Privacy Policy

This Privacy Policy ("Policy") is issued by QKWin ("QKWin", "we", "us", "our") and applies to all personal data collected through or in connection with the QKWin online gaming platform accessible at https://qkwin.cam (the "Platform"), including all services, features, and payment facilities offered thereon.

QKWin is an English-language online gaming platform serving Malaysian players with sports betting, live casino games, and slot titles. In the course of providing these services, QKWin collects and processes personal data from registered players and, where applicable, from visitors to the Platform who have not completed the registration process.

This Policy describes in plain terms what personal data QKWin collects, the purposes for which that data is processed, the legal basis relied upon for each category of processing, how long data is retained, and the rights available to individuals regarding their personal data.

By registering an account on the Platform or by continuing to use the Platform, you confirm that you have read and understood this Policy and consent to the processing of your personal data as described herein, to the extent that consent forms the applicable legal basis. If you do not agree with any part of this Policy, you should not use the Platform.

In this Policy, the following terms have the meanings assigned to them below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact information, financial data, and online identifiers.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, or deletion.
• "Data Controller" means QKWin, which determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of QKWin under a written data processing agreement.
• "KYC" means Know Your Customer identity verification procedures required to confirm a player's identity, age, and eligibility.
• "Cookies" means small text files placed on a user's device by the Platform to facilitate session management, analytics, and personalisation.
• "Account" means a registered player account on the Platform.
• "Platform" means the QKWin website at https://qkwin.cam and all related subpages, services, and features.

QKWin collects Personal Data from you directly, automatically, and from third parties in the following categories:

3.1 Registration Data

When you create an Account, we collect: full legal name, date of birth, gender, residential address (including city and postcode — e.g., Kuala Lumpur, Petaling Jaya, Penang, Johor Bahru, Shah Alam), email address, and Malaysian mobile phone number.

3.2 Identity Verification (KYC) Data

To comply with our licensing obligations and to verify your eligibility (minimum age 21), we collect copies of: government-issued photo identification (MyKad, passport, or driving licence), proof of residential address (utility bill or bank statement), and payment method verification documents where applicable.

3.3 Financial & Transaction Data

We collect records of all deposits, withdrawals, wagers, bonuses, and other financial transactions on the Platform. This includes payment method identifiers (e-wallet account numbers, masked bank account details, FPX reference numbers) for Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and other accepted payment channels. We do not store full payment card numbers or full bank account credentials.

3.4 Technical & Device Data

We automatically collect: IP address, device type and operating system, browser type and version, session timestamps, Platform navigation data, and referral source information. This data is collected via server logs and cookies.

3.5 Communications Data

We retain records of communications between you and QKWin's customer support team, including live chat transcripts, email correspondence, and any documentation submitted in connection with a query or dispute.

3.6 Responsible Gambling Data

Where you have used QKWin's responsible gambling tools (deposit limits, session reminders, self-exclusion), we retain a record of those elections to fulfil our duty of care obligations and to prevent reactivation of self-excluded accounts.

QKWin processes your Personal Data for the following purposes:

QKWin does not engage in automated decision-making that produces legally significant effects on players without human review, except where explicitly stated and where the applicable legal basis supports such processing.

QKWin relies on the following legal bases for processing Personal Data:

• Contractual Necessity: Processing required to perform the contract with you — namely, operating your Account, processing transactions, and delivering gaming services. Without this processing, QKWin cannot provide the Platform services.
• Legal Obligation: Processing required to comply with applicable laws and licensing conditions, including KYC obligations, anti-money laundering requirements, and regulatory reporting duties.
• Legitimate Interests: Processing carried out for QKWin's legitimate business interests, including fraud detection, platform security, responsible gambling monitoring, and internal analytics, provided those interests are not overridden by your rights and freedoms.
• Consent: Where you have given explicit consent to specific processing activities — for example, receiving marketing communications from QKWin. Consent may be withdrawn at any time by contacting [email protected] or updating your Account preferences, without affecting the lawfulness of processing prior to withdrawal.

QKWin does not sell, rent, or otherwise trade your Personal Data to third-party advertisers or data brokers under any circumstances. Personal Data is shared only in the following specific situations:

• Payment Service Providers: Personal and financial data is shared with licensed payment processors operating the channels you use to transact (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and others) to the extent necessary to complete your transactions. These providers are bound by their own data protection obligations.
• KYC and Identity Verification Providers: Identity documents and registration data may be shared with licensed third-party KYC verification services to fulfil our age and identity verification obligations.
• Game Providers: Where required for the delivery of specific games or betting markets, limited technical data (such as session tokens) may be shared with licensed game studios and content providers.
• Regulatory and Law Enforcement Authorities: QKWin may disclose Personal Data to relevant regulatory bodies, licensing authorities, or law enforcement agencies where required to do so by law, court order, or licensing obligation.
• Fraud Prevention Services: Technical and transaction data may be shared with third-party fraud prevention and anti-money laundering services to protect the integrity of the Platform and its player community.
• Professional Advisers: Personal Data may be disclosed to legal advisers, auditors, or accountants where strictly necessary for QKWin to obtain professional advice or in connection with legal proceedings.

All third-party Data Processors engaged by QKWin are required to enter into written data processing agreements that impose obligations equivalent to, or more stringent than, those set out in this Policy.

QKWin uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that help the Platform function correctly and allow QKWin to understand how players interact with the Platform.

QKWin uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session management cookies that keep you logged in during your visit. These cannot be disabled without affecting core Platform functionality.
• Analytics Cookies: Used to collect anonymised data about how players navigate the Platform, which pages are most visited, and where errors occur. This data is used solely to improve the Platform experience.
• Functional Cookies: Used to remember your preferences such as language selection, display settings, and last-used payment method to streamline future sessions.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorised access attempts.

You may manage cookie preferences through your browser settings. Note that disabling certain cookies may impair the functionality of the Platform, including the ability to maintain your session or access certain features.

QKWin retains Personal Data only for as long as is necessary for the purposes for which it was collected, unless a longer retention period is required by applicable law or licensing obligations. The following indicative retention periods apply:

• Account and Registration Data: Retained for the duration of the Account plus a minimum of 5 years following Account closure, in compliance with anti-money laundering record-keeping requirements.
• KYC Documents: Retained for a minimum of 5 years from the date of verification or Account closure, whichever is later, in accordance with applicable licensing obligations.
• Transaction Records: Retained for a minimum of 5 years following the date of each transaction, or longer where required by regulatory authority.
• Communications Records: Retained for a minimum of 2 years following the closure of the relevant support interaction or dispute.
• Responsible Gambling Records: Self-exclusion records are retained indefinitely to prevent reactivation of excluded accounts. Other responsible gambling tool records are retained for 5 years following Account closure.
• Technical and Device Data: Retained for up to 13 months for analytics purposes, after which they are deleted or anonymised.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with QKWin's internal data management procedures.

QKWin implements appropriate technical and organisational security measures designed to protect Personal Data against accidental loss, unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between user devices and QKWin's servers;
• Encryption of sensitive Personal Data at rest within QKWin's database infrastructure;
• Role-based access controls ensuring that Personal Data is accessible only to authorised personnel with a genuine business need;
• Multi-factor authentication requirements for all internal staff accessing production systems;
• Regular security audits, penetration testing, and vulnerability assessments of the Platform's infrastructure;
• Incident response procedures designed to detect, contain, and report data breaches in accordance with applicable obligations.

While QKWin takes all reasonable measures to secure your Personal Data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your Account credentials. If you believe your Account has been compromised, contact QKWin support immediately.

Subject to applicable law and certain legitimate restrictions, you have the following rights in relation to your Personal Data held by QKWin:

• Right of Access: You may request a copy of the Personal Data QKWin holds about you and information about how it is processed.
• Right to Rectification: You may request correction of any Personal Data that is inaccurate or incomplete. Basic account details such as address and phone number can be updated directly in Account Settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent (where consent was the legal basis). Note that this right is subject to limitations where retention is required by law or licensing obligation.
• Right to Restrict Processing: You may request that QKWin restricts the processing of your Personal Data in certain circumstances, such as while a disputed accuracy is being resolved.
• Right to Data Portability: Where processing is based on your consent or a contract and carried out by automated means, you may request your Personal Data in a structured, commonly used machine-readable format.
• Right to Object: You may object to processing based on QKWin's legitimate interests at any time. You may also opt out of direct marketing communications at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Rights Request" and include your registered Account username and a description of your request. QKWin will respond within 30 calendar days. We may request identity verification before processing your request.

The Platform is strictly intended for individuals aged 21 years and above. QKWin does not knowingly collect Personal Data from any individual under the age of 21. If QKWin discovers or has reasonable grounds to suspect that Personal Data has been submitted by a person under 21, the associated Account will be suspended immediately, all data will be retained solely for compliance purposes, and no withdrawals will be processed.

QKWin requires all players to complete KYC verification as part of the account process, which includes providing government-issued photo identification confirming date of birth. This verification step serves as QKWin's primary control against underage gambling.

If you have reason to believe that a minor has registered an Account on the Platform, please notify QKWin immediately at [email protected].

QKWin operates as an internationally licensed platform. In the course of providing services, your Personal Data may be transferred to and processed in countries other than Malaysia, including the jurisdiction in which QKWin holds its gaming licence and the locations of its third-party service providers.

Where Personal Data is transferred outside Malaysia, QKWin takes reasonable steps to ensure that appropriate safeguards are in place to protect your data, including contractual clauses in agreements with Data Processors that impose data protection standards consistent with those described in this Policy.

By using the Platform, you acknowledge that your Personal Data may be processed in jurisdictions outside Malaysia and consent to such transfer for the purposes described in this Policy.

QKWin reserves the right to update or amend this Privacy Policy at any time to reflect changes in data practices, applicable law, or Platform services. The date of the most recent revision is displayed at the top of this page.

Where amendments are material — for example, changes to the categories of data collected, new purposes for processing, or changes to data sharing arrangements — QKWin will provide reasonable prior notice to registered players via an in-platform notification or by email to the address registered to your Account.

Continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not accept the revised terms, you must cease using the Platform and contact QKWin to request Account closure.

If you have any questions, concerns, or complaints regarding this Privacy Policy or QKWin's data practices, you may contact us through the following channels:

• Data Rights Requests: Submit a written request to [email protected] with subject line "Data Rights Request" including your registered username and a description of your request.
• General Privacy Enquiries: Email [email protected] — responses within 24 hours.
• Live Chat: Available 24/7 via the Platform in English, Bahasa Melayu, and Mandarin — average response time 3–5 minutes.

QKWin will acknowledge data-related requests within 5 business days and provide a substantive response within 30 calendar days. If your request is complex or if you have submitted multiple requests, the response period may be extended by a further 60 days with notification of the extension.

You also have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction if you are not satisfied with QKWin's response to a data rights request or privacy concern.