Privacy Policy

This Privacy Policy (hereinafter "Policy") is published by Won99 (hereinafter "Won99", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at won99.cam (the "Platform"). This Policy governs the collection, use, storage, disclosure, and protection of personal data relating to registered users and visitors of the Platform (hereinafter "you", "Player", "User").

Won99 is committed to processing personal data responsibly and in accordance with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, accuracy, integrity, and confidentiality. This Policy is designed to provide full transparency about our data practices so that you can make informed decisions about the personal information you share with us.

By registering an account on Won99, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree to any part of this Policy, you should not use the Platform.

For the purposes of this Policy, the following definitions apply:

• Personal Data — Any information that can identify you directly or indirectly, including name, email address, phone number, date of birth, payment account details, IP address, device identifiers, and behavioural data.
• Processing — Any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• Data Controller — Won99, as the entity that determines the purposes and means of processing personal data collected through the Platform.
• Data Processor — A third party that processes personal data on behalf of Won99 under contractual instruction (e.g., payment processors, KYC verification providers).
• KYC — Know Your Customer, the identity verification process used to confirm a Player's identity, age, and payment method ownership.
• Cookies — Small text files placed on your device by the Platform to support functionality, session management, and analytics.
• Legitimate Interest — A legal basis for processing personal data where Won99 has a genuine business interest that is not overridden by the rights and interests of the data subject.

Won99 collects personal data through several channels: directly from you during registration and use of the Platform, automatically through technical means, and from third-party verification providers. The categories of data we collect are described below.

Won99 uses your personal data for the following purposes, each of which is tied to a defined legal basis described in Section 5:

• Account registration and management: Creating and maintaining your player account, authenticating login sessions, and managing account preferences.
• Identity verification (KYC): Verifying your identity and age to comply with anti-money laundering (AML) and responsible gambling obligations, and to prevent underage access to gambling services.
• Payment processing: Processing deposits and withdrawals via DuitNow, FPX, Touch 'n Go eWallet, Maybank, CIMB, Public Bank, Hong Leong Bank, Visa/Mastercard, and cryptocurrency channels.
• Customer support: Responding to enquiries, resolving complaints, and providing assistance via live chat and email.
• Fraud prevention and security: Detecting and preventing fraudulent activity, unauthorised access, money laundering, and abuse of promotional offers.
• Responsible gambling compliance: Monitoring player behaviour for indicators of problem gambling, enforcing deposit limits and self-exclusion requests, and conducting age verification checks.
• Platform improvement: Analysing usage patterns and technical performance to improve platform stability, user experience, and game library curation.
• Marketing communications: Where you have provided explicit consent, sending promotional emails, bonus notifications, and relevant product updates. You may withdraw this consent at any time by contacting support.
• Regulatory compliance: Meeting the reporting and record-keeping requirements of Won99's gaming licence and applicable financial regulations.

Won99 processes personal data on the following legal bases, consistent with internationally recognised data protection frameworks:

• Contractual necessity: Processing required to fulfil the contract between you and Won99, including account registration, payment processing, and game provision.
• Legal obligation: Processing required to comply with AML regulations, gaming licence conditions, KYC obligations, and applicable financial reporting requirements.
• Legitimate interests: Processing carried out for Won99's genuine business interests — including fraud prevention, platform security, and internal analytics — where such interests are not overridden by your privacy rights.
• Consent: Processing that relies on your freely given, specific, informed, and unambiguous consent, such as optional marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

Won99 does not sell personal data to any third party. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual data protection safeguards:

• Payment processors and financial institutions: To facilitate deposits and withdrawals via DuitNow, FPX, e-wallets, bank transfer, and cryptocurrency networks.
• KYC and identity verification providers: Third-party services used to verify identity documents, check age, and screen against AML watchlists.
• Game studios and content providers: To the extent necessary for game provision, session tracking, and fair-play certification. Data shared with game providers is limited to session identifiers and game-relevant parameters.
• Fraud detection and cybersecurity providers: Third-party services that assist with detecting suspicious activity, preventing account takeover, and ensuring platform security.
• Regulatory authorities and law enforcement: Where disclosure is required by the terms of Won99's gaming licence, court order, legal process, or applicable law. Won99 will notify you of such disclosure where legally permissible.
• Professional advisers: Including lawyers, auditors, and compliance consultants, bound by obligations of confidentiality.

Won99 operates internationally and may transfer personal data to, or store it in, countries outside Malaysia. This may include jurisdictions where the platform's servers, payment processors, or KYC verification providers are located.

Where personal data is transferred internationally, Won99 takes steps to ensure that appropriate safeguards are in place — including contractual data protection clauses, data processing agreements, and assessment of the recipient jurisdiction's data protection standards — before any transfer takes place.

By using Won99 and accepting this Privacy Policy, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Malaysia for the purposes described in this Policy.

Won99 uses cookies and similar tracking technologies to operate the Platform, maintain login sessions, monitor performance, and analyse user behaviour for the purpose of improving platform quality. The categories of cookies we use are:

• Strictly necessary cookies: Essential to the functioning of the Platform, including session management, login authentication, and security token verification. These cannot be disabled without impacting core platform functionality.
• Performance and analytics cookies: Used to collect aggregated, anonymised data about how players interact with the Platform — including page load times, navigation paths, and feature usage — to guide platform improvements.
• Functional cookies: Used to remember your preferences, such as language settings and display configurations, to provide a personalised experience.

Won99 does not deploy third-party advertising or social media tracking cookies on the Platform. You may manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform.

Won99 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable regulatory and legal obligations. The following general retention principles apply:

• Active account data: Retained for the full duration of the account's active status.
• Transaction and financial records: Retained for a minimum of five (5) years following account closure, to satisfy AML record-keeping obligations and potential audit requirements.
• KYC documentation: Retained for a minimum of five (5) years following account closure, in compliance with international gaming licence conditions.
• Customer support communications: Retained for three (3) years following the resolution of the relevant support interaction, or longer where a dispute remains unresolved.
• Marketing consent records: Retained for the duration of the consent period and for three (3) years following consent withdrawal, as evidence of consent management.

When personal data is no longer required, it is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

As a data subject, you have the following rights in relation to your personal data held by Won99. To exercise any of these rights, please contact our support team with your account details and the specific right you wish to invoke.

Won99 will respond to all verified data rights requests within 30 days of receipt. Where the complexity or volume of requests requires additional time, we will notify you within the initial 30-day period and provide an anticipated response date. Please note that certain rights may be limited where Won99 has an overriding legal obligation to retain or process the relevant data.

Won99 is strictly prohibited to persons under the age of 21. We do not knowingly collect personal data from individuals under the age of 21. If Won99 becomes aware that personal data has been collected from a minor without appropriate age verification having occurred, the relevant account will be suspended immediately, all associated data will be reviewed, and steps will be taken to delete or anonymise the minor's personal data as soon as practicable.

If you are a parent or guardian and believe that your child has registered on Won99 without your knowledge, please contact our support team immediately. We will investigate and take appropriate action without undue delay.

Won99 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encrypted storage of sensitive data at rest, including payment account identifiers and identity documents;
• Role-based access controls limiting data access to authorised personnel on a need-to-know basis;
• Regular internal security audits and vulnerability assessments;
• Two-factor authentication (2FA) available to all players for account login;
• Secure password hashing protocols — Won99 does not store passwords in plain text;
• Intrusion detection systems and real-time monitoring of access logs for suspicious activity.

While Won99 takes all reasonable precautions, no system is entirely immune to security risks. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, Won99 will notify affected individuals promptly in accordance with applicable obligations.

The Won99 Platform may from time to time contain references to third-party services or content providers — for example, game studio descriptions or payment method information. Won99 does not maintain external hyperlinks to third-party websites from the Platform and does not take responsibility for the privacy practices of any external organisations.

Where you access third-party services in connection with your use of Won99 (for example, completing a payment via your banking application or e-wallet), your interaction with those third-party services is governed by that third party's own privacy policy, and Won99 has no control over such third parties' data practices.

Won99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. When material changes are made, the "Last Updated" date at the top of this page will be revised accordingly.

We encourage you to review this Privacy Policy periodically to stay informed about how we manage your personal data. Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the revised terms.

Where changes are particularly significant — for example, a change to the categories of data we collect or the third parties we share data with — Won99 will take reasonable steps to notify active players directly via email or in-platform notification prior to the changes taking effect.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights described in Section 10, or have a concern about how Won99 has handled your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 directly within the Won99 platform. This is the fastest channel for urgent data concerns.
• Email: [email protected] — please include "Privacy Request" in your subject line and provide your registered account email and the nature of your request.

For all formal data rights requests, Won99 may require you to verify your identity before processing the request, to ensure we are responding to the legitimate account holder. Identity verification may involve confirming account details or providing a copy of an identity document.

Won99 aims to acknowledge all privacy-related enquiries within two (2) business days and to provide a full response within thirty (30) days of receipt, or sooner where the nature of the request permits. If your concern relates to responsible gambling or account closure, please also refer to our Responsible Gambling page.