QQWIN4D Privacy Policy

01 Introduction

This Privacy Policy (the "Policy") sets out how QQWIN4D (referred to herein as "QQWIN4D", "we", "us", or "our"), operating the online gaming platform accessible at qqwin4d.cam, collects, processes, stores, uses, and protects the personal data of individuals who visit, register on, or interact with our platform (referred to as "you", "your", "Player", or "User").

QQWIN4D has served Malaysian players since 2017. We understand that trust is fundamental to our relationship with every player across Kuala Lumpur, Petaling Jaya, Penang, Johor Bahru, Shah Alam, and the rest of Malaysia. This Policy reflects our genuine commitment to transparent, lawful, and fair handling of your personal information.

This Policy should be read in conjunction with our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated herein by reference.

02 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" — Any information relating to an identified or identifiable natural person. This includes, but is not limited to, name, identification number, email address, phone number, location data, and online identifiers.
• "Processing" — Any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction, whether carried out by automated or manual means.
• "Data Controller" — QQWIN4D, which determines the purposes and means of the processing of players' personal data.
• "Data Processor" — Any third party that processes personal data on QQWIN4D's behalf, such as payment service providers, KYC verification partners, and cloud hosting providers.
• "Consent" — Any freely given, specific, informed, and unambiguous indication of a data subject's agreement to the processing of their personal data.
• "KYC" — Know Your Customer; the identity verification process applied to players for age verification, fraud prevention, and anti-money laundering compliance.
• "Cookies" — Small text files placed on your device by the Platform for session management, analytics, and functional purposes.

03 Personal Data We Collect

QQWIN4D collects the following categories of personal data in the course of operating the platform and delivering our services to registered players:

We do not knowingly collect sensitive personal data (such as racial or ethnic origin, religious beliefs, or health data) except where strictly required by applicable legal or regulatory obligations, such as responsible gambling programme administration.

04 How We Collect Your Data

QQWIN4D 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 update your account settings.
• Automated technical collection: Our platform automatically collects technical data when you access QQWIN4D, including IP address, browser information, device identifiers, and session behaviour data through cookies and server logs.
• Payment processors: When you transact using Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, or other payment providers, limited transaction confirmation data is shared with us by those processors.
• Third-party KYC partners: Identity verification services may return verification results to QQWIN4D following document checks conducted on our behalf.
• Publicly available sources: In limited circumstances, we may verify information against publicly available government or regulatory databases for anti-money laundering compliance purposes.

05 Purposes of Data Processing

QQWIN4D processes your personal data for the following specific and legitimate purposes:

• Account management: Creating, maintaining, and administering your QQWIN4D player account, including authentication and security management.
• Service delivery: Providing access to all games, betting markets, live casino services, and other features of the QQWIN4D platform.
• Payment processing: Facilitating MYR deposits and withdrawals via verified Malaysian payment channels, reconciling transactions, and maintaining accurate financial records.
• Identity verification (KYC): Verifying your identity and age (21+ requirement) prior to processing withdrawals and where otherwise required for compliance purposes.
• Fraud prevention & anti-money laundering: Monitoring transactions and account activity to detect and prevent fraudulent activity, unauthorised access, and money laundering in compliance with applicable AML obligations.
• Responsible gambling: Administering self-exclusion requests, deposit limits, cool-off periods, and other responsible gambling tools; identifying accounts that may require intervention.
• Legal compliance: Meeting our obligations under applicable gaming regulations, financial legislation, and lawful demands from competent authorities.
• Customer support: Responding to your enquiries, resolving disputes, and maintaining records of communications for quality and training purposes.
• Platform improvement: Analysing aggregated usage data to improve platform performance, user experience, and game offerings.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates — only where you have provided consent or where permitted under applicable law. You may unsubscribe at any time.

06 Legal Basis for Processing

QQWIN4D processes your personal data on the following legal bases, depending on the nature and purpose of each processing activity:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you have entered into with QQWIN4D — including account management, game access, and payment processing.
• Legal obligation: Processing necessary to comply with applicable laws and regulations, including KYC identity verification, AML monitoring, and responses to lawful authority requests.
• Legitimate interests: Processing for fraud prevention, platform security, and business analytics, where such interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, certain cookie types, and any processing activities that are not covered by the above bases. Consent may be withdrawn at any time.

07 Data Sharing & Disclosure

QQWIN4D does not sell your personal data. We share your personal data only in the following limited and controlled circumstances:

• Payment service providers: Verified Malaysian payment partners — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX-connected banks (Maybank, CIMB, Public Bank, Hong Leong, RHB), and cryptocurrency channels (USDT TRC20, BTC) — receive the minimum data necessary to process your requested transactions.
• KYC and identity verification partners: Third-party KYC service providers receive your identification documents and related data solely for the purpose of verifying your identity and age.
• Technology and hosting providers: Cloud infrastructure, server hosting, and cybersecurity partners process data on QQWIN4D's behalf under binding data processing agreements.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory direction, QQWIN4D will disclose personal data to competent authorities. We will notify you of such disclosure where legally permitted to do so.
• Responsible gambling organisations: In limited circumstances, and only where required by our responsible gambling obligations or at your explicit request, anonymised or identifiable data may be shared with problem gambling support programmes.

All third-party data processors engaged by QQWIN4D are bound by contractual data processing agreements that require them to maintain appropriate technical and organisational security measures and to process data only in accordance with QQWIN4D's documented instructions.

08 Data Retention

QQWIN4D retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and regulatory obligations. Our standard retention periods are as follows:

• Account data and gaming records: Retained for the duration of your active account relationship with QQWIN4D, and for a period of five (5) years following account closure, to meet audit, legal, and dispute resolution requirements.
• Financial transaction records: Retained for a minimum of seven (7) years from the date of each transaction, in compliance with financial record-keeping obligations applicable to licensed gaming operators.
• KYC documents: Retained for the duration of account activity and for five (5) years post-closure, in compliance with AML and identity verification regulatory requirements.
• Customer support communications: Retained for three (3) years from the date of the final interaction, for quality assurance and dispute resolution purposes.
• Responsible gambling records: Self-exclusion and intervention records are retained for the full duration of any exclusion period plus five (5) years, to prevent re-registration in violation of exclusion conditions.
• Marketing consent records: Retained for the duration of the relationship and for three (3) years thereafter as evidence of consent or opt-out, as applicable.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with QQWIN4D's data destruction procedures.

09 Security Measures

QQWIN4D implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data stored in our databases;
• Two-factor authentication (2FA) available for all player accounts;
• Role-based access controls ensuring staff access only the data necessary for their specific function;
• Regular third-party penetration testing and security audits of our platform infrastructure;
• 24/7 automated intrusion detection and real-time threat monitoring;
• Strict data access logging and audit trails for all systems holding personal data.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, QQWIN4D will notify affected players without undue delay and will take all appropriate remedial action.

10 Cookies & Tracking Technologies

QQWIN4D uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device. We use the following categories of cookies:

You can manage cookie preferences through your browser's settings. Please note that disabling strictly necessary cookies will impair or prevent access to the platform. Most modern browsers allow you to view, manage, and delete cookies via the browser's privacy or security settings panel.

QQWIN4D does not use third-party advertising cookies or tracking pixels for behavioural advertising purposes.

11 International Data Transfers

In order to operate the QQWIN4D platform and deliver our services, your personal data may be transferred to, and processed in, countries outside of Malaysia. This may occur where our hosting infrastructure, KYC partners, or live casino studio operators are based outside Malaysia.

Where personal data is transferred internationally, QQWIN4D takes appropriate steps to ensure that such transfers are subject to adequate safeguards, including:

• Binding contractual data processing agreements incorporating appropriate data protection clauses;
• Transfer to jurisdictions recognised as providing an adequate level of data protection; or
• Other lawful transfer mechanisms applicable under the laws of the jurisdiction governing our operations.

QQWIN4D does not transfer personal data internationally beyond what is strictly necessary for operational and compliance purposes. Malaysian payment data is processed predominantly within Malaysia and its immediate financial processing infrastructure.

12 Your Data Rights

As a registered QQWIN4D player, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact our Data Support team at [email protected] with your registered email address and a description of your request. We will respond within thirty (30) days.

Please note that the exercise of certain rights may affect your ability to use the QQWIN4D platform. For example, requesting deletion of identity data will prevent us from maintaining your account in compliance with our KYC obligations. We will advise you of any such implications when responding to your request.

13 Minors & Age Verification

QQWIN4D's platform is strictly restricted to individuals who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21.

Where QQWIN4D discovers or has reasonable grounds to suspect that personal data belonging to an underage individual has been collected, we will:

• Immediately suspend the relevant account pending investigation;
• Erase the personal data of the underage individual to the extent legally permissible;
• Withhold and return any funds deposited by the account holder in accordance with our Terms;
• Take appropriate steps to prevent recurrence.

14 Amendments to This Policy

QQWIN4D reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements.

Where material changes are made to this Policy, we will notify registered players via email to their registered address and/or via a prominent notice on the QQWIN4D platform, at least fourteen (14) days prior to the changes taking effect, where reasonably practicable.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the QQWIN4D platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you should discontinue use of the platform and may request account closure in accordance with Section 11 of our Terms & Conditions.

15 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or QQWIN4D's data processing activities, please contact our team through the channels below. All data rights requests should include your registered email address and a clear description of your request.

For data rights requests specifically (access, rectification, deletion, portability), please use the subject line "Data Rights Request — [Your Registered Email]" when emailing us. We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days.