awclub Privacy Policy

1. Introduction

awclub ("we", "us", "our", or the "Company") operates the online gaming platform accessible at awclub.win and any associated subdomains or mobile applications (the "Platform"). We are committed to protecting the personal data of all players and users of the awclub Platform in a manner consistent with applicable data protection legislation and the standards expected by Malaysian consumers who trust awclub with their financial and personal information.

This Privacy Policy ("Policy") describes what personal data awclub collects, why we collect it, how we use and protect it, who we may share it with, how long we retain it, and what rights you have in relation to your data. This Policy applies to all persons who access or use the awclub Platform, including registered players, visitors browsing the Platform without an account, and individuals who contact awclub support.

By using the awclub Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform. This Policy should be read together with the awclub Terms & Conditions.

2. Personal Data We Collect

awclub collects personal data that you provide directly to us, data generated automatically through your use of the Platform, and — in limited cases — data obtained from third-party verification services. The categories of personal data we collect include:

Category	Examples	Source
Identity Data	Full legal name, date of birth, nationality, government-issued ID number	Provided by you at registration or during KYC verification
Contact Data	Email address, Malaysian mobile number, mailing address	Provided by you at registration
Financial Data	Bank account details, FPX transaction references, e-wallet identifiers (Touch n Go, Boost), DuitNow ID, transaction history	Provided by you during deposit/withdrawal; received from payment processors
Account Data	Username, encrypted password, account preferences, bonus history, wagering history, game activity records	Generated through Platform use
Technical Data	IP address, device type, browser type and version, operating system, session timestamps, geolocation data (country/region level)	Collected automatically via Platform access logs and cookies
Communications Data	Live chat transcripts, support email correspondence, feedback submissions	Generated through your interactions with awclub support
Verification Data	Identity document images (MyKad, passport), selfie images for liveness checks	Provided by you during KYC/AML verification

awclub does not intentionally collect sensitive personal data (such as racial or ethnic origin, religious beliefs, or health data) unless specifically required for responsible gaming assessments, in which case it will only be processed with your explicit consent.

3. How We Use Your Personal Data

awclub uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your awclub player account, including authentication and session management.
• Service Delivery: To provide access to gaming products, process deposits and withdrawals via FPX, DuitNow, Touch n Go eWallet, Boost, and other supported payment channels, and to deliver bonuses and promotions applicable to your account.
• Identity Verification and KYC: To verify your identity and age (minimum 21 years) as required by our licensing obligations and anti-money laundering (AML) policies. This may involve sharing your data with accredited third-party identity verification providers.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, and other illegal activities on the awclub Platform.
• Regulatory Compliance: To comply with applicable legal and regulatory obligations under our international gaming authority licence, including record-keeping, AML reporting, and data subject request fulfilment.
• Customer Support: To respond to your enquiries, resolve complaints, and maintain records of our communications with you.
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling and to administer responsible gaming tools, including deposit limits, session limits, and self-exclusion requests.
• Platform Improvement: To analyse usage patterns, optimise game performance, and improve the awclub user experience using aggregated and anonymised analytics data.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where our legitimate interests apply. You may opt out of marketing communications at any time via your account settings or by contacting support.

4. Legal Basis for Processing

awclub processes your personal data only when a valid legal basis exists under applicable data protection law. The primary bases on which awclub relies are:

• Contractual Necessity: Processing required to perform our obligations under the awclub Terms & Conditions — including account administration, payment processing, and game service delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML requirements mandated by our gaming authority licence.
• Legitimate Interests: Processing for fraud prevention, Platform security, and analytics, where our legitimate interests do not override your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications and the collection of sensitive personal data for responsible gaming assessments, where you have provided explicit, freely given consent. You may withdraw consent at any time.

5. Data Sharing and Third Parties

awclub does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following limited and controlled circumstances:

• Payment Processors: FPX-participating Malaysian financial institutions, DuitNow network operators, and licensed e-wallet providers (Touch n Go eWallet, Boost) receive the minimum data necessary to process your transactions. These providers are bound by their own regulatory and contractual data protection obligations.
• Identity Verification Providers: Accredited KYC/AML service providers who assist with age verification and identity document authentication. Data shared is limited to identity documents and verification outputs.
• Game Content Providers: Third-party game software providers (such as Pragmatic Play, Playtech, and NetEnt) receive session tokens and anonymised player identifiers to deliver their games on the awclub Platform. These providers do not receive your personal identification data.
• Regulatory and Law Enforcement Authorities: awclub will disclose personal data to regulators, law enforcement agencies, or courts where required by applicable law, a valid legal order, or to protect the rights, safety, or property of awclub, its players, or the public.
• Professional Advisers: Lawyers, auditors, and consultants who provide professional services to awclub under strict confidentiality obligations.

Any third party that processes personal data on behalf of awclub does so under a data processing agreement that requires them to maintain appropriate security measures and to process the data only for the specified purpose.

6. Cookies and Tracking Technologies

awclub uses cookies and similar technologies on the Platform to enable core functionality, maintain session state, and improve performance. The types of cookies deployed include:

• Strictly Necessary Cookies: Required for authentication, session management, and security functions. These cannot be disabled without affecting Platform functionality.
• Performance Cookies: Anonymised analytics data used to understand how players navigate the Platform, identify slow-loading pages, and measure the effectiveness of Platform improvements.
• Functionality Cookies: Remember your language preferences, game settings, and interface choices.

You may manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect your awclub experience. awclub does not deploy third-party advertising cookies or cross-site tracking technologies.

7. Data Retention

awclub retains personal data for as long as necessary to fulfil the purposes outlined in this Policy, subject to the following principles:

• Active Accounts: Personal data is retained for the duration of your active awclub account relationship.
• Closed Accounts: Following account closure, awclub retains identity, financial, and transaction records for a minimum of five (5) years to comply with AML record-keeping obligations and applicable gaming regulatory requirements.
• Support Communications: Live chat transcripts and email correspondence are retained for a minimum of two (2) years for dispute resolution and quality assurance purposes.
• Technical Logs: Server access logs and security event records are retained for a period of twelve (12) months, after which they are securely deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identified individual.

8. Data Security

awclub implements a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit AES encryption for personal data stored in awclub databases
• TLS 1.3 encryption for all data transmitted between your device and the awclub Platform
• Multi-factor authentication controls for internal staff access to player data systems
• Regular third-party penetration testing and vulnerability assessments
• Role-based access controls ensuring that staff only access the minimum personal data required for their function
• Incident response procedures with defined notification timelines in the event of a data breach

While awclub takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your awclub account credentials and for ensuring the security of your own devices and internet connections.

9. Your Data Rights

Subject to applicable data protection law, you have the following rights in relation to your personal data held by awclub:

• Right of Access: Request a copy of the personal data awclub holds about you.
• Right of Rectification: Request correction of inaccurate or incomplete personal data.
• Right of Erasure: Request deletion of your personal data where it is no longer necessary for the purpose collected, subject to our legal retention obligations.
• Right to Restrict Processing: Request that we limit how we process your personal data in certain circumstances.
• Right to Data Portability: Request a machine-readable copy of your personal data where processing is based on consent or contractual necessity.
• Right to Object: Object to processing based on legitimate interests, including direct marketing.
• Right to Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact awclub via 24/7 live chat or by emailing [email protected] (plain text — not a clickable link). awclub will respond to all data rights requests within 30 calendar days. In complex cases, this may be extended by a further 30 days with prior notice.

10. Children's Privacy

The awclub Platform is strictly intended for persons aged 21 years and above. awclub does not knowingly collect personal data from individuals under the age of 21. If awclub becomes aware that personal data has been collected from a person under 21, it will promptly delete all associated data and close the relevant account. If you believe that a person under the age of 21 has registered on the awclub Platform, please contact support immediately.

11. International Data Transfers

awclub's primary data infrastructure is hosted on servers that may be located outside Malaysia. Where personal data is transferred internationally, awclub ensures that appropriate safeguards are in place, including standard contractual clauses approved by relevant data protection authorities, or transfers only to jurisdictions that provide an adequate level of data protection. awclub will not transfer personal data to jurisdictions that do not meet these standards.

12. Changes to This Privacy Policy

awclub reserves the right to update or modify this Privacy Policy at any time. Material changes will be communicated to registered players via Platform notification or email to the address on your awclub account, with a minimum of seven (7) days' notice before changes take effect, except where immediate amendment is required by law or regulatory directive. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Continued use of the awclub Platform following notification of changes constitutes your acceptance of the revised Policy.

13. Contact Us

For all privacy-related enquiries, data subject requests, or concerns regarding how awclub handles your personal data, please contact our Data Protection team:

• Live Chat: Available 24/7 on the awclub Platform — response within 2 minutes for urgent data concerns
• Email: [email protected] — for formal data subject access requests and written complaints

awclub is committed to resolving all privacy complaints promptly and will acknowledge receipt of formal complaints within 3 business days and provide a substantive response within 30 calendar days.