winmry Privacy Policy

Section 1

1. About This Policy

This Privacy Policy ("Policy") applies to all personal data collected and processed by winmry in connection with the operation of the winmry platform, accessible at winmry.app. The Policy covers data collected from Members who register a winmry account, visitors who browse the platform without registering, and individuals who contact winmry's support team.

winmry is committed to handling personal data in a manner consistent with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, and integrity and confidentiality. winmry does not sell personal data to third parties for their own marketing purposes.

By accessing the winmry platform or registering a winmry account, you acknowledge that you have read and understood this Policy. If you do not accept the terms of this Policy, you must cease using the platform.

Section 2

2. Data We Collect

winmry collects personal data in the following categories, depending on your interaction with the platform:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification
• Date of birth (used for mandatory 21+ age verification)
• Email address and account username
• Residential address (required for Know Your Customer verification)
• Mobile phone number (used for 2FA and account security notifications)

2.2 Verification Documents

• Copy of government-issued photo identification (e.g., Malaysian MyKad, passport)
• Proof of address (e.g., utility bill or bank statement dated within 90 days)
• Proof of payment method ownership, where required for KYC compliance

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction history
• Payment method details (e-wallet identifiers, bank account references — winmry does not store full payment card numbers)
• Account balance history and bonus credit records

2.4 Gaming & Betting Activity

• Bet history, game session logs, and wagering records across all winmry products
• Responsible gaming tool settings (deposit limits, exclusion periods)
• Game preferences and platform navigation behaviour

2.5 Technical & Device Data

• IP address and approximate geographic location at the time of login
• Device type, operating system, browser type and version
• Session timestamps, duration, and interaction logs
• Cookie identifiers and analytics identifiers (see Section 6)

2.6 Communications Data

Content and metadata from support interactions via live chat, email, or any other communication channel with winmry's support or compliance teams, including records of complaints and dispute submissions.

Data Category	Collected At	Required?
Identity & Registration	Account signup	Mandatory
Verification Documents	KYC review / withdrawal	Mandatory
Financial & Transaction	Deposit / withdrawal	Mandatory
Gaming Activity	Ongoing platform use	Automatic
Technical & Device	Each session	Automatic
Communications	Support interactions	Where applicable

Section 3

3. How We Use Your Data

winmry uses the personal data it collects for the following purposes:

• Account Administration: Creating, managing, and maintaining your winmry account, processing deposits and withdrawals, and resolving account-related queries.
• Identity & Age Verification: Conducting mandatory KYC checks to verify that Members are aged 21 or above and to comply with applicable anti-money laundering obligations.
• Platform Security: Detecting and preventing fraud, unauthorised account access, multi-accounting, and other prohibited conduct. Monitoring for suspicious login activity and notifying Members of security events.
• Regulatory Compliance: Meeting obligations under international gaming licensing frameworks, anti-money laundering regulations, and data protection requirements applicable to the jurisdictions in which winmry operates.
• Customer Support: Responding to Member inquiries, processing complaints, and resolving disputes through winmry's internal dispute resolution process.
• Responsible Gaming: Monitoring gaming activity patterns to identify potential problem gambling behaviour and applying responsible gaming tools where appropriate. winmry may contact Members proactively where significant risk indicators are observed.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the winmry platform's performance, UX, and game library curation.
• Communications: Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about winmry offers relevant to your activity.

Section 4

4. Legal Basis for Processing

winmry processes personal data under the following legal bases:

• Contractual Necessity: Processing required to perform the winmry member agreement — including account management, transaction processing, and customer support.
• Legal Obligation: Processing required to comply with applicable KYC, AML, age verification, and regulatory reporting obligations.
• Legitimate Interests: Processing conducted in winmry's legitimate interests where these are not overridden by the Member's fundamental rights — including fraud prevention, security monitoring, and platform analytics.
• Consent: Where processing is based on consent (e.g., promotional communications), you may withdraw that consent at any time by contacting winmry support or updating your communication preferences in your account settings. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.

Section 5

5. Data Sharing & Third Parties

winmry does not sell, rent, or trade your personal data to third parties. winmry shares personal data with third parties only in the following circumstances:

5.1 Service Providers

winmry engages third-party service providers who process data on winmry's behalf, subject to binding data processing agreements. These include: KYC and identity verification providers, payment processing partners (including e-wallet operators such as Touch n Go and Boost), IT infrastructure and hosting providers, fraud detection and AML screening services, and customer support platform operators.

5.2 Game Content Providers

winmry's game content partners (including providers of live casino, slots, and sportsbook software) may receive pseudonymised gaming session data necessary for the delivery and settlement of their products. Game providers do not receive personally identifiable data beyond what is strictly necessary for game delivery.

5.3 Regulatory and Legal Disclosure

winmry may disclose personal data to regulatory authorities, law enforcement bodies, or courts of competent jurisdiction where required by applicable law, a valid legal order, or where winmry determines in good faith that disclosure is necessary to protect the rights, property, or safety of winmry, its Members, or the public.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of winmry's business or assets, Member personal data may be transferred to a successor entity. Members will be notified via the email address on record prior to any such transfer, with the opportunity to request account closure before the transfer takes effect.

Section 6

6. Cookies & Tracking Technologies

winmry uses cookies and similar tracking technologies to operate and improve the platform. The categories of cookies used are:

• Essential Cookies: Required for the platform to function — including session management, login state preservation, and security token maintenance. These cannot be disabled without disrupting platform functionality.
• Functional Cookies: Store your preferences such as language settings, preferred game categories, and responsible gaming tool configurations.
• Analytics Cookies: Used to collect anonymised, aggregated data about how Members navigate and use the winmry platform. This data is used solely to improve platform performance and UX — it is not used for individual profiling or sold to third parties.
• Security Cookies: Support fraud detection and suspicious activity monitoring, including device fingerprinting for the purpose of detecting multi-accounting.

You can manage non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of certain winmry features. winmry does not use third-party advertising cookies or cross-site tracking technologies for the purpose of serving targeted advertising outside the winmry platform.

Section 7

7. Data Retention

winmry retains personal data for as long as is necessary to fulfil the purposes described in this Policy or as required by applicable law. Specific retention guidelines include:

• Account and identity data is retained for the duration of your winmry membership and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping obligations.
• Transaction records are retained for a minimum of five (5) years following each transaction.
• KYC verification documents are retained for the legally mandated period applicable to the relevant regulatory jurisdiction, typically five (5) years.
• Support communications are retained for a period of three (3) years following the closure of each support interaction.
• Gaming activity logs are retained for five (5) years for regulatory reporting and dispute resolution purposes.

When data is no longer required for any legitimate purpose, winmry will securely delete or anonymise it in accordance with its internal data lifecycle procedures.

Section 8

8. Data Security

winmry implements a multi-layered security architecture to protect Member personal data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• Encryption in Transit: All data transmitted between your browser and the winmry platform is encrypted using 256-bit SSL/TLS — the same standard used by major Malaysian banking platforms including Maybank2u and CIMB Clicks.
• Encryption at Rest: Sensitive personal data fields, including identity documents and payment references, are encrypted at rest in winmry's database infrastructure.
• Password Security: winmry stores all Member passwords as one-way cryptographic hashes. Plaintext passwords are never stored or accessible by any winmry employee or system.
• Access Controls: Internal access to Member personal data is restricted on a strict need-to-know basis, with role-based access controls and audit logging applied to all privileged data access.
• Incident Response: winmry maintains a documented data breach response procedure. Where a breach poses a material risk to Members' rights, affected Members will be notified without undue delay.

Section 9

9. Your Rights

Subject to applicable data protection law, winmry Members have the following rights in relation to their personal data:

• Right of Access: You may request a copy of the personal data winmry holds about you.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to winmry's legal retention obligations.
• Right to Restrict Processing: You may request that winmry restrict its processing of your data in certain circumstances, such as while a data accuracy dispute is being resolved.
• Right to Data Portability: You may request your personal data in a structured, commonly used machine-readable format where technically feasible.
• Right to Object: You may object to processing carried out on the basis of legitimate interests. winmry will cease that processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact winmry's support team via live chat or by writing to [email protected]. winmry will respond to all data rights requests within a reasonable time period in accordance with applicable law. Identity verification may be required before winmry can action a data rights request.

Section 10

10. Children's Privacy

The winmry platform is strictly not intended for use by individuals under the age of 21. winmry does not knowingly collect personal data from persons under 21. If winmry determines that personal data has been collected from an individual below the minimum age requirement, that data will be deleted and the associated account closed immediately. If you have reason to believe that a person under 21 may have registered a winmry account, please contact the support team immediately at [email protected].

Section 11

11. Changes to This Policy

winmry reserves the right to update this Privacy Policy at any time. Where a material change is made — such as a change in the categories of data collected, a new purpose for processing, or a new category of third-party recipient — winmry will notify registered Members via the email address on file at least fourteen (14) days before the change takes effect.

The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of the winmry platform after the effective date of any amendment constitutes your acknowledgement of the revised Policy. We encourage you to review this page periodically to stay informed about how winmry handles your personal data.

Section 12

12. Contact Us

For questions, concerns, or data rights requests relating to this Privacy Policy or winmry's data practices, please contact the winmry Data & Privacy team through any of the following channels:

winmry Data & Privacy
Email: [email protected]
Live Chat: Available at winmry.app — 24 hours a day, 7 days a week
Average response time: 3–5 minutes via live chat; up to 2 business days via email for formal data requests