Privacy Policy — How winrm7 Collects, Uses & Protects Your Data

This Privacy Policy ("Policy") is issued by winrm7 ("winrm7", "we", "us", "our") and applies to all users ("Player", "User", "you") of the winrm7 online casino and sports betting platform, accessible at https://winrm7.cam/ and its associated mobile applications and services (collectively, the "Platform").

winrm7 is committed to processing personal data in a manner that is transparent, lawful, and consistent with the reasonable expectations of our users. We recognise that our players — whether based in Kuala Lumpur, Petaling Jaya, Penang, Johor Bahru, Shah Alam, or anywhere else in Malaysia — trust us with sensitive personal and financial information, and we take that responsibility seriously.

This Policy describes the categories of personal data we collect, the purposes for which we process it, the conditions under which we may share it, and the rights you hold in relation to your data. This Policy should be read in conjunction with our Terms & Conditions, which govern your use of the Platform overall.

In this Policy, the following terms shall have the meanings set out below:

• "Personal Data" — Any information that identifies or can be used to identify a natural person, directly or indirectly, including but not limited to a name, identification number, location data, or online identifier.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" — winrm7, the entity that determines the purposes and means of processing Personal Data collected on the Platform.
• "Data Processor" — A third party that processes Personal Data on behalf of winrm7 under written instructions and appropriate data processing agreements.
• "KYC" — Know Your Customer; the identity and age verification process conducted by winrm7 as part of account activation and withdrawal processing.
• "Cookies" — Small text files placed on your device by the Platform to enable functionality, analytics, and personalisation features.
• "Platform" — The winrm7 website, mobile application, and all associated digital services operated by winrm7.

winrm7 collects the following categories of personal data from registered players and Platform visitors:

winrm7 does not collect special categories of personal data (such as health information, racial or ethnic origin, or biometric data) except where strictly necessary for responsible gambling assessment purposes, in which case such data is handled with additional safeguards and explicit consent.

winrm7 collects personal data through the following channels:

• Direct Submission: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or submit any other form on the Platform, you provide personal data directly to us.
• Automated Collection: When you visit and interact with the Platform, we automatically collect Technical Data (including IP address, device identifiers, and session data) through server logs and cookies.
• Payment Processors: When you deposit via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, or cryptocurrency channels, our integrated payment processors may share transaction confirmation data with us for reconciliation and fraud prevention purposes.
• Third-Party Verification Services: We may receive identity verification data from licensed KYC and AML screening providers who cross-reference the information you supply during account registration.
• Publicly Available Sources: In limited circumstances and where legally permitted, we may supplement your profile with information from publicly available databases for fraud prevention or compliance purposes.

winrm7 processes personal data for the following defined purposes:

• Account Administration: To create, manage, verify, and maintain your winrm7 player account, including identity and age verification (21+ requirement) and KYC compliance.
• Service Delivery: To enable you to access and use all features of the Platform, including sports betting markets (Liga Super Malaysia, EPL, UFC, and others), live casino games, slot titles, and payment processing.
• Transaction Processing: To process deposits and withdrawals through your selected payment method (including Touch 'n Go eWallet, DuitNow, FPX, and bank transfers), and to maintain accurate financial records.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, multiple account creation, and other prohibited conduct on the Platform.
• Legal & Regulatory Compliance: To fulfil our obligations under applicable anti-money laundering, counter-terrorism financing, and data protection laws, including responding to lawful requests from regulatory or law enforcement authorities.
• Customer Support: To respond to your enquiries, resolve disputes, process complaints, and provide technical assistance through our 24/7 support channels.
• Responsible Gambling: To monitor gaming patterns, implement responsible gambling tools (deposit limits, self-exclusion, cool-off periods), and identify players who may be showing signs of problem gambling behaviour.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve Platform performance, design, game offerings, and overall user experience.
• Marketing & Promotions: To send you relevant promotional communications, bonus notifications, and personalised offers, subject to your marketing preferences and applicable consent requirements. You may opt out of marketing communications at any time.

winrm7 processes your personal data on the following legal bases, depending on the nature of the processing activity:

• Contractual Necessity: Processing necessary to perform our obligations under our Terms & Conditions, including account administration, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, and data retention obligations.
• Legitimate Interests: Processing conducted in furtherance of winrm7's legitimate business interests — such as fraud prevention, platform security, and service improvement — where such interests are not overridden by your rights and interests.
• Consent: Where required by applicable law, we will seek your explicit consent before processing personal data for specific purposes such as marketing communications or the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

winrm7 does not sell, rent, or trade your personal data to any third party. We may, however, share your personal data with the following categories of recipients where necessary and appropriate:

• Payment Processors: Including but not limited to Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and partner banking institutions (Maybank, CIMB, Public Bank, Hong Leong Bank), solely for the purpose of processing deposits and withdrawals in connection with your account activity.
• KYC & Compliance Providers: Licensed third-party identity verification and AML screening services engaged by winrm7 to fulfil regulatory verification obligations. These providers are contractually bound to process data only as instructed by winrm7.
• IT & Infrastructure Providers: Cloud hosting, database management, and cybersecurity service providers who process data on winrm7's behalf under strict data processing agreements and confidentiality obligations.
• Customer Support Platforms: Third-party live chat and helpdesk solutions used to deliver 24/7 support services. These providers access only the data necessary to resolve your support request.
• Regulatory & Law Enforcement Authorities: Where winrm7 is required by law, court order, or regulatory directive to disclose personal data, we will comply with such requirements. Where legally permitted, we will notify affected users of such disclosure.
• Professional Advisers: Lawyers, auditors, and compliance consultants engaged in the ordinary course of winrm7's business operations, subject to confidentiality obligations.

Any third party with whom winrm7 shares personal data is required to maintain appropriate technical and organisational security measures and to process the data only for the specified purposes described above.

winrm7 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without materially impairing Platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised data about how users interact with the Platform — including pages visited, time spent, and error occurrences — to help us improve Platform design and performance.
• Functionality Cookies: Store your preferences (such as language settings and responsible gambling limit configurations) to deliver a personalised experience across sessions.
• Marketing Cookies: Used to track your engagement with winrm7 promotional content across the Platform. These are only deployed with your consent and may be withdrawn at any time via your Account Settings or browser preferences.

You may control non-essential cookie usage through your browser settings. Note that disabling certain cookies may affect the availability or functionality of specific Platform features.

winrm7 retains personal data for only as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Our standard retention periods are as follows:

• Active Account Data: Retained for the duration of your account's active status on the Platform.
• Transaction & Financial Records: Retained for a minimum of five (5) years following each transaction, in accordance with applicable AML and financial record-keeping requirements.
• KYC & Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the last applicable transaction, as required by compliance frameworks.
• Customer Support Records: Retained for three (3) years following resolution of the relevant support interaction.
• Marketing Preferences & Consent Records: Retained for the duration of your account and for a minimum of two (2) years following any consent withdrawal, as evidence of your preferences.

Where personal data is no longer required for any lawful purpose, winrm7 will securely delete or anonymise it in accordance with our internal data lifecycle management procedures.

winrm7 implements comprehensive technical and organisational security measures to protect personal data against unauthorised access, loss, alteration, disclosure, or destruction. Our security programme includes:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and the winrm7 Platform is encrypted in transit using industry-standard TLS protocols.
• Encryption at Rest: Sensitive personal and financial data stored in our systems is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data access is restricted on a strict need-to-know basis, with role-based access controls and mandatory multi-factor authentication for internal staff.
• Fraud Detection Systems: Real-time multi-layer fraud monitoring identifies suspicious account activity, unusual transaction patterns, and potential account compromise attempts.
• Regular Security Audits: winrm7 conducts periodic internal security reviews and engages independent security consultants for vulnerability assessments.
• Incident Response: In the event of a personal data breach that poses a risk to your rights and interests, winrm7 will notify affected users promptly and take immediate remedial action.

Subject to applicable law, you hold the following rights in relation to your personal data processed by winrm7. To exercise any of these rights, please contact us at [email protected] with your full name, registered email address, and a description of your request. winrm7 will respond within 30 days of receipt.

The winrm7 Platform is strictly intended for adults aged 21 years and above. winrm7 does not knowingly collect, process, or store personal data from any individual under the age of 21.

During the account registration process, winrm7 requires users to confirm their date of birth and that they are at least 21 years of age. Where age cannot be verified, account registration will be declined. winrm7 further conducts age verification as part of its KYC process, which may require submission of a government-issued identification document (such as a Malaysian MyKad or passport).

If winrm7 becomes aware that personal data has been collected from an individual under 21 without parental or guardian consent, we will take immediate steps to delete such data and close any associated account. If you believe that a person under 21 has registered on winrm7, please contact us immediately at [email protected].

The winrm7 Platform may contain links to third-party websites or services, including but not limited to payment gateways and responsible gambling support resources. This Privacy Policy applies solely to data processed by winrm7 and does not extend to any third-party websites or services you may access via links on the Platform.

winrm7 has no control over the privacy practices or content of third-party websites and is not responsible for their data handling. We encourage you to review the privacy policies of any third-party service you interact with, particularly those through which you conduct financial transactions.

winrm7 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform functionality. When material changes are made, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered Players via email or in-platform notification.

Your continued use of the Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any amendment to this Policy, you must cease using the Platform and may request account closure in accordance with the procedures set out in our Terms & Conditions.

We recommend reviewing this page periodically — at minimum on a quarterly basis — to remain informed of how winrm7 handles your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by winrm7, please contact our Data & Privacy team through the following channels:

• Email: [email protected] (please include "Privacy Request" in the subject line)
• Live Chat: Available 24/7 directly within the winrm7 Platform
• Response Time: winrm7 aims to acknowledge all privacy-related requests within 3 business days and to resolve them within 30 calendar days

For requests to exercise your data subject rights (access, rectification, erasure, or portability), please provide your full name, registered email address, and a clear description of your request. Identity verification may be required before certain requests are actioned to protect against unauthorised access to your data.