Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how we1wi ("Company", "we", "us", "our"), the operator of the online gaming platform accessible at https://we1wi.cam, collects, processes, stores, and protects the personal data of individuals who access or use our services ("Users", "Players", "you").

We1wi takes the privacy of its users seriously. We understand that Malaysian players entrust us with sensitive personal and financial information when they register, deposit, and play on our platform. This Policy sets out our obligations to you and your rights in relation to that information.

This Policy applies to all personal data collected through the we1wi website, mobile site, any associated applications, live chat interactions, email correspondence, WhatsApp communications, and any other channel through which you interact with us.

2 Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial account information, and any data that could be used to identify you directly or indirectly.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, transmission, disclosure, restriction, erasure, or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, the Data Controller is we1wi.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller under contractual instruction.
• "Consent" — a freely given, specific, informed, and unambiguous indication of agreement by a data subject to the processing of their Personal Data for a stated purpose.
• "KYC" — Know Your Customer, the process of verifying a player's identity and eligibility using government-issued documents and supporting records.
• "Cookie" — a small text file placed on your device by a website to store information about your browsing preferences, session state, or usage patterns.
• "PDPA" — the Personal Data Protection Act 2010 of Malaysia, the primary legislation governing data protection obligations for entities processing personal data in Malaysia.

3 Data Controller

We1wi acts as the Data Controller for all personal data collected from users of the platform. We determine the purposes and means of processing your data and are responsible for ensuring that data is handled in accordance with applicable data protection principles.

Where we engage third-party service providers — such as payment processors (including those operating Touch 'n Go eWallet, DuitNow, Maybank FPX integrations, CIMB, Public Bank, and Hong Leong payment gateways), KYC verification providers, customer support platforms, and analytics tools — those parties act as Data Processors under contractual agreements that restrict how they may use your data.

For any data protection enquiries, to exercise your rights, or to raise a complaint, please contact our Data Protection team at [email protected].

4 Data We Collect

We collect personal data from you through different channels and at different stages of your engagement with the we1wi platform. The categories of data we collect are as follows:

4.1 Registration Data

When you create a we1wi account, we collect:

• Full legal name
• Date of birth (to verify you are aged 21 or above)
• Email address
• Malaysian mobile number
• Residential address (including city — e.g., Kuala Lumpur, Petaling Jaya, Johor Bahru, Penang, Shah Alam)
• Username and encrypted password
• Preferred currency (MYR)

4.2 Identity Verification (KYC) Data

During KYC verification, we collect:

• Copy of government-issued photo identification (Malaysian MyKad or passport)
• Proof of residential address (utility bill, bank statement)
• Proof of payment method ownership (e.g., bank statement confirming ownership of Maybank, CIMB, or Public Bank account; screenshot of Touch 'n Go or GrabPay account)
• Selfie photograph where requested for identity confirmation

4.3 Transaction & Financial Data

In connection with deposits and withdrawals, we collect:

• Payment method type (e.g., Touch 'n Go eWallet, DuitNow, FPX, Boost, GrabPay, USDT TRC20)
• Transaction amounts and timestamps
• Bank account or e-wallet reference identifiers (we do not store full card numbers or e-wallet PINs)
• Withdrawal destination details

4.4 Gaming & Betting Activity Data

• Game history, wager amounts, and outcomes
• Sports betting selections (EPL, Liga Super Malaysia, UFC, and other markets)
• Session duration and frequency
• Bonus claims and wagering progress
• Responsible gambling tool usage (deposit limits set, session timers, exclusion requests)

4.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie and session data (see Section 9)
• Platform access logs and timestamps

4.6 Communications Data

• Content of live chat, WhatsApp, and email exchanges with our support team
• Feedback, complaints, and dispute records
• Marketing communication preferences and opt-out records

5 Legal Basis for Processing

We process your personal data under the following legal bases:

6 How We Use Your Data

We1wi uses your personal data for the following purposes:

6.1 Platform Operations

• To create and manage your player account;
• To process deposits and withdrawals via your chosen Malaysian payment method;
• To provide access to games, sports betting markets, live casino, and promotional offers;
• To apply and track bonus offers, wagering requirements, and loyalty programme points;
• To manage responsible gambling tools including deposit limits, session timers, and self-exclusion requests.

6.2 Verification & Compliance

• To verify your identity and age (21+) during KYC procedures;
• To comply with our anti-money laundering (AML) and counter-financing of terrorism (CFT) obligations;
• To detect and prevent fraud, collusion, bonus abuse, and prohibited conduct as described in our Terms & Conditions;
• To respond to lawful requests from regulatory authorities or law enforcement agencies.

6.3 Communications & Support

• To respond to your customer support queries via live chat, WhatsApp, or email;
• To send transactional notifications (deposit confirmations, withdrawal approvals, account security alerts);
• To send promotional communications where you have consented or where we have a legitimate interest based on your existing player relationship;
• To process and respond to complaints and dispute submissions.

6.4 Platform Improvement

• To analyse aggregated, anonymised player behaviour to improve platform design and game offerings;
• To test new features and assess platform performance;
• To conduct responsible gambling risk assessments based on your activity patterns.

7 Data Sharing & Disclosure

We1wi does not sell, rent, or trade your personal data to third-party marketers or data brokers. We share personal data with third parties only in the circumstances described below:

7.1 Service Providers (Data Processors)

We engage trusted third-party service providers to support our platform operations. These include:

• Payment processors: entities facilitating transactions via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX (Maybank, CIMB, Public Bank, Hong Leong, RHB), 7-Eleven Cliq, and USDT TRC20 networks;
• KYC and identity verification providers: third-party services that assist in verifying player identity documents;
• Customer support platforms: live chat and ticketing systems used by our support team;
• Analytics and fraud detection tools: services that help us identify suspicious activity and improve platform performance.

All service providers are bound by data processing agreements that prohibit them from using your data for any purpose other than the specific service they provide to us.

7.2 Legal & Regulatory Disclosure

We may disclose personal data to competent authorities, law enforcement agencies, or regulatory bodies where we are required to do so by law, court order, or under our licensing obligations. We will notify you of such disclosure where we are legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, or transfer of substantially all of we1wi's assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and your rights under this Policy will be preserved.

8 Payment Data Processing

All payment transactions on we1wi — whether via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX (Maybank, CIMB, Public Bank, Hong Leong), 7-Eleven Cliq, or USDT TRC20 — are processed through PCI-DS-compliant payment infrastructure. We1wi does not store full payment card numbers, CVV codes, e-wallet PINs, or banking login credentials on our servers.

Payment authentication (e.g., Maybank TAC codes, Touch 'n Go biometric approval, DuitNow OTPs) is handled entirely within your payment provider's ecosystem. We1wi only receives a transaction reference and confirmation of payment status — not the authentication credentials themselves.

Transaction records (amounts, timestamps, payment method type, and reference identifiers) are retained for a minimum of seven (7) years in compliance with our AML and licensing obligations, even after account closure.

9 Cookies & Tracking Technologies

We1wi uses cookies and similar tracking technologies to operate the platform, maintain your session, and improve your user experience. The types of cookies we use are as follows:

• Essential Cookies: Required for the platform to function. These include session management, login state, and security tokens. They cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings and responsible gambling tool configurations.
• Analytics Cookies: Collect anonymised data on how users navigate the platform, which pages are visited most frequently, and where users encounter friction. This data is used to improve the platform experience.
• Security & Fraud Prevention Cookies: Help detect suspicious activity, multiple account registrations from the same device, and abnormal betting patterns.

We do not use advertising or retargeting cookies that track you across third-party websites. You can manage cookie preferences through your browser settings; however, disabling essential cookies may impair platform functionality.

10 Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and our licensing obligations. Our standard retention periods are as follows:

• Active account data: Retained for the duration of your account's active status plus five (5) years after account closure, to comply with AML regulations and licensing requirements.
• KYC / identity documents: Retained for a minimum of seven (7) years from the date of verification, in accordance with standard AML record-keeping obligations.
• Transaction records: Retained for a minimum of seven (7) years from each transaction date.
• Support communications: Retained for three (3) years from the date of last interaction.
• Marketing preferences and opt-out records: Retained indefinitely to honour your marketing preferences even after account closure.

At the end of applicable retention periods, personal data is securely deleted or anonymised in a manner that renders re-identification impossible.

11 Data Security

We1wi implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers;
• Encrypted storage of sensitive data fields at rest, including identity documents and financial reference data;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of platform infrastructure;
• Two-factor authentication (2FA) available for player accounts;
• Automated monitoring for anomalous login activity and transaction patterns;
• Incident response procedures for data breach scenarios, including player notification obligations.

While we take all reasonable precautions, no online system is completely impenetrable. You are also responsible for maintaining the security of your own account credentials. We1wi will never ask for your password through any communication channel.

12 International Data Transfers

As we1wi operates under an international gaming licence, your personal data may be processed and stored on servers located outside of Malaysia. Where such transfers occur, we implement appropriate safeguards to ensure that your data receives an equivalent level of protection to that required under applicable data protection standards.

Safeguards for international transfers include: contractual clauses binding recipient entities to data protection standards consistent with our obligations; use of processors operating in jurisdictions recognised as providing adequate data protection; and technical measures ensuring equivalent security regardless of data location.

By using we1wi, you acknowledge and consent to the international transfer of your personal data as described in this Policy. If you have concerns about where your data is stored or processed, please contact us at [email protected].

13 Your Data Rights

As a user of we1wi, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We respond to all verified requests within 10 business days.