Win111 Privacy Policy
Your privacy matters to us. This Policy explains exactly what personal data Win111 collects, why we collect it, how we use it, and the rights you hold as a player on our platform.
How Win111 Protects Your Data
Six core data protection principles that underpin everything we do at Win111.
Encrypted at Every Step
All data transmitted between your device and Win111's servers is protected by 256-bit SSL/TLS encryption. Data at rest is stored using AES-256 encryption in access-controlled environments.
We Never Sell Your Data
Win111 does not sell, rent, or trade your personal information to third-party advertisers, data brokers, or any commercial entities outside the scope defined in this Policy.
Minimal Data Collection
We collect only the personal data that is strictly necessary for the purposes described in this Policy. We do not collect data speculatively or for undefined future uses.
Your Rights Are Respected
As a Win111 player, you hold clear rights over your personal data: access, correction, deletion, portability, and objection. These rights are described in full in Section 8 of this Policy.
Defined Retention Periods
We retain your data only for as long as is necessary to fulfil the purposes stated in this Policy or to comply with applicable legal obligations. Data is securely deleted or anonymised when no longer required.
Transparent Policy Updates
When we make material changes to this Privacy Policy, we will notify registered players by email or in-platform notification before the changes take effect, giving you the opportunity to review and respond.
Contents
- 1. Introduction
- 2. Definitions
- 3. Data We Collect
- 4. How We Collect Data
- 5. Purposes & Legal Bases
- 6. Data Sharing & Disclosure
- 7. Data Retention
- 8. Your Data Rights
- 9. Data Security
- 10. Cookies & Tracking
- 11. Children's Privacy
- 12. International Transfers
- 13. Third-Party Services
- 14. Policy Amendments
- 15. Contact & Complaints
1. Introduction
Win111 ("we", "us", "our", "the Platform") operates the online casino and sports betting platform accessible at win111.cam. We are committed to protecting the personal information of our registered players ("you", "your", "the Player") and all other individuals who interact with our platform.
This Privacy Policy ("Policy") explains how Win111 collects, uses, stores, shares, and protects your personal data in connection with your use of our website, mobile browser platform, customer support services, and all related features (collectively, the "Services"). It also sets out the rights you hold in relation to your personal data and how you may exercise them.
This Policy is supplemented by our Terms & Conditions, which govern the overall use of our Services, and our Responsible Gambling Policy. By using the Win111 platform, you confirm that you have read this Policy and agree to the data practices described herein.
Win111 acts as the Data Controller for the personal data collected through this platform. If you have any questions about this Policy or wish to exercise your data rights, please refer to Section 15 (Contact & Complaints) for the appropriate contact channels.
2. Definitions
The following definitions apply throughout this Privacy Policy:
- "Personal Data" means any information relating to an identified or identifiable natural person. This includes, but is not limited to, name, email address, date of birth, IP address, payment details, and account activity records.
- "Processing" means any operation performed on personal data, including collection, recording, storage, alteration, retrieval, use, disclosure, and deletion.
- "Data Controller" means the entity that determines the purposes and means of processing personal data. Win111 is the Data Controller for all personal data collected through this platform.
- "Data Processor" means any third party that processes personal data on behalf of Win111 under a documented contractual arrangement.
- "Consent" means freely given, specific, informed, and unambiguous agreement by the data subject to the processing of their personal data for a defined purpose.
- "KYC" means Know Your Customer — the identity and age verification process required before withdrawal processing.
- "Cookie" means a small data file placed on your device by a website for the purposes of tracking, analytics, or user preference management.
3. Data We Collect
Win111 collects the following categories of personal data:
3.1 Identity & Contact Data
- Full legal name
- Date of birth
- Residential address (including city — e.g., Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam)
- Email address
- Mobile phone number
- Government-issued identification number (where required for KYC verification)
3.2 Financial & Transaction Data
- Deposit and withdrawal records, including amounts, timestamps, and payment method references
- Bank account details, eWallet account identifiers (e.g., Touch 'n Go eWallet, Boost, GrabPay), or cryptocurrency wallet addresses used for transactions
- Account balance history and bonus records
3.3 Gaming Activity Data
- Game history including stakes, outcomes, and session durations
- Sports betting history including markets, odds, and settlement records
- Responsible gambling tool usage (deposit limits set, self-exclusion periods, session time limits)
3.4 Technical & Usage Data
- IP address and approximate geolocation
- Device type, operating system, browser type and version
- Session timestamps, pages visited, features used, and navigation patterns
- Error logs and crash reports
3.5 Communications Data
- Content of customer support interactions via live chat, email, and WhatsApp
- Records of complaints and dispute correspondence
- Marketing communication preferences and opt-in/opt-out records
| Data Category | Examples | Collected At |
|---|---|---|
| Identity & Contact | Name, date of birth, email, phone, address | Registration & KYC |
| Financial | Deposit/withdrawal records, payment method IDs | Each transaction |
| Gaming Activity | Game history, bet records, session data | During gameplay |
| Technical | IP address, device, browser, navigation logs | Each platform visit |
| Communications | Support chat logs, complaint records | When you contact us |
4. How We Collect Personal Data
Win111 collects your personal data through the following means:
- Direct Submission: When you register an account, submit KYC documents, make a deposit or withdrawal request, contact customer support, or subscribe to promotional communications.
- Automated Collection: Through cookies, web beacons, and server logs that capture your technical usage data during each session on the platform.
- Third-Party Sources: From identity verification providers, payment processors (including local Malaysian banking partners and eWallet providers), fraud detection services, and analytics partners, all of whom are contractually bound to data protection obligations.
- Public Sources: In limited circumstances, from publicly available sources for the purposes of fraud prevention or compliance checks.
5. Purposes & Legal Bases for Processing
Win111 processes your personal data on the following lawful bases and for the following stated purposes:
5.1 Contract Performance
Processing necessary to deliver the Services you have contracted for, including account management, processing deposits and withdrawals in MYR, providing access to games, and delivering customer support.
5.2 Legal Obligation
Processing required to comply with applicable legal and regulatory obligations, including Know Your Customer (KYC) identity verification, anti-money laundering (AML) monitoring, age verification (21+), and financial record-keeping obligations under the licensing requirements of our jurisdiction.
5.3 Legitimate Interests
Processing carried out for Win111's legitimate business interests where these interests are not overridden by your privacy rights, including:
- Fraud detection, abuse prevention, and platform security
- Platform performance analytics and product improvement
- Responsible gambling monitoring (detecting unusual patterns that may indicate problem gambling)
- Customer communications relating to account status or policy changes
5.4 Consent
Where you have provided explicit, opt-in consent, Win111 may process your data to send promotional emails, SMS notifications, or in-platform messages about bonuses, new games, and special offers. You may withdraw consent for marketing communications at any time by updating your account preferences or contacting our support team.
Win111 does not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects without human oversight, except as required by AML monitoring obligations.
6. Data Sharing & Disclosure
Win111 does not sell your personal data. We share your data only in the following limited and documented circumstances:
6.1 Service Providers (Data Processors)
We engage third-party service providers who process personal data on our behalf to support the delivery of our Services. These include:
- Payment processors and banking partners (including local Malaysian banks such as Maybank, CIMB, Public Bank, and Hong Leong; and eWallet providers including DuitNow, FPX, Touch 'n Go eWallet, Boost, and GrabPay)
- KYC and identity verification providers
- AML screening and fraud prevention services
- Cloud hosting and data storage providers
- Customer support platform providers
- Analytics and session recording tools (configured to anonymise IP addresses where possible)
All Data Processors are bound by written data processing agreements that restrict them from using your data for any purpose beyond the contracted service and require them to maintain appropriate security standards.
6.2 Legal & Regulatory Disclosure
Win111 may disclose your personal data to law enforcement agencies, regulatory bodies, or courts where we are legally compelled to do so by a valid legal order, court order, or statutory requirement. We may also disclose data where we reasonably believe disclosure is necessary to prevent financial crime, protect the safety of a person, or enforce our Terms & Conditions.
6.3 Business Transfers
In the event of a merger, acquisition, asset sale, or restructuring of Win111's business, your personal data may be transferred to the successor entity as part of that transaction. We will provide reasonable advance notice before your data is transferred and becomes subject to a different Privacy Policy.
7. Data Retention
Win111 retains your personal data for no longer than is necessary to fulfil the purposes for which it was collected or to comply with applicable legal and regulatory retention requirements. The following general retention periods apply:
| Data Type | Retention Period | Basis |
|---|---|---|
| Account & identity records | Duration of account + 5 years post-closure | Legal / AML obligation |
| Financial transaction records | 7 years from transaction date | Financial record-keeping law |
| Gaming activity logs | Duration of account + 2 years post-closure | Licensing compliance |
| KYC documents | 5 years from account closure or last transaction | AML regulatory obligation |
| Customer support records | 3 years from last interaction | Legitimate interest / dispute resolution |
| Marketing consent records | Until consent is withdrawn + 1 year | Proof of consent |
| Technical / session logs | Up to 12 months | Security & fraud prevention |
Upon expiry of applicable retention periods, data is securely deleted or irreversibly anonymised. Anonymised aggregate data (with no identifying information) may be retained indefinitely for statistical and analytical purposes.
8. Your Data Rights
As a Win111 player, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact our Data Protection team using the details in Section 15.
Right of Access
Request a copy of the personal data Win111 holds about you. We will respond within 30 days of a valid request.
Right to Rectification
Request correction of any inaccurate or incomplete personal data. Most account details can be updated directly in your profile settings.
Right to Erasure
Request deletion of your personal data where it is no longer necessary for the purposes collected and no legal retention obligation applies.
Right to Restriction
Request that we restrict processing of your data in certain circumstances, such as while a correction request is being reviewed.
Right to Portability
Request a machine-readable copy of the personal data you provided to us, where technically feasible, for transfer to another service provider.
Right to Object
Object to processing of your data based on legitimate interests. You may always opt out of marketing communications at any time.
Win111 will acknowledge all data rights requests within 5 business days and will fulfil valid requests within 30 calendar days. In complex cases where additional time is required, you will be notified of the extension and the reason for it. There is no charge for exercising your data rights in most circumstances.
9. Data Security
Win111 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. 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 at rest
- Two-factor authentication (2FA) available for all player accounts
- Role-based access controls limiting staff access to personal data on a need-to-know basis
- Regular security audits, penetration testing, and vulnerability assessments
- Intrusion detection systems and 24/7 security monitoring
- Formal data breach response procedures, including notification obligations
Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights or freedoms, Win111 will notify affected players without undue delay and in accordance with applicable legal notification requirements.
10. Cookies & Tracking Technologies
Win111 uses cookies and similar tracking technologies (including web beacons and local storage) to operate the platform, analyse usage, and deliver a personalised experience. The following categories of cookies are used:
- Strictly Necessary Cookies: Required for the platform to function. These cannot be disabled and do not require consent. Examples include session authentication cookies and security tokens.
- Functional Cookies: Remember your preferences such as language setting, display options, and responsible gambling tool configurations.
- Analytics Cookies: Collect aggregated, anonymised data about how users interact with the platform to help us improve performance and usability. These are deployed only with your consent where required.
- Marketing Cookies: Used to measure the effectiveness of promotional campaigns and to avoid showing you the same promotional message repeatedly. These are only activated where you have provided explicit consent.
You may manage your cookie preferences at any time through your browser settings. Disabling strictly necessary cookies may impair the functionality of certain platform features. Detailed cookie management instructions are available in your browser's help documentation.
11. Children's Privacy
Win111 is an adult entertainment platform. Access is strictly restricted to individuals aged 21 years and above. Win111 does not knowingly collect personal data from individuals under the age of 21. If you are a parent or guardian and believe that a minor may have registered an account or provided personal data to Win111, please contact us immediately using the details in Section 15. Upon receiving and verifying such a report, Win111 will take immediate action to delete the relevant account and all associated personal data.
Win111 employs automated age verification checks at registration and requires government-issued photo identification confirming date of birth as part of the KYC process before any withdrawal is processed.
12. International Data Transfers
Win111 may transfer your personal data to servers and service providers located in countries outside Malaysia. When such transfers occur, Win111 ensures that appropriate safeguards are in place to protect your data, including:
- Standard contractual clauses approved by recognised data protection authorities
- Data processing agreements with all third-party recipients
- Transfer impact assessments where required by the laws of the destination country
By using Win111's Services, you acknowledge that your personal data may be transferred to and processed in countries with data protection laws that may differ from those of Malaysia. Win111 takes all reasonable steps to ensure that such transfers are conducted lawfully and securely.
13. Third-Party Services & Links
The Win111 platform may reference third-party services such as payment processors, eWallet providers (including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, and FPX), and licensed game studio partners. When you interact with these services — for example, when initiating a deposit through a banking portal — you may be subject to that third party's own privacy policy and data practices.
Win111 is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services you use in connection with your Win111 account. Win111 only selects third-party partners who meet our contractual data protection standards, but we cannot guarantee the privacy practices of external entities beyond those contractual obligations.
14. Amendments to This Policy
Win111 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform functionality. When material changes are made, Win111 will:
- Update the "Last Updated" date at the top of this page
- Notify registered players via email or in-platform notification at least 14 days before material changes take effect
- Provide a summary of the key changes alongside the full updated Policy text
Your continued use of the Win111 platform following the effective date of any updated Policy constitutes your acknowledgement of the revised terms. If you disagree with any changes, you should stop using the Services and may request account closure in accordance with Section 13.2 of our Terms & Conditions.
15. Contact & Complaints
For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the Win111 Data Protection team through the following channels:
- Email: [email protected] — please include "Privacy Request" in the subject line
- Live Chat: Available 24/7 on the Win111 platform with an average response time of 3–5 minutes
- WhatsApp: Available in English, Bahasa Melayu, and Chinese. Contact number available upon request through live chat
Win111 aims to acknowledge all data privacy enquiries within 2 business days and to resolve requests fully within 30 calendar days. For complex requests, we will notify you of any extension to this timeline.
If you are not satisfied with Win111's response to your data privacy concern, or if you believe that your data rights have been violated, you may escalate your complaint to the relevant data protection supervisory authority in the jurisdiction in which Win111 holds its gaming licence, or to a consumer protection body applicable in your location.
Win111 takes all data privacy complaints seriously. Every complaint received is logged, investigated by a responsible team member, and responded to in writing. We do not dismiss or minimise privacy concerns — our commitment to player data protection is operational, not aspirational.
Your Data Is Safe With Us
Have a question about how we use your data? Our multilingual support team is available 24/7 in English, Bahasa Melayu, and Chinese. You can also read our FAQ for quick answers about your account and our platform.
For players aged 21 and above only. Please gamble responsibly. 21+