Privacy Policy

1. Introduction

Wingiler ("Company", "we", "us", "our") is committed to protecting the personal data of all individuals who register for, access, or otherwise use the Wingiler platform, including its website, mobile interface, gaming products, payment services, and promotional programmes. This Privacy Policy ("Policy") sets out how we collect, use, disclose, store, and protect that information.

By creating a Wingiler account, depositing funds, participating in games, or otherwise engaging with any part of our services, you acknowledge that you have read and understood this Policy and that you consent to the data practices described herein. If you do not accept the terms of this Policy, you must not register or continue to use the Wingiler platform.

2. Definitions

Throughout this Policy, the following terms have the meanings set out below:

• "Personal Data" means any information that identifies or can be used to identify you as an individual, directly or indirectly.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, and deletion.
• "Data Controller" refers to the entity that determines the purposes and means of processing Personal Data — in this context, Wingiler.
• "Data Processor" refers to a third party that processes Personal Data on behalf of the Data Controller.
• "Cookies" refers to small text files stored on your device by your web browser at the request of a website.
• "KYC" refers to Know Your Customer verification procedures required under our licensing obligations.
• "Services" refers to all products, features, and functions offered through the Wingiler platform.

3. Data Controller

Wingiler acts as the Data Controller in respect of Personal Data collected from registered players and website visitors. As Data Controller, Wingiler is responsible for determining the purposes for which your Personal Data is collected and the manner in which it is processed. For all privacy-related queries, you may contact our data team at the address provided in Section 15 of this Policy.

4. Personal Data We Collect

4.1 Registration Data

When you create a Wingiler account, we collect the information you provide, which typically includes your full legal name, date of birth, residential address, nationality, email address, mobile phone number, and chosen username. This information is required to establish and manage your account and to fulfil our KYC obligations.

4.2 Identity Verification Data

As part of our KYC process, we may collect copies of government-issued identification documents (such as a Malaysian National Identity Card or passport), proof of address (such as a utility bill or bank statement issued within the preceding three months), and, where relevant, source-of-funds documentation. This data is processed solely for verification and compliance purposes.

4.3 Financial and Transaction Data

We record details of all deposits, withdrawals, game wagers, and bonus transactions associated with your account. This includes transaction amounts in MYR, payment method identifiers (such as the last four digits of a bank account or e-wallet reference), timestamps, and transaction reference numbers. Full financial account credentials are handled directly by your payment provider and are not stored on Wingiler systems.

4.4 Technical and Usage Data

When you access Wingiler, we automatically collect certain technical data about your device and browsing behaviour. This includes your IP address, browser type and version, operating system, device identifiers, pages visited, session duration, and referral URLs. This data is used for platform security, fraud detection, and service improvement purposes.

4.5 Communications Data

We retain records of communications between you and Wingiler, including support chat transcripts, email correspondence, and any complaints or queries you submit. This data is used for account management, dispute resolution, and service quality monitoring.

The table below summarises the key categories of data we collect and their primary purposes:

5. Purposes of Processing

Wingiler processes your Personal Data for the following purposes:

• Establishing and administering your player account.
• Verifying your identity and age in accordance with KYC requirements.
• Processing deposits, withdrawals, and in-platform transactions via payment methods including Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank, DuitNow, FPX, and USDT TRC20.
• Detecting and preventing fraud, money laundering, and other financial crimes.
• Providing customer support and resolving account disputes.
• Administering promotions, bonuses, and loyalty rewards.
• Sending account-related communications, including transaction confirmations and security alerts.
• Analysing platform usage to improve the Wingiler experience.
• Complying with legal, regulatory, and licensing obligations applicable to Wingiler's operations.
• Monitoring responsible gambling indicators and applying player-protection controls where appropriate.

6. Legal Basis for Processing

Wingiler relies on the following legal bases to process your Personal Data:

• Contractual necessity: Processing required to perform our obligations under the account agreement with you, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable anti-money laundering legislation, licensing conditions, and KYC requirements.
• Legitimate interests: Processing conducted for fraud detection, platform security, and service improvement, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications, where we rely on your explicit opt-in consent. You may withdraw such consent at any time.

7. Data Sharing and Disclosure

7.1 Service Providers

Wingiler engages third-party service providers to assist with the operation of the platform. These providers may include payment processors, identity verification services, cloud hosting providers, fraud detection specialists, and customer support software vendors. Such providers are permitted to process your data only as necessary to deliver services to Wingiler and are bound by appropriate confidentiality and data protection obligations.

7.2 Regulatory and Legal Disclosures

Wingiler may disclose Personal Data to regulatory authorities, licensing bodies, law enforcement agencies, or courts where required by applicable law, regulation, or a binding legal order. We will not voluntarily disclose your information to government bodies beyond what is legally compelled.

7.3 No Sale of Personal Data

Wingiler does not sell, rent, or trade your Personal Data to third parties for their own marketing or commercial purposes. Any data sharing with partners is limited to what is operationally necessary and conducted under appropriate data protection safeguards.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of Wingiler's business assets, Personal Data may be transferred to the acquiring entity as part of that transaction. Where such a transfer occurs, we will take reasonable steps to ensure that your data continues to be protected in accordance with this Policy.

8. Cookies and Tracking Technologies

Wingiler uses cookies and similar tracking technologies on its website and platform to support functionality, security, and analytics. The categories of cookies we use include:

• Strictly necessary cookies: Required for the platform to function, including session management, login authentication, and security tokens. These cannot be disabled without impairing platform usability.
• Functional cookies: Remember your preferences, such as language settings and notification configurations, to improve your experience.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate the platform. This data helps Wingiler identify usability issues and prioritise improvements.
• Security cookies: Detect unusual account activity, bot traffic, and potential fraud attempts.

You may control cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent certain features of the Wingiler platform from functioning correctly.

9. Data Retention

Wingiler retains Personal Data for as long as your account remains active and for a period thereafter as required by our licensing conditions, anti-money laundering obligations, and applicable legal requirements. In practice, player account data — including transaction records and identity documents — is typically retained for a minimum of five years following account closure, in line with standard financial compliance requirements.

Where Personal Data is no longer required for any lawful purpose and no retention obligation applies, we delete or anonymise it in a secure and irreversible manner.

10. Data Security

Wingiler implements technical and organisational measures designed to protect your Personal Data from unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and Wingiler servers.
• Encrypted storage for sensitive data at rest, including identity documents and financial records.
• Access controls limiting Personal Data visibility to authorised personnel with a legitimate operational need.
• Regular internal security reviews and monitoring for anomalous data access patterns.
• Two-factor authentication options for player accounts to reduce the risk of unauthorised login.

11. Your Data Rights

Subject to applicable law and our legal retention obligations, you have the following rights in relation to your Personal Data held by Wingiler:

• Right of access: You may request a copy of the Personal Data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete Personal Data.
• Right to erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention requirements.
• Right to restrict processing: You may request that we limit the processing of your Personal Data in certain circumstances.
• Right to data portability: Where processing is based on your consent or contractual necessity, you may request a structured copy of your data in a commonly used format.
• Right to withdraw consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You may object to processing based on our legitimate interests where your particular circumstances warrant it.

To exercise any of the above rights, please contact Wingiler's support team using the contact details in Section 15. We aim to respond to all valid requests within 30 days of receipt.

12. Minors and Age Protection

The Wingiler platform is intended exclusively for individuals aged 21 years and above. We do not knowingly collect Personal Data from individuals under this age. If we become aware that a minor has registered on the platform, we will immediately suspend the associated account, delete the minor's data as far as legally permissible, and withhold any associated balances pending investigation.

Parents and guardians who believe a minor may have accessed Wingiler are encouraged to contact our support team immediately so that the account can be reviewed and closed.

13. International Data Transfers

Wingiler operates under international licensing and may store or process your Personal Data in jurisdictions outside Malaysia. Where data is transferred internationally, Wingiler ensures that appropriate safeguards are in place — such as contractual data protection clauses — to maintain a standard of protection consistent with this Policy. By registering with Wingiler, you acknowledge and accept that your Personal Data may be transferred to and processed in countries outside your jurisdiction of residence.

14. Changes to This Privacy Policy

Wingiler reserves the right to update or amend this Privacy Policy at any time. Where a material change is made, registered players will be notified via the email address on file or through a prominent notice on the platform, no fewer than seven days before the change takes effect. Continued use of the Wingiler platform following notification constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed of how Wingiler protects your Personal Data.

15. Contact Us

For any questions regarding this Privacy Policy, to exercise your data rights, or to raise a privacy concern, please contact the Wingiler data team. We aim to provide a substantive written response within 30 days of receiving your request.

Contact email (plain text — not a clickable link): [email protected]

For information on your rights as a player and the rules governing your use of the platform, please review our Terms & Conditions. For information on responsible gambling controls and player protection tools, please visit our Responsible Gambling page.