Privacy Policy
Betwoon Platform

1. Introduction

This Privacy Policy ("Policy") describes how Betwoon ("we", "us", "our") collects, uses, stores, shares, and protects personal data in connection with your use of the betwoon platform accessible at https://betwoon.cam and its associated mobile applications and services (collectively, the "Platform").

We are committed to protecting the privacy of all users of the betwoon Platform, including players registered from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and other locations across Malaysia. This Policy is designed to be transparent, readable, and comprehensive — not to obscure how your data is handled.

If you have questions about this Policy at any time, please contact our Data Protection contact using the details provided in Section 14.

2. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or could reasonably be used to identify you as an individual, whether directly or in combination with other available information.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
• "Data Subject" means the individual to whom Personal Data relates — in this context, you as registered or prospective user of the Platform.
• "Third Party" means any entity other than you and Betwoon, including payment processors, KYC verification providers, and technical infrastructure suppliers.
• "Cookie" means a small data file placed on your device by the Platform to support session management, security, and user experience functions.
• "KYC" means Know Your Customer — mandatory identity verification processes required prior to withdrawal processing.

3. Personal Data We Collect

Betwoon collects Personal Data through several channels: information you provide directly, information generated by your use of the Platform, and information received from authorised third-party service providers. The following table summarises the categories of Personal Data we collect:

3.1 Data You Are Not Required to Provide

You are not required to provide Personal Data beyond what is necessary to create an account and operate it. However, failure to provide required information (such as KYC documents) may prevent Betwoon from processing withdrawals or providing certain services.

4. How We Use Your Personal Data

Betwoon uses Personal Data strictly for the purposes set out below. We do not use your data for any purpose incompatible with those listed:

• Account Administration: Creating and managing your registered account, verifying your identity, and maintaining account security.
• Transaction Processing: Facilitating deposits and withdrawals via Malaysian payment channels including DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, Touch 'n Go eWallet, Boost, and GrabPay.
• KYC and AML Compliance: Verifying your identity and monitoring transactions to detect and prevent fraud, money laundering, and other illegal activities as required by applicable standards.
• Platform Improvement: Analysing usage patterns to improve Platform performance, game selection, interface design, and overall user experience.
• Customer Support: Responding to enquiries, complaints, and requests submitted via live chat or email.
• Responsible Gambling: Monitoring account activity to identify patterns consistent with problem gambling and to apply player protection tools where appropriate.
• Communications: Sending you transactional communications (e.g., deposit confirmations, withdrawal notifications, account alerts). Marketing communications are sent only with your consent and can be opted out of at any time.
• Legal and Regulatory Obligations: Retaining records as required by applicable law, regulatory direction, or legal proceedings.

5. Legal Basis for Processing

Betwoon processes your Personal Data one or more of the following legal bases, depending on the specific activity:

1. Contractual Necessity: Processing that is necessary to perform our contractual obligations to you under the Terms & Conditions — for example, processing deposits and withdrawals, managing your account, and providing the Platform services you have requested.
2. Legal Obligation: Processing that is required to comply with applicable laws and regulations, including anti-money laundering (AML) legislation, KYC requirements, and record-keeping obligations.
3. Legitimate Interests: Processing that is necessary for our legitimate business interests — such as fraud prevention, Platform security, and service improvement — provided such interests are not overridden by your privacy rights.
4. Consent: Processing based on your freely given, specific, and informed consent — for example, where you have opted in to receive marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Third Parties

Betwoon does not sell, rent, or otherwise transfer your Personal Data to third parties for their own commercial purposes. We may share Personal Data with the following categories of third party, strictly as necessary:

• Payment Service Providers: Banks and e-wallet operators (including Maybank, CIMB, Public Bank, Hong Leong, DuitNow / FPX operators, Touch 'n Go eWallet, Boost, and GrabPay) that process your transactions. These providers are bound by their own privacy and security standards.
• KYC and Identity Verification Providers: Third-party services used to verify your identity documents and screen against applicable sanction and watchlists.
• Technology Infrastructure Providers: Cloud hosting, server management, and security service providers who process data solely on our behalf under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: Where required by law, court order, or regulatory direction, we may disclose Personal Data to relevant authorities in Malaysia or other applicable jurisdictions.
• Professional Advisors: Legal, accounting, or compliance advisors bound by professional confidentiality obligations where disclosure is necessary to obtain professional advice.

7. Cookies & Tracking Technologies

The betwoon Platform uses cookies and similar technologies (collectively, "Cookies") to support essential functions, maintain session security, and improve your user experience. Cookies are small data files stored on your device.

7.1 Types of Cookies We Use

7.2 Cookies We Do Not Use

Betwoon does not deploy third-party advertising or behavioural profiling cookies. We do not participate in cross-site tracking networks for the purpose of serving targeted advertising to you on other websites.

7.3 Managing Cookies

Most browsers allow you to control Cookie settings through their settings menu. Please note that disabling essential Cookies may impair your ability to log in, place bets, or use secure functions of the Platform.

8. Data Retention

Betwoon retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy applicable legal, regulatory, and reporting obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your account relationship with Betwoon and for a minimum of five (5) years following account closure, as required by AML and KYC record-keeping standards.
• Transaction Records: Retained for a minimum of seven (7) years in accordance with applicable financial record-keeping requirements.
• Support Communications: Retained for three (3) years from the date of the last communication.
• Technical and Log Data: Retained for up to twelve (12) months, after which it is aggregated and anonymised.
• Marketing Consent Records: Retained until consent is withdrawn and for one (1) year thereafter as record of the original consent.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be used to identify you.

9. Data Security

Betwoon implements a comprehensive set of technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, destruction, or disclosure:

• Encryption in Transit: All data transmitted between your device and the Platform is encrypted using TLS/SSL (256-bit) protocols. HTTPS is enforced across the entire Platform.
• Encryption at Rest: Sensitive data fields, including identity and financial information, are encrypted in our databases using industry-standard encryption algorithms.
• Access Controls: Internal access to Personal Data is restricted on a strict need-to-know basis. All staff with access to Personal Data undergo mandatory data protection training.
• Penetration Testing: Betwoon conducts regular security assessments and penetration tests to identify and remediate vulnerabilities.
• Incident Response: We maintain a documented security incident response procedure. In the event of a data breach affecting your rights, we will notify you in accordance with applicable legal obligations.

Whilst Betwoon takes all reasonable steps to protect your Personal Data, no method of electronic transmission or storage is entirely without risk. You are responsible for maintaining the security of your account credentials and for notifying us promptly if you suspect any unauthorised account access.

10. Your Data Rights

Subject to applicable legal exceptions (including our AML and KYC retention obligations), you have the following rights in relation to your Personal Data held by Betwoon:

1. 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.
2. Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. Basic account details (such as contact information) can be updated directly via your account settings.
3. Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to any overiding legal retention obligations.
4. Right to Restrict Processing: You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while we verify the accuracy of data you have disputed.
5. Right to Data Portability: You may request that we provide your Personal Data in a structured, machine-readable format for transmission to another service provider where technically feasible.
6. Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
7. Right to Object: You may object to processing based on our legitimate interests, including direct marketing communications.

To exercise any of these rights, please contact our support team via the details provided in Section 14. We will respond to all verifiable requests within thirty (30) days. We may require identity verification before processing a data rights request.

11. International Data Transfers

Certain infrastructure and service providers used by Betwoon may be located outside of Malaysia. Where Personal Data is transferred internationally connection with these services, Betwoon ensures that appropriate safeguards are in place to protect the data, consistent with applicable data protection requirements.

These safeguards may include contractual obligations on the receiving party to apply data protection standards equivalent to those applicable Betwoon, and the use of providers certified under recognised international security frameworks.

12. Children's Privacy

The betwoon Platform is strictly intended for individuals aged21 and above. We do not knowingly collect Personal Data from individuals under the age of 21. Registration by minors is prohibited under our Terms & Conditions.

If we become aware that Personal Data has been collected from a person under 21 without appropriate parental consent, we will take immediate steps to delete that information and close the associated account.

13. Updates to This Privacy Policy

Betwoon may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory guidance. Where amendments are material, we will notify registered players via the Platform's notification system or by email to the address associated with your account.

The "Last Updated" date displayed at the top of this page and in the page hero indicates the date on which this Policy was most recently revised. We encourage you to review this Policy periodically. Your continued use of the Platform after any updated Policy is published constitutes your acceptance of the revised terms.

14. Contact Us

For any questions, concerns, or requests related to this Privacy Policy or the processing of your Personal Data, please contact the Betwoon team using the following details: