Privacy Policy Legowin – Personal Data Protection for Malaysian Players

Legowin ("we", "the platform") respects the privacy of every individual who uses our services and is fully committed to protecting your personal information. This Privacy Policy ("Policy") explains in detail how Legowin collects, stores, uses, discloses, and safeguards your personal information when you use the Legowin platform at legowin.app.

This document has been prepared in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and relevant international data protection standards. By registering for or using the Legowin platform, you consent to the collection and use of your personal information as set out in this Privacy Policy.

We take this responsibility seriously because we understand that your trust is the foundation of our relationship. When you entrust Legowin with your personal information, we commit to safeguarding it to the highest protection standards, using it only for its stated purposes, and never selling or misusing that data.

Legowin collects various types of personal information during registration and platform use. The information we collect depends on how you interact with our platform.

We only collect data that is strictly necessary to deliver our services effectively and to meet legal requirements. We do not collect sensitive information such as biometric data, health information, or your political affiliations.

Legowin collects your personal information through a variety of transparent and lawful methods. The following are the primary ways in which data collection takes place:

• Account Registration: When you register a new Legowin account, you provide us directly with basic personal information such as your name, email address, and phone number.
• Financial Transactions: When you make a deposit using Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, or FPX, our system records the transaction details required to process and verify your payment.
• Identity Verification (KYC): When required, you will be asked to submit identity verification documents such as a copy of your MyKad or other supporting documents to comply with legal requirements.
• Platform Usage: Our system automatically logs technical information such as your IP address, device type, and in-platform activity each time you log in and play.
• Cookies and Similar Technologies: The Legowin platform uses cookies and other tracking technologies to enhance your experience and ensure the security of your login session.
• Support Communications: When you reach out to our customer support team via live chat or email, conversations are recorded for quality assurance and training purposes.

Legowin uses the personal information it collects solely for legitimate and transparent purposes. We will not use your data for any purpose not stated in this Policy without your prior consent. The purposes for which we use your data are as follows:

• Managing Your Account: Allows you to log in, play games, make deposits and withdrawals, and access all features on the Legowin platform.
• Identity Verification & Legal Compliance: Fulfils KYC (Know Your Customer) requirements and applicable anti-money laundering legislation in Malaysia.
• Security & Fraud Prevention: Monitoring suspicious activity, preventing unauthorised access, and protecting your account from security threats.
• Customer Support: Helping you resolve issues, answering your queries, and improving our service quality based on your feedback.
• Personalise Your Experience: Tailoring game recommendations, promotions, and relevant content based on your preferences and play patterns.
• Service Communications: Sends you important account notifications, policy updates, and promotional information (with your consent).
• Platform Improvement: Analysing aggregated usage data to improve the features, performance, and usability of the Legowin platform.

Legowin does not sell, rent, or trade your personal information to any third party for their own commercial purposes. However, we may share your data in the limited circumstances described below:

• Payment Service Providers: To process your transactions via Touch 'n Go eWallet, GrabPay, DuitNow, FPX, and other methods, we are required to share the minimum necessary transaction information with the relevant payment providers. All such providers are bound by strict confidentiality agreements.
• Game Providers: Minimal technical data may be shared with third-party game providers that supply slots, live casino, and other games on our platform to ensure a seamless gaming experience.
• Regulatory Authorities & Law Enforcement: Legowin will disclose personal information to the relevant authorities in Malaysia if required by law, court order, or valid legal process.
• Rights & Security Protection: We may disclose your data where we reasonably believe it is necessary to prevent fraud, protect the safety of other users, or defend the rights of Legowin.

Any third parties with whom we share data are required to uphold data protection standards equal to or stricter than those set out in this Privacy Policy. We do not control how these third parties use the data once it has been shared under the circumstances described above.

Legowin continuously invests in security infrastructure to keep your personal data protected at all times. Our security measures include:

• 256-bit SSL Encryption: All communications between your device and Legowin's servers are encrypted using the latest Transport Layer Security (TLS) technology, ensuring your data cannot be intercepted in transit.
• Two-Factor Authentication (2FA): We provide and encourage the use of two-factor authentication for all accounts, adding an extra layer of security that protects your account even if your password is compromised.
• Segregation of Funds: Your deposit funds are held in a dedicated account, separate from Legowin's operational accounts, and protected against any third-party claims against the company.
• 24/7 Monitoring: Our security systems monitor for unusual activity around the clock, enabling us to detect and respond to potential threats promptly.
• Regular Penetration Testing: The Legowin platform undergoes comprehensive security testing on a regular basis to identify and address vulnerabilities before they can be exploited.
• Internal Access Controls: Only Legowin staff who require access to specific data to carry out their duties are granted that access, in accordance with the principle of minimum necessary access.

The Legowin platform uses cookies and similar technologies to enhance your user experience. Cookies are small text files stored on your device when you visit our website. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as maintaining your login session and storing security settings. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Helping us understand how users interact with our platform by collecting aggregated and anonymised information about pages visited and actions taken.
• Functional Cookies: Allows the platform to remember your preferences — such as your chosen language and display settings — for a more personalised experience.

You can manage cookies through your web browser settings. However, disabling certain cookies may affect the functionality of the Legowin platform. Continued use of our platform after being notified of our cookie usage constitutes your consent to their use.

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and the Legowin Privacy Policy, you have the following rights in relation to your personal information:

• Right to Access: You have the right to request a copy of the personal information we hold about you. Requests can be submitted by email to support@legowin.app.
• Right to Rectification: If any of your personal information is inaccurate or incomplete, you may request that we correct it.
• Right to Erasure: Under certain circumstances, you may request that we delete your personal information. Such requests are subject to legal requirements that may obligate us to retain specific data for a prescribed period.
• Right to Restrict Processing: You may request that we restrict how we process your data under certain circumstances.
• Right to Object: You may object to the processing of your data for direct marketing purposes at any time.
• Right to Withdraw Consent: Where data processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal.

To exercise any of the above rights, please contact our privacy team at support@legowin.app. We will respond to your request within 30 business days.

The Legowin platform is strictly for adults aged 18 and above. Legowin does not knowingly collect, store, or process personal information from individuals under the age of 18.

All new registrants are required to confirm they are at least 18 years of age during the registration process. Should we discover that we have inadvertently collected personal information from someone under the age of 18, we will take immediate steps to delete that information and close the account in question.

If you believe a person under the age of 18 has registered a Legowin account, please contact us immediately at support@legowin.app so we can take the appropriate action.

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

• Active Account Information: Retained for as long as your account is active and for a reasonable period following account closure.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with Malaysia's accounting and tax legal requirements.
• KYC Records & Identity Verification: Retained for a minimum of 5 years after the business relationship ends, as required under anti-money laundering legislation.
• Support Communication Logs: Retained for 2 years for quality assurance and dispute resolution purposes.
• Technical Data & Security Logs: Retained for 1 year for security and threat analysis purposes.

When data is no longer required, Legowin will securely delete or destroy it using methods that ensure it cannot be recovered or reused.

Legowin reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or new platform features. When we make material changes, we will notify you via your registered email and/or a prominent notice on the Legowin platform before the changes take effect.

The "Updated" date at the top of this page will always reflect the most current version of our Privacy Policy. We encourage you to check this page periodically to stay informed about how we protect your data.

Your continued use of the Legowin platform after any amendments to this Privacy Policy take effect constitutes your acceptance of those changes.

If you have any questions, concerns, or complaints about this Privacy Policy or how legowin handles your personal information, please do not hesitate to contact us. We are committed to addressing every privacy enquiry promptly, thoroughly, and with the utmost respect.

How to reach the Legowin privacy team:

• Privacy Email: support@legowin.app (please mark the subject as: "Data Privacy Enquiry")
• Live Chat: Available 24/7 on the Legowin platform – select the "Privacy & Data" category

We will endeavour to respond to all privacy enquiries within 5 business days. For more complex requests, such as data erasure or full access to your records, the process may take up to 30 business days as provided under Malaysia's PDPA.