Privacy Policy will33 – Malaysian Member Data Protection

1 Introduction – Who We Are and Why This Policy Matters

This Privacy Policy is published by will33 ("Platform", "We") and applies to all registered members, users browsing the will33 website, and mobile app users. This document transparently explains how we collect, use, store, protect, and in certain circumstances disclose your personal data when you use will33's services.

Will33 understands that trust is the foundation of our relationship with every member. Your privacy is not merely a legal obligation to us – it is a core value we uphold in every operational decision. This policy is written in plain, straightforward language rather than confusing legal jargon, so every Malaysian member can truly understand their rights.

2 Personal Data We Collect

Will33 collects your personal data through several channels – during account registration, through your use of the platform, and via your interactions with our support team. Below are the categories of data we collect and their purposes:

Will33 does not collect sensitive data such as medical information, religious beliefs, political views, or biometric data, except where required by law and with your explicit consent.

3 How We Use Your Data

The personal data we collect is used solely for legitimate, stated purposes. will33 does not use member data for purposes beyond the scope outlined below without first obtaining fresh consent from you:

• Account management: To create, verify, and manage your will33 account — including the login process, identity verification, and password resets.
• Transaction processing: Handles deposits via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, Maybank2u, CIMB Clicks, and FPX, and securely processes winning withdrawals to your account.
• Security and fraud prevention: Detecting and preventing unauthorised access, fraudulent activity, money laundering, and misuse of the will33 platform.
• Legal compliance: Fulfils legal obligations under Malaysian legislation, including anti-money laundering (AML) and Know Your Customer (KYC) requirements.
• Customer support: To enable the will33 support team to assist you effectively with inquiries, complaints, and technical issues.
• Service communications: Sends important notifications about your account, changes to our terms, promotions you are eligible for, and relevant security updates.
• Platform improvements: Analyses usage patterns in aggregate — not at the individual level — to improve the user experience, identify technical issues, and develop useful new features.

4 Disclosure of Data to Third Parties

Will33 does not sell, rent, or disclose members' personal data to third parties without your consent. However, in limited and specific circumstances, we may need to share data with certain parties as follows:

• Payment service providers: eWallet providers (Touch 'n Go, GrabPay, Boost, ShopeePay) and banks (Maybank, CIMB) receive only the minimum transaction data required to process your deposits and withdrawals. All providers are bound by strict confidentiality agreements.
• Relevant authorities: will33 may be required to disclose member data to Malaysian authorities — such as Bank Negara Malaysia, the Companies Commission of Malaysia, or the police — when required by law or a valid court order.
• Technology providers: Certain server infrastructure and technical services are supported by certified technology providers who are bound by strict data protection agreements with will33. They are not permitted to use member data for their own purposes.
• Game providers: In the context of certain games, minimal session data may be shared with licensed game providers for strictly technical purposes only. No personally identifiable information is shared with game providers.

In all cases of data disclosure, will33 ensures that the receiving party is bound by confidentiality obligations equivalent to or stricter than those in our own privacy policy. will33 consistently strives to minimise the amount of data shared to the absolute minimum necessary.

5 Data Security & Protection Measures

Will33 continuously invests in the latest cybersecurity infrastructure to ensure every member's personal data is protected from external threats. The key security measures we have in place are as follows:

• SSL 256-bit Encryption: All communications between your device and will33's servers are encrypted using 256-bit SSL/TLS protocols — the same standard used by major banking institutions in Malaysia.
• Secure password storage: Member passwords are never stored in plain text. All passwords are processed through a strong hashing algorithm with a unique salt applied to each account.
• Two-factor authentication (2FA): will33 members are encouraged to enable 2FA for an added layer of protection — ensuring that even if your password falls into the wrong hands, your account remains secure.
• 24/7 monitoring: will33's cybersecurity team monitors account activity and server traffic around the clock to detect and respond to any threats in real time.
• Internal access controls: Member data is accessible only to will33 staff with a legitimate operational need. All access is logged, audited, and regularly monitored by the internal security team.
• Regular penetration testing: will33 conducts regular security testing and vulnerability audits by certified third parties to identify and resolve any weaknesses before they can be exploited.

While will33 takes all reasonable steps to protect your data, no security system is entirely infallible. Should any security incident occur that affects member data, will33 is committed to notifying the affected members within 72 hours and taking immediate remedial action.

6 Use of Cookies and Tracking Technologies

Will33 uses cookies and similar tracking technologies to enhance your experience on our platform. Below is an explanation of the types of cookies we use and their purposes:

• Session cookies: Required to maintain your login status during an active session. This cookie is automatically deleted when you close your browser or log out of your will33 account.
• Preference cookies: Saves your preferences such as language, time zone, and display settings to ensure a more personalised experience each time you visit the will33 platform.
• Security cookies: This helps will33's systems identify suspicious activity and protect your account from unauthorised access attempts or automated attacks.
• Internal analytics cookies: Collecting aggregated usage data (with no individual identification) to understand how members use the will33 platform, so we can continually improve the user experience.

Will33 does not use third-party tracking cookies for advertising purposes. You can manage cookie settings through your browser preferences, although disabling certain cookies may affect the functionality of some parts of the will33 platform.

7 Data Retention Period

Will33 retains members' personal data only for as long as necessary for the purposes stated in this policy, or as required by Malaysian law. The following are our data retention guidelines:

• Active account data: Retained for as long as your account remains active on the will33 platform. Data is updated whenever you make changes to your profile information.
• Financial transaction records: Retained for a minimum of 7 years in accordance with Malaysian accounting and anti-money laundering legal requirements, even after account closure.
• Security logs: Retained for 12 months for security investigation and dispute resolution purposes where required.
• Support chat logs: Retained for 24 months for issue resolution reference and service quality improvement.
• Account closed: Following account closure, data that is no longer required for legal compliance will be deleted or anonymised within 90 days.

8 Cross-Border Data Transfers

As an online casino platform operating in a global digital environment, some data may be processed outside Malaysia by certified technical infrastructure providers. In all cases, will33 ensures that:

• Data transfers only take place to countries or entities that provide a level of data protection equivalent to or higher than Malaysia's standards.
• Legally binding data protection agreements are in place between will33 and all vendors that process member data outside Malaysia.
• Financial data and sensitive identity information are processed in accordance with strict international financial compliance standards.
• Will33 retains full control over member data even when it is processed by third-party providers.

Will33 does not transfer members' personal data to countries known to have inadequate data protection or that are subject to relevant international restrictions.

9 Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and the international privacy principles we adhere to, you have the following rights regarding your personal data held at will33. To exercise any of these rights, contact us at support@will33.best:

• Access rights: You have the right to request a copy of the personal data we hold about you, in a readable format.
• Right to rectification: If your personal data is inaccurate or out of date, you have the right to request a correction promptly.
• Right to erasure: You may request the deletion of your personal data under certain circumstances — for example, when the data is no longer needed for its original purpose — subject to applicable legal retention requirements.
• Right to restrict processing: You may request that we restrict the processing of your data in certain circumstances while a dispute is being resolved.
• Right to object: You may object to the processing of your data for specific purposes such as marketing communications – whichever is applicable.
• Data portability right: You may request your data in a structured, portable format for transfer to another service provider where technically feasible.

Will33 is committed to responding to all privacy rights requests within 30 days of receipt. For complex cases, this period may be extended up to 60 days, with prior notice to you.

10 Children's Privacy

Will33 is an online casino platform intended exclusively for adults aged 18 and above. We do not knowingly collect or process the personal data of individuals under the age of 18.

If you believe that someone under the age of 18 has registered an account on will33 or that their data has been collected without appropriate consent, please contact us immediately at support@will33.best. will33 will take prompt action to close the account in question and delete all associated data.

11 Changes to This Privacy Policy

Will33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, new legal compliance requirements, or platform service expansions. When material changes are made, we will:

• Updating the "Last Updated" date at the top of this document.
• Sending email notifications to all active members outlining key changes, no fewer than 14 days before the changes take effect.
• Displaying a prominent notice on the will33 platform homepage for a set period following the implementation of any changes.

Continued use of the will33 platform after the effective date of any policy change constitutes acceptance of the updated terms. If you disagree with the changes made, please contact our support team to discuss further or to initiate the account closure process.

12 Contact will33's Privacy Officer

Will33 has appointed an internal privacy officer to oversee compliance with our privacy policy and handle data-related enquiries. If you have any questions or concerns, or wish to exercise your privacy rights, please reach us through the following channels:

• Privacy email: support@will33.best – include "Privacy Inquiry" in the subject line for faster processing.
• Live chat: Available 24/7 within the will33 platform – select the "Data Privacy" category in the chat menu to be connected with the relevant team.
• Response time: We are committed to responding to all privacy enquiries within 3 business days.