Privacy Policy — Winter4D

This Privacy Policy ("Policy") describes how Winter4D ("we", "us", "our", "the Company") collects, processes, stores, and discloses personal data obtained from individuals ("you", "User", "Member") who access or use the Winter4D website at https://winter4d.cam and all associated services, features, games, and payment facilities (collectively, "the Platform").

Winter4D operates as an online casino and sports betting platform primarily serving players across Malaysia, including users in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and other regions throughout the country. We are committed to handling your personal data in accordance with applicable data protection principles and international best practices.

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. Any sharing of data described in this Policy is limited to what is strictly necessary to operate the Platform, fulfil our legal obligations, and deliver the services you have requested.

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

• "Personal Data" means any information that directly or indirectly identifies a natural person, including but not limited to name, identification number, email address, phone number, location data, or online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, or erasure.
• "Data Controller" means Winter4D, which determines the purposes and means by which Personal Data is processed.
• "Data Processor" means any third party that processes Personal Data on behalf of Winter4D under a data processing agreement.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the User's agreement to the processing of their Personal Data.
• "KYC Data" means identity verification documents and information collected to comply with Know Your Customer and Anti-Money Laundering obligations.
• "Device Data" means technical information about the device and browser used to access the Platform, including IP address, browser type, operating system, and session identifiers.

We collect Personal Data from you through various means during your interaction with the Platform. The categories of data we collect are described below:

When you create a Winter4D account, we collect:

• Full legal name
• Date of birth (used for age verification — minimum 21 years)
• Email address
• Mobile phone number
• Residential address (including city and postcode)
• Preferred username and encrypted password

To comply with Anti-Money Laundering (AML) regulations and to verify your identity prior to processing withdrawals, we may collect:

• Copy of government-issued photo identification (e.g., MyKad for Malaysian residents, passport for non-citizens)
• Proof of residential address issued within the preceding three months
• Source of funds documentation where required by regulatory obligation

When you make deposits or request withdrawals using Malaysian payment methods (including Maybank2u, CIMB Clicks, Public Bank, Hong Leong Connect, DuitNow, FPX, Touch 'n Go eWallet, Boost, or GrabPay), we collect:

• Payment method type and associated account identifiers (masked)
• Transaction amounts in MYR
• Transaction timestamps and reference numbers
• Deposit and withdrawal history

Winter4D does not store full bank account numbers, full card numbers, or e-wallet PINs. Payment card details (where applicable) are handled directly by our PCI-DSS compliant payment processors.

• Game session records, including game type, stake amounts, results, and session duration
• Sports betting selections and wager history (e.g., Liga Super Malaysia, EPL, UFC markets)
• Responsible gambling settings and limit configurations
• Bonus uptake and wagering progress records

• IP address and approximate geolocation (used for fraud detection and jurisdiction verification)
• Browser type, version, and operating system
• Device identifiers and screen resolution
• Referring URL and session navigation data

• Records of customer support interactions via live chat and email
• Correspondence sent to or received from [email protected]
• Feedback, complaints, and dispute records

Winter4D processes your Personal Data for the following purposes:

Winter4D processes your Personal Data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is required to provide the Services you have requested, including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML, KYC, and counter-terrorism financing obligations.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your fundamental rights.
• Consent: Where you have freely provided specific consent to a particular processing activity — for example, opting in to receive promotional communications from Winter4D. You may withdraw your consent at any time by contacting [email protected].

Winter4D does not sell or rent your Personal Data to third parties. We share data only where necessary, and only with the categories of recipients listed below, each of whom is bound by appropriate data protection obligations:

• Payment Service Providers: We share transaction data with Malaysian payment processors (e.g., FPX gateway operators, e-wallet providers) solely to execute deposits and withdrawals you initiate.
• Identity Verification Services: We engage third-party KYC service providers to assist in verifying your identity. These providers receive the minimum data necessary to complete verification and are prohibited from using it for any other purpose.
• Game Studio Partners: Licensed international game studios that provide content to Winter4D may receive your Member ID and session data as required to deliver game functionality. No personally identifiable information beyond the necessary session identifiers is shared.
• Fraud Prevention and AML Services: We may share Device Data and transaction information with specialist fraud detection services to identify suspicious activity.
• Regulatory and Law Enforcement Authorities: We will disclose Personal Data to regulatory bodies, law enforcement agencies, or courts where required by applicable law, court order, or regulatory directive. We will notify you of such disclosure where we are legally permitted to do so.
• IT Infrastructure and Cloud Service Providers: Our platform infrastructure is supported by hosting and cloud service providers who process data on our behalf under strict data processing agreements.

All financial transactions on the Winter4D platform are denominated in Malaysian Ringgit (MYR). When you transact using any supported Malaysian payment channel — including Maybank2u, CIMB Clicks, Public Bank Online (PBe), Hong Leong Connect, DuitNow, FPX, Touch 'n Go eWallet, Boost, or GrabPay — the following data handling principles apply:

• Full bank account numbers, full card numbers, and e-wallet PINs are never stored on Winter4D servers. These are handled exclusively by the respective payment provider's secure infrastructure.
• Winter4D retains a record of the transaction amount, timestamp, method type, and anonymised payment reference for the purposes of account reconciliation, dispute resolution, and regulatory compliance.
• Transaction records are retained for a minimum of five (5) years following the conclusion of the Member relationship, in accordance with applicable financial record-keeping obligations.
• Where a chargeback or payment dispute arises, Winter4D may share the relevant transaction record with the payment provider and, if required, with the relevant financial authority.

Winter4D uses cookies and similar tracking technologies to operate the Platform, improve your experience, and maintain security. Cookies are small text files stored on your device that allow us to recognise returning visitors, maintain session states, and analyse usage patterns.

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens, security cookies, and load-balancing identifiers. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings and display options to enhance your experience across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how visitors interact with the Platform to help us identify areas for improvement. These cookies do not identify you personally.
• Security Cookies: Used by our fraud detection systems to identify anomalous session patterns and prevent unauthorised account access.

You may manage your cookie preferences through your browser settings. However, disabling strictly necessary cookies will prevent you from accessing core Platform features including account login and game functionality.

Winter4D retains Personal Data for no longer than is necessary to fulfil the purpose for which it was collected, subject to any legal or regulatory retention obligations. Our retention schedule is as follows:

• Active Account Data: Retained for the full duration of the Member relationship and for five (5) years following account closure, to comply with AML and KYC record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years from the transaction date.
• Gaming Activity Logs: Retained for three (3) years from the date of the session, unless a shorter period is legally permissible.
• Customer Support Communications: Retained for two (2) years from the date of the last interaction unless the matter relates to an unresolved dispute.
• Marketing Consent Records: Retained for as long as you remain opted-in, and for two (2) years following opt-out, as evidence of the consent history.

Upon expiry of the relevant retention period, Personal Data is securely deleted or anonymised such that it can no longer be associated with an identified individual.

Winter4D implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• Encrypted storage of passwords using industry-standard hashing algorithms (bcrypt)
• Multi-factor authentication (MFA) available for all Member accounts
• Regular penetration testing and vulnerability assessments conducted by independent security specialists
• Role-based access controls limiting internal staff access to Personal Data on a need-to-know basis
• Intrusion detection and prevention systems monitoring platform infrastructure in real time
• Encrypted backups stored in geographically separate data centres

In the event of a data breach that is likely to result in a high risk to your rights and freedoms, Winter4D will notify affected Members and, where applicable, the relevant supervisory authority, within the timeframe required by applicable law.

You are responsible for maintaining the confidentiality of your own account credentials. If you suspect that your account has been compromised, please contact our support team at [email protected] immediately.

You hold a number of rights with respect to the Personal Data that Winter4D holds about you. To exercise any of the rights described below, please submit a written request to [email protected] with the subject line "Data Rights Request" and your registered account email address. We will respond within thirty (30) days.

• Right of Access: You may request a copy of the Personal Data we hold about you, together with information about how it is being processed.
• Right to Rectification: You may request the correction of any inaccurate or incomplete Personal Data we hold about you.
• Right to Erasure: In certain circumstances, you may request the deletion of your Personal Data. Note that this right is subject to overriding legal obligations, including AML record-keeping requirements, which may prevent complete erasure.
• Right to Restriction of Processing: You may request that we restrict the processing of your Personal Data in certain circumstances, for example while a dispute about accuracy is being resolved.
• Right to Data Portability: Where technically feasible, you may request a copy of your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your Personal Data where that processing is based on our legitimate interests. You also have an absolute right to object to processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Winter4D operates exclusively as an adult gaming platform. Our Services are strictly restricted to individuals aged 21 and above. We do not knowingly collect, process, or store Personal Data relating to individuals under 21 years of age.

If we become aware that Personal Data has been submitted by or on behalf of a person under 21 years of age, that data will be immediately deleted and the associated account will be permanently closed. All funds deposited by underage users will be handled in accordance with our Terms & Conditions and applicable regulatory requirements.

If you have reason to believe that a person under 21 years of age has registered an account with Winter4D, please notify us immediately at [email protected].

In the course of providing our Services, your Personal Data may be transferred to and processed in countries outside of Malaysia. For example, certain platform infrastructure and third-party service providers may be located in jurisdictions where data protection laws differ from those applicable in Malaysia.

Where such transfers occur, Winter4D ensures that appropriate safeguards are in place to protect your Personal Data, including but not limited to contractual clauses that impose data protection obligations on the recipient, equivalent in substance to those applicable in the originating jurisdiction.

By using the Platform, you consent to the transfer of your Personal Data to third-party Data Processors located in other countries, subject to the safeguards described in this clause.

Winter4D reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Material changes to this Policy will be communicated to registered Members via email notification to the address on file and/or by a prominent notice displayed on the Platform prior to the change taking effect.

The "Last Updated" date at the top of this page reflects the date on which the most recent version of this Policy entered into effect. We encourage you to review this Policy periodically to remain informed of how we protect your Personal Data.

Your continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree to the revised terms, you should cease using the Platform and contact us to request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by Winter4D, please contact our Data Protection team using the details below:

For questions relating to our Terms of Service, please refer to our Terms & Conditions. For guidance on responsible gambling tools, deposit limits, and self-exclusion, please visit our Responsible Gambling page.