Privacy Policy 46phwin – How We Protect the Personal Data of Malaysian Players

1. Introduction & Scope of Privacy Policy

46phwin ("we", "the Company" or "the Platform") is committed to protecting the privacy of every individual who uses our services. This Privacy Policy explains how we collect, store, use, disclose, and protect your personal information when you use the 46phwin platform — including the website, mobile application, and all related services.

This policy applies to all users and members 46phwin in Malaysia, including active players, prospective members browsing our website, and former members whose records remain in our system. Continued use of the platform 46phwin by reading and understanding this Privacy Policy, you are agreeing to its contents.

This Privacy Policy should be read together with Terms & Conditions and Responsible Gaming Policy 46phwin which together constitute the entire agreement between you and us.

2. Data We Collect

46phwin collects various types of personal data depending on how you interact with our platform. The main categories of data we collect are as follows:

a) Identity Data

• Full name as stated on a valid government-issued identification document (MyKad or passport).
• Date of birth for age verification (18 years and above).
• National identification number (MyKad) or passport number.
• A valid Malaysian residential address.
• Gender (for the purpose of personalising your experience).

b) Contact Data

• An active Malaysian mobile phone number.
• An active email address that belongs to you.
• The username you chose during registration.

c) Financial Data

• E-wallet account details (Touch 'n Go eWallet, GrabPay, Boost, ShopeePay) — authentication tokens only, not passwords.
• Bank account details for FPX transactions (Maybank2u, CIMB Clicks) — only the bank name and masked account number are stored.
• Deposit and withdrawal transaction history in Malaysian Ringgit (MYR).
• Payment records and jackpot winnings.

d) Game Activity Data

• Gaming records — titles played, session duration, bet amounts and outcomes.
• History of bonuses and promotions claimed and used.
• Game preferences and personal account settings.
• Records of self-exclusions or limits set under the Responsible Gaming programme.

e) Technical & Usage Data

• IP address, device type, operating system, and web browser used.
• Cookie data and similar tracking technologies (see section 6).
• Access logs, session durations, and platform usage patterns.
• Approximate geolocation information (state/city level) for regional verification.

3. How We Use Your Data

The personal data you provide to 46phwin used for the following purposes:

For marketing communications such as bonus offers, Hari Raya promotions, or special jackpot deals, you may opt out at any time by clicking the "unsubscribe" link in any promotional email or by contacting our support team. 46phwin. Withdrawing consent for marketing communications will not affect your core platform services.

4. Legal Basis for Data Processing

46phwin processes your personal data on valid legal grounds under Malaysia's Personal Data Protection Act 2010 (PDPA). These grounds are:

• Consent: You provide explicit consent when registering with 46phwin and when opting in to receive marketing communications. This consent may be withdrawn at any time.
• Performance of Contract: Processing necessary to fulfil the agreement between you and 46phwin — including deposit processing, withdrawal of winnings, and provision of access to games.
• Legal Obligation: Processing required to fulfil 46phwin's legal obligations under Malaysian law, including KYC (Know Your Customer) and AML (Anti-Money Laundering) requirements.
• Legitimate Interest: Processing that is genuinely necessary for the safe and efficient operation of the platform, such as fraud prevention and system security analysis, where those interests do not override your fundamental rights and freedoms.

5. Data Sharing & Disclosure

46phwin does not sell, rent, or trade your personal data. However, in certain situations we may need to share your data with the following parties, solely to enable the platform to operate properly:

• Payment Processors: Local Malaysian payment service providers handling transactions for Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow and FPX. Data sharing is strictly limited to what is necessary to verify and process transactions.
• Game Providers: Companies such as Microgaming, NetEnt, Playtech, and Pragmatic Play may receive minimal game session data necessary to enable gameplay. They are bound by strict data protection agreements with 46phwin.
• Legal Authority: 46phwin may be required to disclose your data to Malaysian authorities (such as the police, the Companies Commission of Malaysia, or relevant regulatory bodies) when compelled to do so by law or a valid court order.
• Audit & Security Firms: Independent audit firms that verify the fairness of games and the security of the 46phwin platform may access system data (not personal data) within the scope of their audit mandate.

6. Cookies & Tracking Technologies

46phwin uses cookies and similar tracking technologies to enhance the user experience, maintain session security and analyse platform usage patterns. The cookies we use fall into the following categories:

• Essential Cookies: Required for the core functions of the 46phwin platform — including login verification, gaming session management, and security. These cookies cannot be disabled as they are essential for the platform to operate.
• Performance Cookies: Collects information on how visitors use the 46phwin platform — including the most frequently visited pages, time spent, and navigation paths. This data is used in aggregated, anonymised form to improve the platform.
• Functionality Cookies: Remembering your preferences such as interface language, favourite games and other personal settings on 46phwin. This enables a more personalised experience each time you log in.
• Analytics Cookies: Helping us understand overall platform performance and user engagement. All analytics data is kept in a non-personally identifiable form.

You can manage cookies through your web browser settings. However, disabling essential cookies may affect the functionality of the platform 46phwin and you may experience issues logging in or playing normally.

7. Data Security Measures

46phwin implements multiple layers of technical and organisational safeguards to protect your personal data from unauthorised access, loss, destruction, or accidental disclosure:

• Transmission Encryption: All data transmitted between your device and 46phwin's servers is protected by TLS 1.3 with AES-256 encryption.
• Storage Encryption: Sensitive data stored in 46phwin's databases is encrypted using industry-recognised algorithms.
• Two-Factor Authentication (2FA): Available to all 46phwin accounts as an additional layer of security beyond your standard password.
• 24/7 Security Monitoring: An automated threat detection system monitors 46phwin platform activity around the clock to identify any unauthorised access attempts or suspicious behaviour.
• Internal Access Controls: 46phwin staff access to user data is governed by the principle of least privilege, and all access is logged for audit purposes.
• Regular Penetration Testing: 46phwin conducts regular security testing by independent third parties to identify and address system vulnerabilities before they can be exploited.

8. Data Retention Period

46phwin does not retain your personal data longer than necessary for the original purpose of collection, or as required by Malaysian law. Our general data retention guidelines are as follows:

• Active Account Data: Retained for the duration of your active account at 46phwin and for 7 years after account closure, in compliance with financial and tax regulations.
• Financial Transaction Records: Retained for a minimum of 7 years from the transaction date, in accordance with Malaysian financial legislation and Anti-Money Laundering (AML) requirements.
• Gaming Activity Records: Retained for 5 years from the date of activity for audit and dispute resolution purposes.
• Customer Support Communication Data: Retained for 3 years after case closure for reference and service improvement purposes.
• Technical Log Data: Retained for 12 months from the date the log was created.
• Self-Exclusion Data: Retained for the duration of the self-exclusion period and for 5 years thereafter to ensure compliance with the request.

Once the retention period expires, your data will be securely deleted or permanently anonymised using industry-recognised methods.

9. Your Rights Under Malaysia's PDPA

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data at 46phwin:

10. Children's Data Protection

46phwin is a platform restricted to users aged 18 and above only. We do not knowingly collect, store or process the personal data of any individual under the age of 18.

Should we discover that personal data belonging to an individual under the age of 18 has been collected without our knowledge — whether through false registration or any other means — we will immediately delete that data, close the associated account, and take appropriate preventive action.

11. Cross-Border Data Transfers

In the course of operating the platform 46phwin, some data may be processed or stored on servers located outside Malaysia — particularly for international game provider services such as Microgaming, NetEnt and Pragmatic Play, which operate on a global infrastructure.

When cross-border data transfers occur, 46phwin ensures that adequate protections are in place through:

• Standard data transfer agreements that ensure recipients comply with data protection standards equivalent to Malaysia's PDPA.
• Selection of technology partners based in countries with recognised data protection laws.
• End-to-end encryption is applied to all cross-border data transfers.

12. Contact Us for Privacy Enquiries

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 46phwin handling your personal data, please contact our Data Privacy Officer at:

• Email: support@46phwin.net (please state "Privacy Enquiry" in the email subject line)
• Live Chat: Available on the 46phwin platform 24 hours a day, 7 days a week

46phwin is committed to responding to all privacy-related enquiries within 3 business days. For formal requests concerning your rights under the PDPA (such as data access or deletion requests), we will process these within 21 business days as required by law.

13. Privacy Policy Amendments

46phwin reserves the right to amend, add to, or update this Privacy Policy at any time to reflect changes in our operational practices, new Malaysian legal requirements, or relevant technological developments.

All members will be notified of any material changes to this Privacy Policy 46phwin through:

• Written notice via the email address registered to your account.
• A prominent in-platform notice on 46phwin during your next login session.
• Update of the "Last Updated" date at the top of this page.

Continued use of the platform 46phwin after a policy change notice is considered your acceptance of the amended policy. If you do not agree with any changes, you may close your account by contacting the 46phwin support team.