euwins Privacy Policy

1. Data Controller

1.1 The data controller responsible for your personal data is euwins, the operator of the online gaming platform accessible at euwins.app. References to "euwins", "we", "us", and "our" throughout this Policy refer to the same entity in its capacity as data controller.

1.2 If you have any questions or concerns about this Privacy Policy or about how euwins processes your personal data, you may contact our data protection team at [email protected] (plain text — not a clickable link).

2. Personal Data We Collect

2.1 Registration and Identity Data. When you open an euwins account, we collect your full legal name, date of birth, residential address, email address, and mobile phone number. This information is required to create your account and to fulfil our Know Your Customer (KYC) obligations under our gaming licence.

2.2 Identity Verification Documents. Before processing withdrawals or upon our internal risk trigger, euwins may request a copy of a government-issued identity document (national identity card, passport, or driver's licence) and a proof of address document (utility bill or bank statement dated within three months). Images of these documents are processed solely for identity verification purposes.

2.3 Financial and Transaction Data. We record all deposits, withdrawals, and in-platform transactions associated with your account. Payment method identifiers — such as the last four digits of a bank account or the registered mobile number of an e-wallet — are retained to facilitate withdrawals and to detect financial crime. Full payment credentials are never stored by euwins; these are processed directly by our licensed payment service providers.

2.4 Gaming Activity Data. We collect records of all bets placed, games played, session durations, and account balance movements. This data is used for account management, dispute resolution, regulatory reporting, and responsible gaming monitoring.

2.5 Technical and Device Data. We automatically collect IP address, browser type and version, operating system, device type, screen resolution, and session timestamps when you access the euwins platform. This data assists with fraud detection, security monitoring, and service optimisation.

2.6 Communications Data. We retain records of your communications with euwins customer support, including live chat transcripts and email correspondence. These records are used for quality assurance, dispute resolution, and staff training purposes.

3. How We Collect Your Data

euwins collects personal data through the following channels:

• Directly from you — via account registration forms, KYC document uploads, payment entries, and customer support interactions.
• Automatically — through server logs, cookies, and similar technologies when you access the euwins platform.
• From third-party service providers — including payment processors, identity verification services, and fraud detection partners, who may supply us with data necessary to complete transactions or verify your identity.
• From public sources — including sanctions lists and politically exposed persons (PEP) databases, which we are required to check as part of our anti-money laundering compliance programme.

4. Lawful Bases for Processing

4.1 euwins processes your personal data on the following lawful bases under applicable data protection law:

• Contractual necessity — processing required to perform our obligations under the Member agreement, including account management and transaction processing.
• Legal obligation — processing required to comply with our gaming licence conditions, anti-money laundering regulations, and tax reporting requirements.
• Legitimate interests — processing for fraud prevention, security monitoring, and platform improvement, where these interests are not overridden by your privacy rights.
• Consent — processing for optional marketing communications, where you have given specific and informed consent. You may withdraw this consent at any time.

5. How We Use Your Personal Data

euwins uses your personal data for the following purposes:

• Creating, maintaining, and administering your euwins account.
• Processing deposits, withdrawals, and other financial transactions in MYR.
• Verifying your identity and age in accordance with our licensing requirements.
• Detecting and preventing fraud, money laundering, and unauthorised account access.
• Providing customer support and resolving account disputes.
• Monitoring gaming activity for responsible gaming purposes and applying appropriate interventions where indicated.
• Complying with regulatory reporting obligations under our gaming licence.
• Sending transactional communications related to your account activity (e.g., deposit confirmations, withdrawal notifications).
• Sending promotional communications, where you have opted in to receive them.
• Improving the euwins platform through analysis of aggregated, anonymised usage data.

6. Disclosure to Third Parties

6.1 euwins does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes.

6.2 We may share your personal data with the following categories of third parties where necessary to deliver our services or meet our legal obligations:

• Payment service providers — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX partners, Maybank, CIMB, Public Bank, and Hong Leong — for the purpose of processing your financial transactions.
• Identity verification services — third-party KYC and AML screening providers engaged to assist with document verification and sanctions checking.
• Game content providers — licensed studios such as Evolution, Pragmatic Play, and PG Soft, which may receive session-level identifiers to facilitate gameplay and settle game outcomes.
• Regulatory and law enforcement authorities — where we are required by law, court order, or our licensing authority to disclose information.
• IT and infrastructure service providers — hosting, security, and analytics vendors who process data strictly on euwins's behalf under data processing agreements.

6.3 All third parties with whom euwins shares personal data are contractually obligated to process that data only for the specified purpose and to maintain appropriate security standards.

7. International Data Transfers

7.1 Some of the third-party service providers engaged by euwins operate from outside Malaysia. Where your personal data is transferred to a jurisdiction that may not provide the same level of data protection as Malaysia, euwins implements contractual safeguards — including standard data protection clauses — to ensure that your data remains protected in accordance with this Policy.

8. Data Retention

8.1 euwins retains your personal data for as long as your account is active and for a minimum period of five (5) years following account closure, or for such longer period as required by our gaming licence conditions, anti-money laundering regulations, or applicable law.

8.2 Gaming activity records and transaction logs are retained for a minimum of five (5) years to satisfy regulatory audit requirements.

8.3 Data held solely on the basis of your consent (such as marketing preferences) will be deleted within 90 days of consent being withdrawn, except where we are required to retain it for a longer period on another lawful basis.

8.4 When personal data is no longer required for any lawful purpose, it is securely deleted or anonymised in a manner that prevents re-identification.

9. Cookies and Tracking Technologies

9.1 euwins uses cookies and similar technologies (including local storage and session tokens) to operate the platform, maintain login sessions, remember your preferences, and gather aggregated analytics data. The following categories of cookies are used:

• Strictly necessary cookies — required for the platform to function, including session authentication and security tokens. These cannot be disabled without breaking core platform functionality.
• Functional cookies — used to remember your language and display preferences across sessions.
• Analytics cookies — used to collect anonymised data on how Members navigate the platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reporting.

9.2 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the euwins platform.

10. Security Measures

10.1 euwins implements technical and organisational security measures appropriate to the risk level of the data processed. These measures include TLS encryption for all data in transit, encryption of sensitive data fields at rest, role-based access controls limiting internal staff access to personal data, and regular third-party security audits of platform infrastructure.

10.2 Notwithstanding these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, euwins will notify affected Members and the relevant supervisory authority as required by applicable law.

11. Your Rights

Subject to applicable data protection law and our legal retention obligations, you have the following rights in respect of your personal data held by euwins:

• Right of access — to request a copy of the personal data we hold about you.
• Right of rectification — to request correction of any inaccurate or incomplete personal data.
• (Right to erasure — to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to restrict processing — to request that we restrict the processing of your data in certain circumstances.
• Right to data portability — to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to withdraw consent — to withdraw any previously given consent for optional processing (such as marketing emails) at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at [email protected]. We will respond to verified requests within 30 calendar days.

12. Children and Minors

12.1 The euwins platform is strictly intended for adults aged 21 and above. We do not knowingly collect or process personal data from individuals below the age of 21. If we become aware that a registered account belongs to a person below the minimum age, we will close the account and delete the associated personal data (subject to any legal retention obligation for fraud or compliance purposes).

12.2 If you believe that a minor has registered an euwins account, please notify us immediately at [email protected] so that appropriate action can be taken promptly.

13. Changes to This Policy

13.1 euwins reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered Members via email or a prominent platform notification not less than seven (7) days before the revised Policy takes effect.

13.2 Your continued use of the euwins platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of, and agreement to, the updated terms. If you do not agree with any changes, you may close your account by contacting support.

14. How to Contact Us

For any privacy-related queries, data subject requests, or concerns regarding how euwins handles your personal data, please contact our support team via live chat on the euwins platform, or by email at [email protected] (plain text — not a clickable link). Our team is available 24 hours a day, seven days a week.