Privacy Policy Kuwin – Malaysia Member Personal Data Protection

1Introduction

Kuwin takes personal data protection responsibilities very seriously. This Privacy Policy describes our practices regarding the collection, use, storage, and disclosure of personal information you provide to us when using Kuwin's platform, website, and mobile app.

This policy applies to all registered members, website visitors, and anyone who interacts with the Kuwin platform in any capacity. By registering for or using Kuwin's services, you agree to the data protection practices described in this document.

Kuwin operates in accordance with the requirements of Personal Data Protection Act 2010 (PDPA) Malaysia and any applicable related laws or regulations in force. We are committed to ensuring your personal data is handled in a transparent, fair, and responsible manner.

2Information We Collect

Kuwin collects various types of information depending on how you interact with our platform. Below are the categories of data we process:

We only collect data that is genuinely necessary to provide our services, meet legal requirements, and improve the user experience. We do not collect additional sensitive data categories unrelated to platform operations.

3How We Use Your Data

The data we collect is used solely for legitimate purposes directly related to the provision of Kuwin's services. Data use includes:

• Account management: Account registration, identity verification, login processing, and ongoing account maintenance.
• Financial processing: Processing deposits, withdrawals, refunds, and maintaining transaction records for tax compliance.
• KYC & AML compliance: Identity verification before withdrawal and ongoing monitoring to prevent money laundering.
• Platform security: Fraud detection, prevention of unauthorized access, and protection against illegal activity.
• Customer support: Handles inquiries, complaints, and support requests you submit to us.
• Platform communications: Sends important notices regarding your account, service updates, and security information.
• Product improvement: Analyzes usage patterns to improve the interface, platform performance, and overall user experience.
• Marketing (with consent): Sends promotional information and exclusive offers if you have consented to receive marketing communications.

4Data Sharing and Disclosure

Kuwin does not sell, rent, or trade your personal data to third parties for their own marketing purposes. However, in certain limited situations, we may need to share your data with:

• Payment service providers: Banks, e-wallet operators, and payment processors required to complete your financial transactions.
• Game software providers: Providers such as Pragmatic Play and Evolution Gaming receive the minimum game data required to operate games within our platform.
• Legal authorities: When required by court order, regulatory investigation, or other legal obligation.
• Audit and security services: Third-party companies conducting security audits or compliance checks on our behalf, subject to strict confidentiality agreements.

All third parties receiving data from kuwin are bound by contractual agreements requiring them to protect that data to a standard equal to or higher than our own policy.

5Security & Data Protection

Kuwin continuously invests in security infrastructure to keep your personal data safe. The technical and organizational measures we implement include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and kuwin servers.
• At-rest encryption for all data stored in our database.
• Strict access controls — only authorized personnel can access user data, and only for legitimate work purposes.
• 24-hour system security monitoring with real-time threat detection.
• Regular security audits conducted by independent experts.
• Synchronised and redundant data backups to ensure continuous availability.
• Two-factor authentication (2FA) is available for all member accounts as an additional layer of protection.

While we implement all reasonable security measures, no system is completely immune. In the event of a material data breach involving your personal information, kuwin will notify you and the relevant authorities within the timeframe required by law.

6Data Retention Period

Kuwin retains your personal data only for as long as necessary to fulfill the purpose for which it was collected, or as required by law. Our data retention guidelines are as follows:

• Active account data: Retained for as long as your account remains active with Kuwin.
• Data after account closure: Basic records are retained for a minimum of 7 years to meet Malaysia's tax and financial legal requirements.
• KYC Records: Identity verification documents are retained for a minimum of 6 years after the end of the business relationship.
• Technical logs: Server logs and usage data are retained for 90–180 days depending on the type.
• Customer support communications: Conversation and inquiry records are retained for 3 years.

When data is no longer needed and the mandatory retention period has ended, Kuwin will securely delete or anonymise that data using industry-standard methods.

7Your Rights as a User

Under Malaysia's PDPA and our own policies, you have several important rights regarding your personal data. These rights may be exercised by contacting the Kuwin support team:

8Cookies & Tracking Technologies

The Kuwin website and app use cookies and similar tracking technologies to enhance the user experience and analyze platform performance. The types of cookies we use include:

• Essential cookies: Required for core platform functions such as login session verification. These cookies cannot be disabled.
• Preference cookies: Saves your settings and preferences such as selected language and display settings.
• Analytics cookies: Helps us understand how users interact with the platform for improvement purposes. This data is collected in aggregate and anonymized form.
• Security cookies: Helps detect and prevent fraudulent activity and unauthorized access.

You can manage cookie settings through your web browser preferences. However, disabling certain cookies may affect the functionality of some platform features. Use of the Kuwin mobile app is subject to a cookie policy consistent with web browser usage.

9Children's Privacy Protection

Kuwin Platform is exclusively for users aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18. If we discover that a minor's personal data has been collected without valid parental or guardian consent, we will promptly delete that data and close the relevant account.

10Amendments to This Privacy Policy

Kuwin reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform operations. Each version will state the latest update date at the top of the document.

When there are material changes to this Privacy Policy, we will notify you through the following means:

• In-platform notice the next time you log in.
• Email notification sent to the address registered to your account.
• Updates to this page will include a clear effective date.

Continued use of the Kuwin platform after those changes take effect will be deemed acceptance of the updated policy. If you do not agree with the changes, you are free to close your account and stop using the platform.