This Privacy Policy outlines Sure Win's commitment to protecting your personal data. By using the Sure Win platform, you agree to the practices described in this document. If you do not agree, please discontinue use of the platform and contact us for further enquiries.
01
Introduction & Scope of This Privacy Policy
Sure Win ("we", "the platform") is the responsible personal data operator for information collected from members and users of our platform in Malaysia. This Privacy Policy applies to all your interactions with Sure Win, including account registration, use of services, financial transactions, and communications with our team.
This document is drafted in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and international best practices in personal data management. We are committed to ensuring your data is used only for legitimate purposes, stored securely and not shared without reasonable grounds.
This policy does not cover third-party websites, applications or services that may be linked from the Sure Win platform. Please read those third parties' privacy policies separately.
02
Types of Personal Data We Collect
Sure Win collects various types of information depending on the services you use. The following are the main categories of data we collect:
| Data Category | Example Information | Primary Purpose |
|---|
| Identity | Full name, date of birth, MyKad/passport number | Identity verification (KYC) |
| Contact | Email address, phone number, residential address | Communications & notifications |
| Financial | Bank account number, e-wallet owner name | Deposit & withdrawal processing |
| Technical | IP address, device type, browser, operating system | Security & fraud detection |
| Usage | Betting history, games played, active session duration | Service enhancement & promotions |
| Communications | Live chat records, support emails, complaints | Issue resolution & quality control |
Sure Win does not collect special (sensitive) categories of data such as health information, religious beliefs, or political views. We only collect information that is strictly necessary to provide our online betting services.
03
How We Collect Your Personal Data
Your personal data is collected through the following channels:
3.1 Directly from You
- During the Sure Win account registration process
- When you complete the identity verification (KYC) form
- When you make a deposit or withdrawal using Touch 'n Go, DuitNow, GrabPay, Boost, ShopeePay, or FPX
- When you contact our customer support team via live chat or email
- When you complete a survey or feedback form
3.2 Automatically
- Through cookies and website tracking technologies (as described in Section 6)
- Server logs recording IP addresses, browser types and pages visited
- Game usage data generated while you play live casino, slots, or place Sports Betting wagers
- Device information used to access the Sure Win platform
3.3 From Third Parties
- Third-party identity verification providers we use for the KYC process
- Payment service providers (Touch 'n Go, banks, etc.) to verify transactions
- Live casino and sports game providers for game record purposes
04
Purposes for Which Your Personal Data Is Used
Sure Win uses your personal data solely for the following legitimate purposes:
- Service Delivery: Managing your account, processing bets, handling deposit and withdrawal transactions, and providing access to all games on the platform.
- Identity Verification: To fulfil the KYC (Know Your Customer) and AML (Anti-Money Laundering) requirements mandated by Malaysian law.
- Security: Detecting and preventing fraud, money laundering, unauthorised access, and other prohibited activities Terms & Conditions us.
- Communications: Sending transaction notifications, account updates, support responses and important service-related information.
- Service Improvement: Analysing usage patterns to improve the interface, platform speed and overall user experience.
- Marketing (with consent): Sending promotions, bonus offers and new game updates if you have consented to receive marketing communications.
- Legal Compliance: To comply with legal obligations, court orders or lawful requests from authorities in Malaysia.
You may withdraw your consent to receive marketing communications at any time by contacting our support team. This withdrawal does not affect your receipt of important service notifications related to your account.
05
Sharing Data with Third Parties
Sure Win does not sell, rent or disclose your personal data to third parties for their own commercial purposes. However, we may share data in the following limited circumstances:
5.1 Trusted Service Providers
We work with service providers who support Sure Win's operations, including:
- Payment processors and e-wallet providers (Touch 'n Go, DuitNow, GrabPay, Boost, ShopeePay, FPX) to process financial transactions
- Live casino game providers such as Evolution Gaming and Pragmatic Play Live for game result verification
- Cloud and hosting service providers that store platform data to high security standards
- Identity verification service providers for the KYC process
All these service providers are bound by strict data protection agreements and are only permitted to use your data for the specific purposes defined.
5.2 Legal Requirements
Sure Win may disclose your personal data when required by Malaysian law, court order, or a lawful request from law enforcement authorities, a financial intelligence unit, or a relevant government agency.
In all instances of data sharing described above, Sure Win will always ensure that only the minimum necessary data is shared and that all receiving parties are bound by appropriate confidentiality obligations.
06
Cookies & Tracking Technologies
Sure Win uses cookies and similar technologies to enhance the user experience, maintain platform security and analyse usage patterns. The following are the types of cookies we use:
Essential Cookies (Required)
Required for core platform functions — login, session security, transaction verification
Performance Cookies
Helping us understand how members use the platform so we can make continuous improvements
Functional Cookies
Saving your preferences such as language, region and display settings
Marketing Cookies
Used to display promotions relevant to your interests (can be declined)
You can manage your cookie settings through your browser. However, disabling essential cookies may affect the functionality of the Sure Win platform. For more information on how to manage cookies, please refer to your browser's documentation.
07
Data Security Measures
Sure Win implements a comprehensive range of technical and organisational measures to protect your personal data against unauthorised access, modification, disclosure, or destruction:
- 256-bit SSL Encryption: All data transmitted between your browser and Sure Win's servers is encrypted using industry-standard TLS/SSL protocols.
- Data-at-Rest Encryption: Sensitive data stored in our databases, including financial information and identification documents, is encrypted using modern encryption algorithms.
- Layered Access Controls: Access to members' personal data is strictly limited to staff who require it for their specific duties only, with a full audit log maintained for every access.
- 24/7 Security Monitoring: Sure Win's automated monitoring system works around the clock to detect unusual or suspicious activity in real time.
- Regular Security Testing: We conduct regular penetration testing and vulnerability assessments to ensure the security of our platform.
- Staff Training: All Sure Win staff who handle personal data receive comprehensive and regular data protection training.
While Sure Win takes all reasonable precautions, no security system is foolproof. In the event of a data breach that affects you, we will notify you within 72 hours and take immediate remedial action.
08
Your Rights as a Sure Win Member
Under Malaysia's PDPA 2010, you have the following rights regarding your personal data held by Sure Win:
1
Right of Access
You have the right to request a copy of the personal data we hold about you. All requests will be processed within 14 business days.
2
Right to Rectification
You may request that we correct or update any personal data that is inaccurate or out of date.
3
Right to Erasure
In certain circumstances, you may request the deletion of your personal data, subject to applicable legal requirements.
4
Right to Object
You may object to the use of your data for direct marketing purposes at any time, with no penalty.
5
Right to Restriction
You may request that we restrict the processing of your data in certain circumstances as provided for under the law.
6
Right to Complain
You have the right to lodge a complaint with Malaysia's Department of Personal Data Protection if you are dissatisfied with our response.
To exercise any of the above rights, please contact us by email at privacy@surewin-jit.com or via the platform's live chat. Please include your account identification details and the specific right you wish to exercise.
09
Data Retention Period
Sure Win retains your personal data for as long as necessary to fulfil the purposes stated in this policy or as required by Malaysian law:
- Active Account Data: Retained for the duration of your active account plus 5 years after account closure for audit and security purposes.
- Financial Transaction Records: Retained for 7 years in accordance with Malaysia's AML (Anti-Money Laundering) legal requirements.
- Support Communication Records: Retained for 2 years from the date of the last communication.
- Security Logs: Retained for 1 year for fraud detection and security investigation purposes.
- Cookie Data: Depending on the type of cookie — from the current session up to a maximum of 2 years.
Once the retention period expires, data will be securely deleted or anonymised so that it can no longer be linked to any individual.
10
Changes to This Privacy Policy
Sure Win reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements or platform operations.
When we make significant changes:
- The "Last Updated" date at the top of this document will be revised accordingly.
- Notifications will be sent via email or in-platform notifications to all registered members.
- For particularly significant changes, we may require you to reconfirm your consent.
Your continued use of the Sure Win platform after any changes to this policy take effect will be considered your acceptance of the amended policy. Please review this page periodically to ensure you are always aware of the latest version.
11
Contact Our Data Protection Officer
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by Sure Win, please contact us via:
- Privacy Email: privacy@surewin-jit.com
- General Support Email: support@surewin-jit.com
- Live Chat: Available 24/7 directly on the Sure Win platform
We are committed to responding to all privacy enquiries within 14 business days. For more complex matters such as data deletion requests or breach complaints, the response time may be longer, but we will keep you updated on the progress of your case.
If you are not satisfied with our response, you have the right to contact the Department of Personal Data Protection (JPDP) Malaysia for further assistance.
FAQ – Sure Win Privacy Policy
Absolutely not. Sure Win has never and will never sell, rent or disclose members' personal data to third parties for commercial purposes. Your data is only shared with service providers who assist in the platform's operations (such as payment processors) and in circumstances required by Malaysian law.
Email privacy@surewin-jit.com or use the platform's live chat, stating your request type (data access, deletion, correction, etc.) along with your Sure Win account number. Requests will be processed within 14 business days. Note: Full data deletion may not always be possible where there is a legal requirement to retain certain records, such as financial transaction records.
Yes. All financial information is transmitted and stored with 256-bit SSL encryption. We do not store full credit card numbers — only the last few digits and the cardholder's name for verification purposes. All transactions via Touch 'n Go, DuitNow, GrabPay, Boost, ShopeePay, and FPX are processed through PCI-DSS certified payment gateways.
Yes. You can opt out of marketing communications at any time by clicking the "unsubscribe" link in any of our promotional emails, or by contacting customer support and requesting to be removed from the marketing list. Requests will be processed within 5 business days. Note: You will still receive transactional emails and important notifications related to your account.