Privacy Policy — t2win

This Privacy Policy ("Policy") is issued by t2win ("we", "us", "our"), the operator of the online gaming platform accessible at https://t2win.cam ("Platform"). This Policy explains how we collect, process, store, share, and protect personal data belonging to individuals who access or use the Platform, including registered players and visitors.

t2win is committed to protecting the privacy and personal data of all users in accordance with applicable data protection laws, including Malaysia's Personal Data Protection Act 2010 (PDPA) and other relevant regulations. This Policy sets out your rights in relation to your personal data and explains how to exercise those rights.

By registering for an Account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must cease using the Platform and may request Account closure by contacting our support team.

The following terms, as used in this Policy, shall have the meanings set out below:

t2win collects personal data in several ways: directly from you when you register or interact with the Platform, automatically through your use of the Platform, and from third-party sources such as KYC verification providers and payment processors.

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, health data, or biometric identifiers beyond standard KYC photo identification unless specifically required by applicable law.

t2win processes your personal data on the following legal bases:

• Contractual Necessity: Processing is required to perform the contract between you and t2win — specifically, to operate your Account, process deposits and withdrawals in MYR, and provide access to our games and betting services.
• Legal Obligation: Processing is required to comply with applicable laws, including anti-money laundering (AML) legislation, financial services regulations, and identity verification requirements under Malaysian law.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, improving user experience, and responsible gambling monitoring — where these interests do not override your fundamental rights.
• Consent: Where required by law, we will obtain your explicit consent before processing certain categories of data, such as for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Your personal data is used exclusively for the purposes set out in this Policy. The specific purposes for which t2win processes personal data include:

5.1 Account Management

To create, maintain, and administer your Account; to verify your identity and age during KYC; to communicate account-related information; and to process your Account closure request where submitted.

5.2 Payment Processing

To process deposits and withdrawals in Malaysian Ringgit (MYR) through supported payment methods including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect; to investigate and resolve payment disputes; and to maintain accurate financial records.

5.3 Fraud Prevention & Security

To detect, investigate, and prevent fraudulent activity, money laundering, account abuse, and other prohibited activities; to monitor compliance with our Terms and Conditions; and to protect the security of the Platform and its users.

5.4 Responsible Gambling

To monitor gaming activity for signs of problem gambling; to enforce deposit limits, session controls, and self-exclusion where set by the user; and to fulfil our obligations under responsible gambling guidelines. Please see our Responsible Gambling page for full details.

5.5 Customer Support

To respond to your enquiries and support requests submitted via live chat or email ([email protected]); to maintain records of communications for quality assurance and dispute resolution purposes; and to improve our support processes.

5.6 Legal Compliance

To comply with applicable Malaysian laws and regulations, including reporting obligations to relevant regulatory authorities where required.

t2win does not sell, rent, or trade your personal data to any third party. Personal data is shared only in the following circumstances:

• Payment Processors: We share necessary financial data with payment service providers to facilitate deposits and withdrawals. This includes providers supporting DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect transactions.
• KYC and Identity Verification Providers: We share identity documents with accredited third-party KYC service providers for the purpose of verifying your identity and age as required by applicable regulations.
• Fraud Prevention and Security Services: We may share data with fraud detection service providers to protect the Platform and its users from fraudulent activity.
• Regulatory and Law Enforcement Authorities: We will disclose personal data to government authorities, regulators, or law enforcement agencies where we are legally required or compelled to do so — for example, to comply with anti-money laundering (AML) reporting obligations.
• Professional Advisers: We may share data with our legal, audit, or compliance advisers on a confidential basis where necessary to obtain professional advice.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of t2win's business, personal data held by us may form part of the transferred assets. Affected users will be notified as required by applicable law.

All third parties with whom we share personal data are required to process it securely, in accordance with applicable data protection law, and solely for the specific purposes for which it was disclosed.

t2win retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active Account Data: Retained for the full duration of your Account's active status and for a period of at least five (5) years following Account closure.
• KYC and Identity Documents: Retained for a minimum of five (5) years following Account closure or the cessation of the business relationship, in compliance with AML legislation.
• Financial Transaction Records: Retained for a minimum of seven (7) years in accordance with applicable financial record-keeping requirements.
• Customer Support Communications: Retained for a period of three (3) years for quality assurance and dispute resolution purposes.
• Technical and Log Data: Typically retained for up to twelve (12) months unless a longer retention period is required for security or fraud investigation purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data disposal procedures.

t2win implements robust technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• Encryption in Transit: All data transmitted between your device and the Platform is encrypted using Transport Layer Security (TLS).
• Encryption at Rest: Sensitive personal data stored on our systems is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within t2win is restricted to authorised personnel only, on a strict need-to-know basis, with role-based permissions and access logging.
• Regular Security Assessments: Our systems and infrastructure are subject to regular security reviews and vulnerability assessments.
• Staff Training: t2win personnel who handle personal data receive appropriate data protection and security training.

t2win uses cookies and similar tracking technologies to operate the Platform effectively, personalise your experience, and analyse usage patterns. The types of cookies we use include:

9.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function. They enable core functionality such as session authentication, security, and fraud detection. These cookies cannot be disabled without rendering the Platform inoperable.

9.2 Functional Cookies

These cookies remember your preferences — such as language settings, display preferences, and previously visited games — to provide a more personalised experience on return visits.

9.3 Analytics Cookies

We use analytics tools to understand how users navigate the Platform, which features are most popular, and where technical issues arise. This data is aggregated and anonymised where possible. Analytics cookies help us continuously improve the t2win experience for Malaysian players.

You may manage or disable non-essential cookies through your browser settings. However, please note that disabling certain cookies may affect the performance or availability of some Platform features.

t2win primarily processes and stores personal data within or in proximity to the Southeast Asian region. In certain circumstances — for example, where we engage international KYC verification providers or cloud infrastructure services — your personal data may be transferred to, and processed in, countries outside of Malaysia.

Where such transfers occur, t2win takes all reasonable steps to ensure that appropriate safeguards are in place to protect your personal data in accordance with applicable data protection law. These safeguards may include contractual data processing agreements incorporating appropriate data protection clauses, and verification that the receiving party operates under an adequate level of data protection.

By using the Platform and accepting this Policy, you consent to the transfer of your personal data to countries outside Malaysia as described above, subject to the safeguards set out in this section.

Subject to applicable law and certain conditions, you have the following rights in respect of your personal data held by t2win. To exercise any of these rights, please contact our Data Support team at [email protected] with the subject line "Data Rights Request".

We will respond to valid data rights requests within a reasonable timeframe and in any event within 30 calendar days of receipt. We reserve the right to request proof of identity before processing any data rights request to protect against unauthorised access.

t2win is an online gaming platform strictly for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory component of our KYC process, and access to all Platform features — including deposits, gameplay, and withdrawals — is restricted to verified adult users.

If t2win becomes aware that personal data has been collected from an individual who is under 21 years of age, that individual's Account will be immediately suspended, all balances will be reviewed, and the personal data will be deleted in accordance with applicable law following the completion of any required regulatory reporting.

The Platform may reference third-party payment providers including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank, and Hong Leong Connect. These entities operate independently of t2win and have their own privacy policies that govern the data they collect and process in connection with payment transactions.

t2win is not responsible for the data processing practices of payment processors or any other third-party service providers beyond our contractual obligations to ensure they maintain appropriate data protection standards. We encourage you to review the privacy policies of all payment services you use in connection with your t2win Account.

t2win reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or Platform features. Where changes are material, we will notify registered users by email to the address on file or by posting a prominent notice on the Platform prior to the effective date of the changes.

The most current version of this Policy, including its effective date, will always be available at https://t2win.cam/privacy-policy. Your continued use of the Platform following the effective date of a revised Policy constitutes acceptance of the updated terms. If you do not agree to the revised Policy, please contact us to close your Account.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by t2win, please contact our support team using the details below. When submitting a data rights request, please include your registered Account username and a clear description of your request.

If you are not satisfied with our response to a data protection concern, you may have the right to lodge a complaint with the relevant data protection authority in Malaysia or the jurisdiction in which you reside.