Privacy Policy

1 Introduction

Winners33 ("we", "us", "our", "the Platform") operates the online casino and sports betting platform accessible at https://winners33.cam/ and all associated services. We are committed to safeguarding the privacy and personal data of every registered player and visitor to our platform.

This Privacy Policy ("Policy") describes the types of personal information we collect from users located in Malaysia and internationally, the purposes for which we process that information, the parties with whom we may share it, and the measures we take to keep it secure. It also sets out the rights you hold in relation to your personal data and explains how to exercise those rights.

By accessing the Winners33 platform, registering an account, making a deposit, or otherwise using our services, you acknowledge that you have read, understood, and accepted the practices described in this Policy. This Policy is to be read together with our Terms & Conditions.

2 Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information that identifies or can reasonably identify a natural person, directly or indirectly — including name, identification number, contact information, financial details, and online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transmission, alteration, and deletion.
• "Data Controller" means Winners33, the entity that determines the purposes and means of Processing Personal Data collected through the Platform.
• "Data Processor" means any third party that processes Personal Data on behalf of Winners33, subject to a written data processing agreement.
• "User" / "Player" / "you" means any individual who accesses or uses the Winners33 platform, whether as a registered account holder or as a visitor.
• "Cookies" means small text files stored on your device by the Platform to facilitate functionality and analytics.
• "KYC" means Know Your Customer — the identity verification process required to confirm a Player's identity and eligibility under anti-money laundering obligations.

3 Personal Data We Collect

Winners33 collects the minimum Personal Data necessary to deliver our services securely, comply with applicable legal obligations, and provide a personalised player experience. The categories of Personal Data we collect include:

Category	Examples	Purpose
Identity Data	Full name, date of birth, MyKad / passport number, nationality	Account registration, KYC verification, age eligibility (21+)
Contact Data	Email address, Malaysian mobile number, residential address	Account communication, support, security notifications
Financial Data	Payment method details (e-wallet ID, bank account, FPX reference), transaction history in MYR	Processing deposits and withdrawals, fraud prevention, AML compliance
Technical Data	IP address, device type, browser, operating system, session timestamps	Security monitoring, geographic access control, platform optimisation
Usage Data	Pages visited, games played, bets placed, session duration, click patterns	Service improvement, personalisation, responsible gambling monitoring
Communications Data	Live Chat transcripts, support ticket content, email correspondence	Support quality assurance, dispute resolution, compliance records
Marketing Preferences	Opted-in promotional subscriptions, preferred contact channel	Sending bonus offers and updates where consented

4 How We Collect Your Data

Winners33 collects Personal Data through the following channels and methods:

• Direct provision: Information you enter during account registration, KYC document upload, deposit and withdrawal requests, support interactions, and promotional opt-ins.
• Automated technologies: Cookies, web beacons, server logs, and analytics tools that record your technical and usage data as you interact with the Platform.
• Payment processors: Transaction data relayed to us by our approved Malaysian payment partners, including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and Hong Leong Bank.
• Third-party verification services: Identity and document verification providers engaged for KYC and anti-money laundering compliance checks.
• Fraud and security tools: Risk assessment and device fingerprinting services that help us detect unauthorised access and protect player accounts.

5 How We Use Your Data

Winners33 processes your Personal Data for the following clearly defined purposes:

• Account management: Creating and maintaining your Winners33 account, verifying your identity and age eligibility, and managing account security.
• Transaction processing: Processing MYR deposits and withdrawals via your chosen payment method — including e-wallets, DuitNow, FPX, and direct bank transfers.
• Legal compliance: Meeting obligations under applicable anti-money laundering (AML), counter-terrorism financing (CTF), and Know Your Customer (KYC) regulations, as well as responding to lawful requests from regulatory or law enforcement authorities.
• Customer support: Responding to enquiries, resolving disputes, and maintaining records of support interactions for quality assurance purposes.
• Platform improvement: Analysing aggregated usage data to improve game performance, navigation, and the overall player experience on Winners33.
• Responsible gambling: Monitoring betting patterns and usage behaviour to identify signs of problem gambling and to enforce self-imposed limits and exclusions.
• Marketing communications: Sending promotional emails, bonus notifications, and platform updates to players who have opted in. You may withdraw marketing consent at any time.
• Fraud prevention and security: Detecting and preventing fraudulent activity, multiple account creation, abuse of promotional offers, and unauthorised access attempts.

6 Legal Basis for Processing

Winners33 relies on the following legal grounds to process your Personal Data:

• Contractual necessity: Processing required to fulfil our obligations under the Winners33 Terms & Conditions — including account operation, transaction processing, and support provision.
• Legal obligation: Processing required to comply with applicable AML, KYC, and gaming regulatory requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and optional analytics, where you have provided freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Personal Data

Winners33 does not sell, rent, or trade your Personal Data to third-party marketers, data brokers, or advertising networks. We may share your data with the following categories of recipient only where strictly necessary:

• Payment service providers: Malaysian payment platforms (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong) require sufficient transaction data to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party services engaged to verify identity documents and check against sanctions and politically exposed person (PEP) lists for AML compliance.
• Game content providers: Certified gaming software providers whose games are hosted on the Winners33 platform may receive anonymised session data required for game functionality and RTP auditing.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity providers that support the technical operation of the Platform under strict data processing agreements.
• Regulatory and law enforcement authorities: Where required by law, court order, or a regulatory directive, Winners33 will disclose Personal Data to competent authorities. We will notify you of any such disclosure where legally permitted to do so.
• Professional advisers: Legal counsel, auditors, and compliance consultants acting in an advisory capacity, subject to professional confidentiality obligations.

8 Cookies & Tracking Technologies

Winners33 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and analyse platform performance. The cookies we use fall into the following categories:

• Strictly Necessary Cookies: Essential for the Platform to function — including login session management, security tokens, and fraud detection. These cannot be disabled without impairing core functionality.
• Performance and Analytics Cookies: Collect anonymised data on how Players navigate the Platform, which games are most popular, and where technical errors occur. This data is used solely to improve Winners33.
• Functionality Cookies: Remember your preferences such as language selection, display settings, and deposit method defaults to personalise your experience on return visits.
• Marketing Cookies (opt-in only): Where you have consented, these cookies enable us to deliver relevant promotional communications. They are not used for third-party advertising networks.

You may control and delete cookies through your browser's settings at any time. Note that disabling strictly necessary cookies will impair your ability to log in and use the Platform securely.

9 Data Retention

Winners33 retains Personal Data only for as long as is 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:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML regulations.
• Transaction records: Retained for a minimum of seven (7) years from the date of each transaction, as required for financial audit and AML compliance.
• Support and communications data: Retained for three (3) years from the date of the interaction, or longer where required for an unresolved dispute.
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier.
• Technical and usage data: Retained in aggregated or anonymised form for analytical purposes; individual-level records deleted after thirteen (13) months.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents re-identification.

10 Data Security

Winners33 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, loss, alteration, or disclosure:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the Winners33 platform.
• Encrypted storage of sensitive financial and identity data at rest, using industry-standard encryption algorithms.
• Strict access controls limiting staff access to Personal Data on a need-to-know basis, with all access activity logged and audited.
• Multi-factor authentication for internal staff systems handling player data.
• Regular penetration testing and vulnerability assessments by independent cybersecurity specialists.
• Incident response protocols to detect, contain, and notify affected users of any personal data breaches within required timeframes.

11 Your Data Rights

As a user of the Winners33 platform, you hold the following rights in relation to your Personal Data. To exercise any of these rights, please contact our support team via Live Chat or the email address set out in Section 15.

• Right to Access: You may request a copy of the Personal Data we hold about you at any time. We will respond within 30 days of a verified request.
• Right to Rectification: If any data we hold about you is inaccurate or incomplete, you may request that we correct it without undue delay.
• Right to Erasure: You may request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to Restrict Processing: You may request that we limit the processing of your data in certain circumstances, such as while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including for direct marketing purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: Where processing relies on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

We aim to respond to all data rights requests within 30 calendar days. Where requests are complex or numerous, we may extend this by a further 60 days with prior notice.

12 Minors and Age Restriction

The Winners33 platform is strictly for individuals aged 21 years and above. We do not knowingly collect Personal Data from persons under 21 years of age. If we become aware that Personal Data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

Parents and guardians who believe that a minor has registered on the Winners33 platform are encouraged to contact us immediately via Live Chat or the email address in Section 15 so that appropriate action can be taken without delay.

13 Third-Party Links and Services

The Winners33 platform may contain references or links to third-party services, including game content providers and payment platforms. These third parties operate under their own independent privacy policies, and Winners33 is not responsible for the privacy practices or content of those external parties.

When you interact with a payment service such as Touch 'n Go eWallet, Maybank, or CIMB to process a transaction, your interaction with those services is governed by their own terms and privacy notices. We encourage you to review the privacy policy of any third-party service you use in connection with your Winners33 account.

14 Amendments to This Policy

Winners33 reserves the right to update or amend this Privacy Policy at any time. Any changes will be published on this page with a revised effective date prominently displayed. Where changes are material, we will notify registered players via email or an in-platform notification prior to the changes taking effect.

Your continued use of the Winners33 platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to any amendment, please discontinue use of the Platform and contact us to arrange account closure and data removal.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the Winners33 Data Privacy team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly on the Winners33 platform. Support is available in English, Bahasa Melayu, and Mandarin. Average response time is 3–5 minutes.
• Email: [email protected] — please include "Privacy Request" in your subject line for priority routing.

For requests to exercise your data rights (access, erasure, portability, etc.), please provide your registered account username and a brief description of your request to help us process it efficiently. We may request identity verification before actioning sensitive data requests.

This Privacy Policy was last updated on 1 January 2026. All prior versions of this Policy are superseded by this document.