Privacy Policy

1. Data Controller

1.1 For the purposes of this Privacy Policy, the data controller responsible for the processing of personal data collected through the lvwin platform is the lvwin operating entity, accessible at lvwin.club and operating under an international gaming authority Operating Licence.

1.2 All data protection enquiries and requests from players should be directed to the lvwin Data Protection contact, reachable through the in-platform support channel or at the written correspondence address referenced in Section 14 of this Policy.

2. Data We Collect

2.1 lvwin collects personal data from players and visitors in the following categories:

2.2 lvwin does not intentionally collect Special Category data (as defined under applicable data protection legislation, including data relating to racial or ethnic origin, health, biometric data for identification, or criminal conviction data) unless specifically required by anti-money laundering regulations or compelled by a competent authority.

3. How We Use Your Data

3.1 lvwin processes personal data for the following purposes:

• Account Management: To create, maintain, and administer your lvwin player account, verify your identity, and facilitate the lvwin login process;
• Transaction Processing: To process deposits and withdrawals in MYR via your chosen payment method, including Touch 'n Go eWallet, Boost, and local bank transfers;
• Regulatory Compliance: To satisfy KYC, anti-money laundering (AML), and counter-terrorism financing (CTF) obligations under the lvwin Operating Licence;
• Responsible Gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may be exhibiting signs of problem gambling;
• Platform Security: To detect and prevent fraud, unauthorised account access, collusion, and bonus abuse;
• Customer Support: To respond to your support requests and maintain records of communications for quality assurance and dispute resolution;
• Platform Improvement: To analyse aggregated, anonymised usage data to improve game selection, platform performance, and user experience;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent or where lvwin has a legitimate interest in doing so, and subject always to your right to opt out.

4. Legal Basis for Processing

4.1 lvwin processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between lvwin and the Player — including account management, transaction processing, and dispute resolution;
• Legal Obligation: Processing required to comply with applicable laws and the requirements of the lvwin Operating Licence, including AML, KYC, and regulatory reporting obligations;
• Legitimate Interests: Processing necessary for lvwin's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided such interests are not overridden by the Player's privacy rights;
• Consent: Processing based on explicit consent provided by the Player, including the receipt of direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing

5.1 lvwin does not sell personal data to third parties. lvwin may share personal data with the following categories of recipients where strictly necessary:

• Payment Processors: Third-party payment service providers (including those facilitating Touch 'n Go eWallet, Boost, Maybank, CIMB, and Public Bank transactions) to whom financial data is disclosed solely for the purpose of processing player deposits and withdrawals;
• Game Providers: Licensed game software providers who may receive limited gaming session data necessary to deliver their games and maintain game integrity;
• KYC and AML Service Providers: Third-party identity verification and AML screening service providers engaged by lvwin to fulfil regulatory compliance obligations;
• Regulatory Authorities: Competent regulatory authorities, including the body governing lvwin's Operating Licence, to the extent required by law or licensing obligation;
• Law Enforcement: Relevant authorities where disclosure is required by law, court order, or in connection with the investigation of fraud, financial crime, or other criminal activity;
• Professional Advisors: Legal, audit, and compliance professionals engaged by lvwin under obligations of professional confidentiality.

5.2 Where data is shared with third-party service providers, lvwin requires such providers to implement appropriate technical and organisational measures to protect personal data and to process data only on lvwin's documented instructions.

6. International Data Transfers

6.1 As an internationally operated platform, lvwin may process and store personal data on servers located outside Malaysia. Where personal data is transferred outside the country of collection, lvwin ensures that appropriate safeguards are in place, including contractual data transfer agreements that provide an equivalent level of protection to that afforded under applicable Malaysian data protection law.

6.2 If you require further information about the safeguards in place for international transfers of your personal data, please contact lvwin's data protection team through the support channel described in Section 14.

7. Data Retention

7.1 lvwin retains personal data for the following minimum periods, subject to extension where required by law or regulatory obligation:

• Account and Identity Data: For the duration of the active account relationship and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• Transaction and Financial Data: For a minimum of seven (7) years from the date of the relevant transaction, in accordance with financial regulatory obligations;
• Gaming Data: For the duration of the active account and for a minimum of three (3) years following account closure;
• Communications Data: For a minimum of two (2) years from the date of the relevant communication, or longer where relevant to an unresolved dispute;
• Technical and Log Data: For a maximum of twelve (12) months, unless retained longer in connection with an active security investigation.

7.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with lvwin's data disposal procedures.

8. Your Data Rights

8.1 Subject to applicable law and any overriding legal or regulatory obligations, registered lvwin players have the following rights in respect of their personal data:

• Right of Access: The right to request a copy of the personal data held by lvwin about you;
• Right of Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right of Erasure: The right to request deletion of personal data, subject to lvwin's legal and regulatory retention obligations;
• Right to Restriction: The right to request that lvwin restricts the processing of your personal data in certain circumstances;
• Right to Object: The right to object to the processing of your personal data on the basis of legitimate interests, including direct marketing;
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where processing is based on consent or contract.

8.2 To exercise any of the above rights, please submit a written request through the lvwin in-platform live chat support or via the contact details in Section 14. lvwin will respond to all valid data rights requests within thirty (30) days.

9. Cookies and Tracking Technologies

9.1 lvwin uses cookies and similar tracking technologies on the lvwin.club platform. Cookies are small text files stored on your device by your browser that allow the platform to recognise your device and retain certain preferences and session information.

9.2 lvwin uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function correctly. These include session authentication cookies that maintain your lvwin login state and security cookies that prevent cross-site request forgery. These cookies cannot be disabled without impairing platform functionality;
• Functional Cookies: Used to remember your preferences such as language settings, remembered device status, and game lobby layout. Disabling these cookies may affect your personalised experience on the platform;
• Analytics Cookies: Used to collect anonymised information about how visitors use the lvwin platform, including page visit frequency and navigation paths. This data is used solely to improve platform performance and user experience;
• Marketing Cookies: Used to deliver relevant promotional content to returning visitors. These cookies are only placed with your consent and can be disabled at any time through your browser settings.

9.3 You may manage or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent you from completing the lvwin login process and accessing your account.

10. Security Measures

10.1 lvwin implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between the player's device and lvwin's servers;
• Encryption of sensitive data at rest, including KYC documentation and financial information;
• Role-based access controls limiting internal access to personal data to authorised personnel with a documented need;
• Regular security audits and penetration testing of the lvwin platform and underlying infrastructure;
• Multi-factor authentication requirements for internal administrative access to systems holding personal data;
• Incident response procedures for the detection, investigation, and notification of personal data breaches in accordance with applicable regulatory requirements.

10.2 Notwithstanding the above measures, no online platform can guarantee absolute security. Players are encouraged to use strong, unique passwords for their lvwin accounts and to enable two-factor authentication as an additional layer of personal account security.

11. Minors

11.1 The lvwin platform is strictly restricted to individuals aged 21 years and above. lvwin does not knowingly collect or process the personal data of individuals under the age of 21. Where lvwin discovers or has reasonable grounds to believe that personal data belonging to a minor has been collected, that data will be immediately deleted and the associated account will be permanently closed.

11.2 Parents or guardians who believe that a minor may have registered on or used the lvwin platform should contact lvwin's support team immediately via the in-platform live chat. lvwin will investigate all such reports promptly.

12. Third-Party Services and Links

12.1 The lvwin platform integrates with third-party services including payment processors, game software providers, and analytics tools. These third parties operate their own privacy policies, and lvwin is not responsible for the data practices of third-party services beyond the contractual data processing obligations described in Section 5.

12.2 Any links appearing on the lvwin platform that direct users to external websites are provided for informational purposes only. lvwin does not control the content or privacy practices of external websites and assumes no responsibility for them.

13. Policy Updates

13.1 lvwin reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered players via in-platform notification or email where practicable. The effective date of the current version of this Privacy Policy is stated at the top of this page.

13.2 Continued use of the lvwin platform following the posting of an updated Privacy Policy constitutes your acknowledgment of and agreement to the revised terms. lvwin recommends that players review this Privacy Policy periodically.

14. Contact Us

14.1 For all privacy-related enquiries, data rights requests, or complaints regarding lvwin's handling of your personal data, please contact the lvwin Data Protection team through the 24/7 live chat service available within the lvwin account dashboard.

14.2 Written correspondence may be directed to: [email protected] (this is a plain text address — not a clickable link).

14.3 If you are not satisfied with lvwin's response to a privacy complaint, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.