Privacy Policy — dsywin

dsywin ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all individuals who access and use the dsywin website at https://dsywin.cam and any associated services. This Privacy Policy ("Policy") sets out how dsywin collects, uses, stores, shares, and protects personal data, and describes the rights of data subjects with respect to their personal information.

This Policy applies to all Users of the Platform, including registered Account holders, prospective players who browse the Platform without registering, and any individual who contacts dsywin for support or other enquiries. This Policy should be read in conjunction with our Terms and Conditions, which govern the use of the Platform generally.

By accessing the Platform or creating an Account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue your use of the Platform.

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

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial information, and online identifiers.
• "Data Subject" — any individual whose personal data is collected, processed, or stored by dsywin in connection with their use of the Platform.
• "Processing" — any operation performed on personal data, including collection, recording, storage, modification, retrieval, use, disclosure, transmission, or erasure.
• "Data Controller" — dsywin, as the entity that determines the purposes and means of processing personal data submitted through the Platform.
• "Data Processor" — any third-party service provider engaged by dsywin to process personal data on its behalf and under its instructions.
• "KYC" — Know Your Customer procedures, comprising identity verification and anti-money-laundering checks required by dsywin's licensing obligations.
• "Cookie" — a small data file stored on a User's device by the Platform for the purposes described in Section 8 of this Policy.

dsywin collects the following categories of personal data, depending on how you interact with the Platform:

dsywin does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, or health information, unless such information is volunteered in the context of a responsible gambling self-assessment or similar welfare-related process.

Personal data is collected through the following means:

• Direct interactions: Data you provide when registering an Account, completing KYC verification, making deposits or withdrawal requests, contacting support, or participating in promotions.
• Automated technical collection: Data collected automatically as you navigate the Platform, including IP addresses, device identifiers, and session activity logs, primarily via cookies and similar tracking technologies.
• Payment processors: Financial transaction data shared with dsywin by payment service providers in connection with FPX bank transfers, DuitNow payments, e-wallet transactions (Touch 'n Go eWallet, Boost, GrabPay), or cryptocurrency deposits (BTC, ETH, USDT, BNB).
• Identity verification providers: Data returned from third-party KYC and fraud prevention service providers engaged by dsywin to verify the identity of registered Users.
• Publicly available sources: In limited circumstances, publicly available information may be used to supplement or verify the accuracy of data already held by dsywin in connection with fraud prevention or regulatory compliance.

dsywin processes personal data for the following specific purposes:

• Account creation and management: To register your Account, authenticate your identity at login, manage your Account settings, and maintain your betting and gaming history.
• Payment processing: To facilitate deposits and withdrawals via FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, and cryptocurrency channels, and to reconcile transaction records.
• KYC and age verification: To verify that all registered players are aged 21 or above and to satisfy our obligations under applicable anti-money-laundering and know-your-customer frameworks.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, money laundering, and other illegal activity on the Platform.
• Regulatory compliance: To comply with legal and regulatory obligations imposed by dsywin's licensing authority, including the retention of transaction records and the reporting of suspicious activity.
• Customer support: To respond to your enquiries, resolve disputes, process complaints, and provide you with assistance related to your Account and the services we offer.
• Platform improvement: To analyse anonymised or aggregated usage data for the purpose of improving Platform performance, user experience, and product development.
• Marketing communications: Where you have provided consent, to send you promotional offers, bonus notifications, and relevant updates regarding new games or features on dsywin. You may withdraw this consent at any time.
• Responsible gambling: To monitor gaming patterns for indicators of problem gambling behaviour and to administer responsible gambling tools including deposit limits, loss limits, and self-exclusion requests.

dsywin relies on the following legal bases for processing personal data:

• Contractual necessity: Processing required to perform our contractual obligations to you as a registered Account holder, including Account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC, anti-money-laundering obligations, and licensing conditions.
• Legitimate interests: Processing carried out in pursuit of dsywin's legitimate business interests, including fraud prevention, platform security, and product improvement — where such interests are not overridden by your rights and interests.
• Consent: Processing for purposes such as direct marketing communications, where your explicit consent has been obtained. Consent may be withdrawn at any time by contacting dsywin's support team.

dsywin does not sell, rent, or trade your personal data to third parties for commercial purposes. Personal data may be shared with the following categories of recipient only to the extent necessary for the purposes described in this Policy:

• Payment service providers: Banks and payment processors (including those facilitating FPX, DuitNow, and e-wallet transactions) receive financial data necessary to process your deposit and withdrawal requests.
• Identity verification providers: Third-party KYC service providers receive identity documentation submitted by Users solely for the purpose of identity and age verification.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on dsywin's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory requirement, dsywin may disclose personal data to competent authorities. We will notify Users of such disclosures to the extent permitted by law.
• Professional advisers: Legal, accounting, and audit firms who may require access to personal data in connection with their professional services to dsywin, subject to confidentiality obligations.

All third-party service providers with whom personal data is shared are required to implement appropriate technical and organisational security measures and to process data only in accordance with dsywin's instructions.

dsywin uses cookies and similar technologies on the Platform. Cookies are small text files stored on your device that help us deliver a functional and secure experience. The following categories of cookie are used:

dsywin does not use third-party advertising cookies or behavioural tracking cookies. You can manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair the functionality of the Platform, including the ability to log in to your Account.

dsywin retains personal data for no longer than is necessary for the purposes for which it was collected, subject to applicable legal and regulatory retention requirements. The following general retention periods apply:

• Account and transaction data: Retained for the duration of the Account's active period plus a minimum of five (5) years following Account closure, to satisfy anti-money-laundering and regulatory record-keeping obligations.
• KYC documentation: Retained for a minimum of five (5) years from the date of last transaction, in accordance with applicable financial regulation requirements.
• Support communications: Retained for up to three (3) years from the date of the last communication, for complaint handling and quality assurance purposes.
• Technical and log data: Retained for up to twelve (12) months, subject to security and fraud investigation requirements that may necessitate longer retention in specific cases.
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents reconstruction of identifying information.

dsywin implements a comprehensive suite of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform — the same encryption standard employed by Malaysian online banking services.
• Encryption at rest for sensitive personal data stored on dsywin's servers, including financial data and identity documents.
• Two-factor authentication (2FA) available to all Account holders as an additional layer of access security.
• Strict access controls ensuring that personal data is accessible only to authorised dsywin personnel who require it to perform their job functions.
• Regular security assessments, vulnerability testing, and penetration testing of Platform infrastructure.
• Staff training on data protection obligations and security best practices.

Notwithstanding these measures, no digital transmission or storage system can be guaranteed to be completely secure. In the event of a data security incident that is likely to affect your rights and interests, dsywin will notify you in accordance with applicable legal requirements and take prompt remediation action.

Subject to applicable data protection law and any overriding regulatory obligations, you have the following rights in respect of your personal data held by dsywin:

• Right of Access: You may request a copy of the personal data dsywin holds about you, along with information about how it is processed.
• Right of Rectification: You may request correction of any personal data that is inaccurate or incomplete.
• Right of Erasure: You may request deletion of your personal data in certain circumstances — for example, where it is no longer necessary for the purposes for which it was collected, subject to overriding legal obligations to retain data.
• Right to Restrict Processing: You may request that dsywin restrict the processing of your personal data in certain circumstances, such as while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request that dsywin provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your personal data where dsywin relies on legitimate interests as the legal basis, subject to dsywin's right to demonstrate compelling legitimate grounds for processing.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact our Data Privacy Team via the contact channels listed in Section 15. All requests will be acknowledged within 5 business days and substantively resolved within 30 calendar days, subject to verification of your identity.

The dsywin Platform is strictly intended for individuals aged 21 years or older. We do not knowingly collect personal data from individuals under the age of 21. If dsywin becomes aware that personal data has been submitted by or on behalf of an individual under the minimum age threshold, that data will be deleted and the associated Account closed immediately.

If you have reason to believe that a minor has created an Account or submitted personal data to dsywin, please contact our support team immediately so that appropriate action can be taken without delay.

dsywin's infrastructure and service providers may be located in jurisdictions outside Malaysia. Where personal data is transferred internationally, dsywin implements appropriate safeguards to ensure that such transfers are conducted in accordance with applicable data protection standards, including:

• Entering into data processing agreements with service providers that incorporate appropriate contractual protections for personal data.
• Transferring data only to countries or organisations that maintain data protection standards adequate to those applied by dsywin under this Policy.
• Applying additional technical and organisational measures where required to protect data in transit and at destination.

By using the Platform, you acknowledge that your personal data may be transferred and processed outside Malaysia. dsywin takes reasonable steps to ensure that any such transfers are handled responsibly and that your data receives equivalent protection regardless of where it is processed.

dsywin reserves the right to update or amend this Privacy Policy at any time. When material changes are made, the revised Policy will be published on the Platform with an updated "Last updated" date, and where required by applicable law, registered Users will be notified via in-Platform notification or email.

We encourage you to review this Policy periodically to stay informed about how dsywin handles your personal data. Your continued use of the Platform following the publication of any amended Policy constitutes your acceptance of the revised terms.

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

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the in-Platform chat function. Average response time: 3–5 minutes. For urgent data security concerns, Live Chat is the fastest route.
• WhatsApp: Available 24/7. Contact details available within your Account dashboard after login.
• Support Languages: English, Bahasa Melayu, and Chinese — all staffed around the clock.

For formal data subject rights requests (access, rectification, erasure, etc.), please use the email channel and include your full name and registered Account email address to facilitate identity verification. We will acknowledge your request within 5 business days.