Directly from You: When you register an account, complete an identity verification form (KYC), make a deposit or withdrawal, contact customer support, or fill in a feedback form.
• Automatically: As you browse and use the Interwin platform, our systems automatically record technical data such as your IP address, device type, access time, and usage patterns via cookies and similar tracking technologies.
• From Third Parties: In certain cases, we may receive information from identity verification providers, payment processors (such as DuitNow, Touch 'n Go eWallet, and GrabPay providers), or regulatory authorities for legal compliance purposes.
• From Public Sources: For anti-money laundering (AML) compliance purposes, we may cross-check information against relevant public databases or sanctions lists.

4Purposes of Personal Data Processing

Interwin processes your personal data only for legitimate and necessary purposes. The following are the primary purposes of processing:

• Account Management: Registration, identity verification, login, and maintenance of your account profile.
• Transaction Processing: Processing deposits via DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, and FPX, as well as withdrawals to verified accounts.
• Service Delivery: Enable you to access and play all Interwin games, including Live Casino, slots, baccarat, blackjack, lottery, and Sports Betting.
• Legal Compliance: Meet our obligations under Malaysia's PDPA, anti-money laundering laws, and other regulatory requirements.
• Fraud Prevention: Detect and prevent fraudulent activity, multi-account use, and bonus system abuse.
• Service Communications: Send important account notifications, transaction confirmations, and policy updates.
• Marketing (With Consent): Send you relevant Interwin promotional offers and bonuses, provided you have given consent to receive marketing communications.
• Platform Improvements: Analyse usage patterns to improve overall design, performance, and user experience.
• Responsible Gambling: Monitor betting patterns to identify signs of problem gambling and trigger appropriate interventions when necessary.

5Data Sharing & Disclosure

Interwin does not sell or rent your personal data to any party. However, in certain limited circumstances, data may be shared with the following parties:

• Payment Service Providers: To process your deposit and withdrawal transactions via DuitNow, Touch 'n Go, GrabPay, FPX, Boost, and ShopeePay. Only the minimum required data is shared.
• Game Software Providers: Live casino, slots, and other game providers may receive the game session data required for technical operations – no unnecessary personal identity data is shared.
• Identity Verification Service Providers: Third parties engaged for KYC and age verification purposes, subject to strict confidentiality agreements.
• Regulatory Authority: When required by Malaysian law, a court order, or direction from a competent authority.
• Selected Business Partners: Only with your explicit consent and subject to a binding data protection agreement.

Any third party that receives your data through Interwin is required to uphold data protection standards equivalent to or higher than our own. We do not permit them to use your data for any purpose other than those specified.

6Data Security Measures

Interwin continually invests in security infrastructure to ensure our players' personal data is protected at all times. Key security measures we have implemented include:

• 256-bit SSL/TLS Encryption for all data in transit between your device and Interwin's servers.
• Encryption at rest for all sensitive data stored in our databases.
• Role-based access control ensuring that only authorised staff can access specific personal data — and only to the extent required for their role.
• 24/7 Threat Monitoring by our information security team using intrusion detection tools and advanced security analytics.
• Regular security audits by accredited independent parties to identify and address vulnerabilities in our systems.
• Staff Training – all Interwin staff who handle personal data receive comprehensive data protection training.

7Data Retention Period

Interwin retains your personal data only for as long as necessary to fulfil the purposes outlined in this policy, or as required by Malaysian law. General data retention guidelines:

• Active Account Data: For as long as your account remains active, plus any post-closure retention period required by law.
• Financial Transaction Records: Minimum 7 years after a transaction is made, in accordance with Malaysia's anti-money laundering and tax regulatory requirements.
• KYC & Identity Verification Records: Minimum 5 years after account closure.
• Customer Service Communication Logs: 2 years from the date of the last communication.
• Cookie & Analytics Data: Depending on the type of cookie – from a single session up to a maximum of 24 months.

Once the retention period expires, your personal data will be securely deleted or anonymised so that it can no longer be linked to you. We use certified data deletion software and procedures to ensure the process is secure and irreversible.

8Cookies & Tracking Technologies

Interwin uses cookies and similar tracking technologies to enhance your experience on our platform. The types of cookies we use are as follows:

You can manage your cookie settings through your web browser at any time. Please note that disabling certain cookies may affect the functionality of some parts of the Interwin platform. For more information on managing cookies in popular browsers such as Chrome, Safari, or Firefox, please refer to your browser's help documentation.

9Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 and international privacy principles, you have the following rights regarding your personal data held by Interwin:

To exercise any of the above rights, please submit a written request to support@interwin.wine by specifying the right you wish to exercise and providing sufficient information for us to identify your account. We will process your request within 30 days work.

10Children's Data Protection

The Interwin platform is strictly for individuals aged 18 and above. We do not knowingly collect, process, or store personal data from minors.

Should we discover that personal data belonging to an individual under the age of 18 has been collected without our knowledge, we will take immediate action to delete that data and close the relevant account.

If you believe that a child or minor under your care may have registered on the Interwin platform, please contact us at support@interwin.wine immediately and we will address the matter with the highest priority.

11Amendments to the Privacy Policy

Interwin reserves the right to amend this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or service improvements. When material amendments are made, we will:

• Updating the "Last Updated" date at the top of this document.
• Sending a notification to your registered email address.
• Displaying a clear notice on the Interwin platform when you log in.

We encourage you to review this Privacy Policy periodically. Continued use of the Interwin platform after any amendments take effect will be deemed acceptance of the updated policy.

12Contact Us & Privacy Complaints

If you have any questions, concerns, or complaints regarding how Interwin handles your personal data, please contact us via:

• Email: support@interwin.wine
• Live Chat: Available 24/7 via the chat icon at the bottom right corner of the Interwin platform
• Response Time: We aim to respond to all privacy enquiries within 3 business days, and data rights requests within 30 business days.

We will treat every complaint seriously and work to resolve it fairly and transparently. If you are not satisfied with our response, you have the right to lodge a complaint with Department of Personal Data Protection (JPDP) Malaysia, the regulatory body responsible for enforcing the PDPA in Malaysia.