Privacy Policy — 17winrm

17winrm ("the Company", "we", "us", "our") operates the online sportsbook and live casino platform accessible at https://17winrm.cam (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who use the Platform, including registered members and visitors located in Malaysia and other jurisdictions.

This Privacy Policy ("Policy") sets out, in plain and formal English, the basis on which any personal data we collect from you, or that you provide to us, will be processed by17winrm. It applies to all registered members, account applicants, and any other persons who visit, browse, or otherwise interact with the Platform, regardless of the device or method of access used.

This Policy should be read in conjunction with our Terms and Conditions, which govern the overall contractual relationship between you and 17winrm. Where this Policy refers to "personal data", it means any information relating to an identified or identifiable natural person, including name, contact details, financial information, and digital identifiers such as IP addresses and device identifiers.

We take our obligations under applicable data protection standards seriously. 17winrm processes personal data only to the extent necessary for the purposes described in this Policy and applies appropriate technical and organisational measures to protect it against unauthorised access, loss, or misuse.

The following terms have the meanings set out below wherever they appear in this Privacy Policy:

• "Personal Data" — any information that relates to an identified or identifiable living individual; this includes names, email addresses, phone numbers, payment details, IP addresses, and device identifiers.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, erasure, or transmission, whether automated or manual.
• "Data Controller" — 17winrm, the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" — a third party that processes personal data on behalf of 17winrm pursuant to a written agreement and strictly within the scope of authorised instructions.
• "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.
• "Sensitive Data" — special categories of personal data that warrant heightened protection, including financial account details, identity document numbers, and information relating to health or gambling behaviour where relevant to responsible gambling obligations.
• "Member" — any individual who has completed the 17winrm registration process and holds a verified account on the Platform.
• "KYC" — Know Your Customer, the identity and age verification procedures17winrm is required to conduct in accordance with applicable licensing and anti-money laundering obligations.
• "Cookie" — a small text file placed on a user's device by the Platform for purposes including session management, analytics, and personalisation.
• "Third Party" — any entity other than 17winrm and the Member, including payment processors, KYC verification providers, analytics platforms, and regulatory authorities.

17winrm collects personal data that is necessary to provide the Platform's services, comply with regulatory obligations, and maintain platform security. The categories of personal data we collect are as follows:

Personal data is collected through the following channels and interactions with the 17winrm Platform:

• Direct Provision by the Member: When you complete the registration form, submit KYC documentation, make a deposit or withdrawal request, contact our support team, or respond to a survey or promotion, you directly provide personal data to 17winrm.
• Automated Technical Collection: As you interact with the Platform, we automatically collect technical and usage data through server logs, session tracking systems, and browser-based mechanisms. This includes your IP address, device identifiers, page navigation data, and bet/game activity logs.
• Cookies and Similar Technologies: The Platform uses cookies and similar browser-based tracking tools to manage user sessions, remember preferences, and collect aggregate analytics data. Further detail is provided in Section 10 of this Policy.
• Third-Party Sources: In limited circumstances, 17winrm may receive personal data from third-party KYC verification providers, fraud screening services, or payment processors as part of our compliance and security obligations. Such data is processed only to the extent necessary for those specific purposes.
• Public Sources: In cases where enhanced due diligence is required under our anti-money laundering obligations, 17winrm may verify or supplement Member information using publicly available data sources, including regulatory databases and publicly accessible records.

17winrm processes personal data only for the purposes described below. We do not use personal data for purposes incompatible with those for which it was originally collected without first obtaining any required additional consent or establishing another valid legal basis.

5.1 Account Administration

We use Identity Data, Contact Data, and Account Data to create, maintain, and administer your 17winrm account — including processing your registration, verifying your identity and age, managing account settings, calculating VIP tier status, and communicating account-related notifications.

5.2 Payment Processing

Financial Data is processed to facilitate deposits via Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank, DuitNow, FPX, and USDT TRC20, as well as to process withdrawal requests. Payment data is handled in accordance with applicable financial data security standards.

5.3 Legal and Regulatory Compliance

We are required by applicable licensing obligations and anti-money laundering regulations to conduct KYC verification, monitor transactions for suspicious activity, maintain records of account activity for specified retention periods, and cooperate with regulatory and law enforcement requests where legally required. Personal data processed for these purposes may include Identity Data, Financial Data, and Technical Data.

5.4 Fraud Prevention and Platform Security

Technical Data and Usage Data are processed to detect and prevent fraudulent activity, account takeovers, bonus abuse, collusion, and other security threats. This includes automated monitoring systems that flag unusual patterns in account behaviour for human review.

5.5 Responsible Gambling Monitoring

Account Data and Usage Data — including betting frequency, deposit patterns, and session duration — are analysed to identify Members who may be exhibiting signs of problem gambling behaviour. This processing is conducted in fulfilment of our responsible gambling obligations and the duty of care we owe to our Members.

5.6 Platform Improvement and Analytics

Aggregated and anonymised usage data is used to understand how Members interact with the Platform, identify technical issues, and inform product development decisions. Where possible, analytics processing uses data in anonymised or pseudonymised form.

5.7 Marketing Communications (Consent-Based)

Where you have explicitly opted in to receiving marketing communications from 17winrm, we will use your Contact Data and Marketing Data to send you information about relevant promotions, bonuses, and platform updates. You may withdraw your marketing consent at any time by contacting our support team or updating your account preferences.

17winrm relies on the following legal bases for processing personal data, consistent with applicable data protection principles:

• Contractual Necessity: Processing required to perform our obligations under the Terms and Conditions — including account management, payment processing, and withdrawal services — is conducted on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with KYC, anti-money laundering, regulatory reporting, and licensing obligations is conducted on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gambling monitoring, and aggregate analytics is conducted on the basis of 17winrm's legitimate interests, provided those interests are not overridden by your privacy rights.
• Consent: Processing for optional marketing communications is conducted solely on the basis of your express, freely given consent. You may withdraw consent at any time without affecting the lawfulness of any prior processing.

17winrm does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Personal data is shared only in the following limited and controlled circumstances:

• Payment Processors: Financial Data is shared with authorised payment processing partners — including Malaysian e-wallet operators and bank payment gateways — solely to facilitate deposit and withdrawal transactions. These partners process data as Data Processors under contractual obligations consistent with this Policy.
• KYC and Identity Verification Providers: Identity Data and supporting documentation may be shared with regulated third-party KYC service providers for the sole purpose of verifying Member identity and age in compliance with our licensing obligations.
• Fraud Prevention Services: Technical Data and Account Data may be shared with fraud screening services to detect and prevent fraudulent account activity, money laundering, and platform abuse.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or valid regulatory request, 17winrm may disclose personal data to relevant governmental, regulatory, or law enforcement authorities. We will, where legally permitted, notify affected Members of such disclosures.
• Corporate Successors: In the event of a merger, acquisition, restructuring, or asset sale involving 17winrm, personal data held by the Company may be transferred to the acquiring entity as part of the transaction, subject to equivalent data protection commitments.
• Professional Advisers: Legal, financial, and compliance advisers engaged by 17winrm may have access to personal data on need-to-know basis, subject to professional confidentiality obligations.

17winrm retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Specific retention periods are governed by the following principles:

• Active Account Data: Personal data associated with an active Member account is retained for the duration of the account relationship and for a period of no less than five (5) years following account closure, in accordance with standard anti-money laundering record-keeping requirements.
• Transaction Records: Financial transaction records — including deposit and withdrawal histories — are retained for a minimum of seven (7) years following the date of the transaction to satisfy regulatory record-keeping obligations.
• KYC Documentation: Identity verification documents submitted as part of the KYC process are retained for a minimum of five (5) years following account closure, or longer where required by applicable regulatory guidance.
• Support and Communications Data: Live chat transcripts, email records, and complaint correspondence are retained for a period of three (3) years following the resolution of the relevant enquiry or complaint.
• Technical and Usage Data: Log files and session data are typically retained for a period of twelve (12) months, unless a longer retention period is required for active fraud investigations or legal proceedings.
• Marketing Data: Marketing consent records and campaign response data are retained for the duration of the consent and for one (1) year following withdrawal of consent, for audit purposes.

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

17winrm implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the 17winrm Platform is encrypted using industry-standard 256-bit SSL/TLS protocols, consistent with the security standards employed by leading global financial institutions.
• Password Hashing: Member account passwords are stored exclusively in irreversibly hashed form using strong cryptographic algorithms. 17winrm does not store plaintext passwords and cannot retrieve them.
• Access Controls: Access to personal data within17winrm is restricted on a strict need-to-know basis. Staff who process personal data receive appropriate data protection training and are bound by confidentiality obligations.
• Server-Side Security: 17winrm's servers operate within secured data centre environments with physical access controls, network firewalls, intrusion detection systems, and regular security audits.
• Payment Security: Financial transactions are processed through compliant payment gateways. 17winrm does not store complete bank account or card numbers on its own servers.
• Incident Response: 17winrm maintains a data breach response procedure. In the event of a security incident affecting Member personal data, the Company will take immediate remedial action and notify affected Members and relevant authorities in accordance with applicable data breach notification requirements.

While 17winrm takes all reasonable precautions to protect your data, no internet-based system is entirely immune to security risks. Members are responsible for maintaining the security of their own account credentials and should contact our support team immediately if they suspect unauthorised access to their account.

The 17winrm Platform uses cookies and similar browser-based technologies to support platform functionality, session management, and aggregate analytics. The following categories of cookies are used:

You may control cookie settings through your browser's privacy configuration. Please note that disabling strictly necessary cookies will impair the functionality of the Platform and may prevent you from accessing certain features, including your account login. 17winrm does not use third-party advertising cookies or cross-site tracking technologies for commercial advertising purposes.

Subject to applicable data protection law and any overiding legal obligations, Members have the following rights in respect of their personal data held by 17winrm. Requests to exercise these rights should be submitted in writing to our support team at the contact details set out in Section 16.

The 17winrm Platform is strictly intended for individuals aged21 years and above. 17winrm does not knowingly collect, store, or process personal data relating to individuals under the age of 21.

All registration applications are subject to age verification procedures. Where the Company has reasonable grounds to believe that a registered Member or applicant is under the age of 21, the Account will be immediately suspended and any personal data collected will be processed solely for the purpose of confirming and documenting the underage status, after which it will be securely deleted in accordance with our data retention procedures.

If a parent or guardian becomes aware that a minor has submitted personal data to 17winrm without their consent, they should contact our support team immediately so that the relevant data can be identified and removed promptly.

The 17winrm Platform may contain references to, or integrations with, third-party services including payment gateways, KYC verification platforms, and analytics providers. These third parties operate under their own privacy policies and data protection frameworks, which are independent of this Policy.

17winrm is not responsible for the privacy practices or data processing activities of third-party services accessed in connection with your use of the Platform. We encourage Members to review the privacy policies of any third-party services they interact with, including payment providers such as Touch'n Go eWallet, Boost, GrabPay, and Malaysian banking portals, prior to submitting personal data to those services.

When you are redirected from the 17winrm Platform to a third-party payment gateway — for example, to complete a DuitNow or FPX bank transfer — the personal data you submit on that third-party interface is governed by that provider's own privacy policy, not by this Policy.

In the course of providing the Platform's services, personal data collected from Members may be transferred to, stored, or processed in jurisdictions outside Malaysia, including where17winrm's operational infrastructure, licensing entity, or third-party service providers are located.

Where personal data is transferred internationally, 17winrm takes appropriate steps to ensure that the transfer is conducted in accordance with applicable data protection standards and that adequate safeguards are in place to protect your personal data in the destination jurisdiction. Such safeguards may include contractual data processing agreements with third-party recipients that impose data protection obligations equivalent to those applicable under this Policy.

By using the 17winrm Platform, you consent to the transfer of your personal data to jurisdictions outside Malaysia where necessary for the purposes described in this Policy, subject to the safeguards described above.

17winrm reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, platform functionality, or our data processing practices. The "Last Updated" date at the top of this page will be revised to reflect the date of the most recent change.

Where amendments are material — meaning they significantly affect the nature of data we collect, the purposes for which we process it, or the rights available to Members — 17winrm will notify registered Members by email to the address on file, or through a prominent notice on the Platform, prior to the changes taking effect.

Minor clarifications, corrections, or reformatting changes that do not alter the substance of this Policy may be made without advance notice. Continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 17winrm, please contact our support team through the following channels. All privacy and data protection enquiries will be handled with priority and in accordance with applicable response time obligations:

• Email: [email protected] — please include "Privacy Request" or "Data Protection Enquiry" in your subject line to ensure prompt routing to our compliance team.
• Live Chat: Available 24 hours a day, 7 days a week through the in-Platform live chat function. Average response time: 3–5 minutes.
• Language of Communication: Privacy and data protection requests may be submitted in English, Bahasa Melayu, or Mandarin. Our support team will respond in the language of your request where possible.

17winrm commits to acknowledging all privacy-related requests within five (5) business days of receipt and to providing a substantive response within thirty (30) business days, or within any shorter timeframe required by applicable law.

For queries relating to the Terms and Conditions governing your use of the Platform, please refer to our Terms & Conditions page.