Privacy Policy 2wiin –
Your Data, Our Responsibility

1Introduction

2wiin ("we", "Platform") is committed to protecting the privacy and security of all users' personal data. This Privacy Policy explains in detail how we collect, process, store and protect your personal information when you use 2wiin's services.

We comply with Malaysia's Personal Data Protection Act 2010 (PDPA) and relevant international data protection standards. If you have any questions about how we handle your data, our privacy team is ready to assist through the available support channels.

This policy applies to all users of the 2wiin platform — whether you access it via the website, iOS or Android mobile app, or any other digital channel we operate.

2Personal Data We Collect

2wiin collects your personal data through various means based on your interactions with the platform. The following are the types of data we collect:

3Purpose of Data Use

Your personal data is used by 2wiin solely for legitimate purposes necessary for platform operations. We do not use your data beyond the scope stated here:

• Verify your identity and process account registration, including KYC procedures required by legal compliance.
• Process deposits, withdrawals, and other financial transactions you make on the 2wiin platform.
• Provide gaming and betting services, including maintaining records of your gaming activity for historical and dispute purposes.
• Contact you regarding your account, security, service updates, and promotional information (subject to your preferences).
• Detect and prevent fraud, money laundering, and other illegal activities in line with our legal obligations.
• Comply with applicable legal requirements, regulations, and court orders governing platform operations.
• Improve the platform, analyse usage patterns, and develop new features based on user needs.

4Third-Party Disclosure

2wiin does not sell, rent or disclose your personal data to third parties for their own marketing purposes. However, we may share your data with certain parties under limited and controlled circumstances:

• Service Providers: Companies that help us operate the platform, such as cloud infrastructure providers, payment processors, and KYC service providers. They are bound by strict confidentiality agreements.
• Regulatory Authority: Regulatory bodies, law enforcement agencies or government authorities when required by law or court order.
• Game Partners: Our game partners may receive technical data required to ensure proper game functionality. This data does not include complete personally identifiable information.
• Business Transfers: In the event of any business merger or acquisition, user data may be transferred as part of the business assets, with prior notice given to users.

In all of the above situations, 2wiin ensures that data recipients comply with data protection standards equivalent to or higher than those we practise.

5Cookies and Tracking Technologies

The 2wiin platform uses cookies and similar tracking technologies to enhance your experience and maintain login session security. Below are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login verification and session security. These cookies cannot be disabled without affecting your use of the platform.
• Performance Cookies: Collect anonymous information about how you use the platform — pages visited, time spent, and any errors encountered. Helps us improve platform functionality.
• Preference Cookies: Save your preferences such as language, display settings, and game preferences so you don't have to set them again each time.

You can manage your cookie settings through your web browser. Disabling certain cookies may affect the functionality of some parts of the platform, but will not block your overall access to 2wiin.

6Data Security

We invest seriously in technical and organisational security to protect your personal data from unauthorised access, disclosure, alteration or destruction. Key security measures we practise:

• 256-bit SSL encryption for all data in transit between your device and our servers.
• Encryption of sensitive data such as financial information and identity documents at rest in the database.
• Role-based access control (RBAC) ensures that only staff who need to can access user data.
• Third-party security audits are conducted periodically to identify and address any vulnerabilities.
• 24/7 monitoring to detect suspicious activity or unauthorised access attempts.
• Regular staff training programmes to ensure all team members understand and adhere to best privacy practices.

While we take all reasonable steps to protect your data, no system is entirely risk-free. We encourage you to take personal precautions as well, such as using a strong password and not sharing your login details.

7Data Retention Period

2wiin retains your personal data for as long as necessary to fulfil the purposes described in this policy or as required by law. Generally:

• Active account data is retained for the duration your account is active, plus any legally required period following closure.
• Financial transaction records are retained for a minimum of 7 years in line with accounting and anti-money laundering legal requirements.
• Customer support communication logs are retained for 3 years from the date of the last interaction.
• KYC data is retained for 5 years after account closure or in accordance with longer regulatory requirements where applicable.
• Technical data and system logs are retained for 90 days before being automatically deleted.

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

8Your Rights

As a 2wiin user, you have the following rights regarding your personal data under Malaysia's PDPA and relevant data protection laws:

To exercise any of the rights above, contact our privacy team through 2wiin customer support. We will verify your identity before processing any request to ensure your security.

9Cross-Border Data Transfers

Some 2wiin platform operations involve service providers operating outside Malaysia. Such cross-border data transfers only occur when necessary and are always subject to adequate safeguards.

When your personal data is transferred outside Malaysia, we ensure that such transfers are protected by appropriate safeguard mechanisms — whether through standard data transfer agreements, recipient compliance verification, or other recognised legal mechanisms.

10Children's Privacy

The 2wiin platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we find that we have inadvertently collected data from an underage individual, we will take immediate steps to delete that data and close the account in question.

If you as a parent or guardian believe your child has provided personal information to us, please contact 2wiin customer support immediately so we can take the appropriate action.

11Privacy Policy Amendments

2wiin reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements or new platform features. All amendments will be published on this page with a revised update date.

For material amendments — meaning changes that significantly affect how we process your data — we will provide notice via your registered email or a prominent in-platform notification at least 14 days before the amendment takes effect. Continued use of the platform after notice is given is considered your acceptance of the amendment.

12Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or how we handle your personal data, please contact the 2wiin privacy and data protection team through the following channels: