Privacy Policy — How Cawan4D Handles Your Personal Data

This Privacy Policy ("Policy") sets out the manner in which Cawan4D ("cawan4d", "we", "us", "our") collects, uses, processes, stores, and discloses personal data relating to users ("you", "your", "User") of the website located at https://cawan4d.cam and all associated services, features, and applications (collectively, the "Platform").

cawan4d is committed to protecting the privacy and personal data of all users, including players across Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and throughout Malaysia. We recognise that personal data is a valuable asset and that you have a right to know precisely how it is handled at every stage of its lifecycle on our Platform.

By accessing or using the cawan4d Platform, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with any provision of this Policy, you must cease using the Platform immediately. This Policy should be read alongside our Terms & Conditions.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, directly or indirectly, including name, identification number, contact details, location data, online identifiers, or factors specific to the physical, economic, or social identity of that person.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction, whether by automated or manual means.
• "Data Controller" means cawan4d, which determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of cawan4d in accordance with documented instructions and a binding 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 for a stated purpose.
• "KYC Data" means identity verification documentation and associated records collected as part of Know Your Customer compliance procedures, including government-issued identification and proof of address documents.

cawan4d collects Personal Data in connection with the registration, operation, and maintenance of your Account, as well as through your general use of the Platform. The categories of Personal Data we collect include:

cawan4d applies the principle of data minimisation: we collect only Personal Data that is necessary and proportionate to the specific purposes outlined in this Policy. We do not collect sensitive categories of personal data (such as health information, racial or ethnic origin, or political opinions) unless strictly required for responsible gambling support purposes, and only with your explicit consent.

cawan4d collects Personal Data through the following channels:

• Direct Submission: When you register an Account, complete KYC verification, make deposits or withdrawals, contact our support team, or respond to promotional communications, you voluntarily provide us with Personal Data.
• Automated Collection: When you access and use the Platform, we automatically collect Technical Data and Behavioural Data through server logs, cookies, pixel tags, and similar tracking technologies. This occurs each time you interact with the Platform, regardless of whether you are logged in.
• Third-Party Payment Providers: When you deposit or withdraw funds via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, or cryptocurrency networks, our payment partners may transmit relevant transaction data to us for the purpose of processing and reconciliation.
• Identity Verification Services: Where we engage third-party KYC verification providers to assist with identity confirmation, those providers may share verification outcomes and associated data with cawan4d.
• Fraud and Risk Intelligence: We may receive data from third-party fraud detection, AML screening, and risk intelligence services to assist in identifying and preventing fraudulent activity on the Platform.

cawan4d processes Personal Data for the following specific purposes:

1. Account Management: Creating and administering your cawan4d Account, including registration, authentication, password recovery, and Account closure.
2. Identity and Age Verification: Conducting KYC procedures to confirm that you are aged 21 or above and to verify your identity in accordance with our regulatory and compliance obligations.
3. Transaction Processing: Facilitating and recording all deposits, withdrawals, bonus credits, and related financial transactions conducted through the Platform via supported Malaysian payment methods and cryptocurrency channels.
4. Regulatory Compliance: Fulfilling our anti-money laundering (AML), counter-financing of terrorism (CFT), and applicable reporting obligations, including the retention of transaction and identity records for the prescribed statutory periods.
5. Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, bonus abuse, collusion, and other security threats to the Platform.
6. Customer Support: Responding to enquiries, resolving disputes, processing complaints, and providing general account assistance through our live chat and email support channels.
7. Responsible Gambling: Monitoring player behaviour patterns to identify potential indicators of problem gambling and to administer the responsible gambling tools available on the Platform, including deposit limits, loss limits, and self-exclusion.
8. Platform Improvement: Analysing aggregated usage data to identify performance issues, improve user experience, develop new features, and optimise the Platform for Malaysian players.
9. Marketing Communications: Where you have provided consent, sending promotional communications, bonus announcements, and platform news. You may withdraw this consent at any time by contacting our support team.

cawan4d relies on the following legal bases to process your Personal Data, consistent with applicable data protection principles:

• Contractual Necessity: Processing required to perform the contract between you and cawan4d — including Account creation, transaction processing, and customer support — is necessary for the provision of our services and is carried out on the basis of our contractual relationship with you.
• Legal Obligation: Processing carried out to comply with applicable laws and regulations, including KYC, AML, CFT, and record-keeping requirements, is conducted on the basis of legal obligation. This data cannot be deleted upon request to the extent that retention is legally mandated.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gambling monitoring, and platform improvement is based on cawan4d's legitimate interests, provided that such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and optional personalisation features is conducted solely on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

cawan4d does not sell, rent, or trade your Personal Data to any third party for commercial purposes. We may share your Personal Data only in the following circumstances and only to the extent necessary:

• Payment Service Providers: Financial transaction data is shared with our payment partners — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and the respective banking institutions — solely for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: KYC Data may be shared with third-party identity verification and AML screening service providers operating under binding data processing agreements that prohibit secondary use.
• Game and Content Providers: Your Account identifier and relevant gameplay data may be shared with licensed game software providers to enable access to and operation of their games on the Platform.
• IT and Infrastructure Providers: Personal Data may be accessible to cloud hosting, cybersecurity, and IT service providers engaged by cawan4d who are bound by strict confidentiality and data processing obligations.
• Regulatory and Law Enforcement Authorities: We will disclose Personal Data to competent regulatory authorities, law enforcement agencies, or courts of competent jurisdiction where we are legally required to do so, or where disclosure is necessary to protect the rights, property, or safety of cawan4d, our players, or the public.
• Corporate Transactions: In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of our assets, Personal Data held by cawan4d may be transferred to the relevant successor entity, subject to equivalent privacy protections.

cawan4d uses cookies — small text files stored on your device — and related technologies such as local storage, pixel tags, and session identifiers to operate and improve the Platform. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for core Platform functionality, including session management, authentication, and security. These cannot be disabled without impairing Platform operation.
• Performance Cookies: Used to collect aggregated, anonymised data about how Users interact with the Platform, enabling us to identify and fix errors, optimise loading performance, and improve navigation.
• Functional Cookies: Store your preferences — such as display language, currency settings, and responsible gambling tool configurations — to personalise your experience across sessions.
• Analytics Cookies: Enable cawan4d to analyse platform usage patterns, measure the effectiveness of features, and make data-driven decisions about product development.

cawan4d does not deploy third-party advertising or cross-site tracking cookies on its Platform. You may manage or disable non-essential cookies through your browser settings or device privacy controls. Note that disabling certain cookies may affect the availability of some Platform features.

cawan4d retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of your active Account and for a minimum of five (5) years following permanent Account closure, in accordance with AML and regulatory record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification, or longer if required by applicable regulatory obligations in force at the time.
• Transaction Records: Financial transaction records are retained for a minimum of seven (7) years from the date of each transaction, consistent with standard financial regulatory expectations.
• Support and Communication Records: Customer support correspondence is retained for three (3) years from the date of each interaction, or longer where a dispute is ongoing.
• Technical and Behavioural Data: Aggregated, anonymised technical usage data may be retained indefinitely for platform analytics purposes. Identifiable technical data is deleted or anonymised within twelve (12) months of collection where no longer required.
• Marketing Consent Records: Records of your consent to receive marketing communications are retained for the duration of your Account and for a period of three (3) years thereafter.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised in accordance with our internal data destruction procedures.

Subject to applicable law and any overriding legal obligations (including AML and KYC retention requirements), you have the following rights in respect of the Personal Data held by cawan4d:

To exercise any of the above rights, please contact our Data Protection team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days and respond substantively within 30 calendar days. Identity verification may be required before we can process your request.

cawan4d implements a comprehensive set of technical, organisational, and procedural security measures to protect Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the cawan4d Platform is encrypted using industry-standard TLS/SSL protocols. Personal Data stored on our servers is encrypted at rest using AES-256 or equivalent standards.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. All staff with access to Personal Data undergo background screening, data protection training, and are subject to binding confidentiality obligations.
• Multi-Factor Authentication: All internal systems containing Personal Data are protected by multi-factor authentication. We also offer two-factor authentication (2FA) to all cawan4d Account holders.
• Intrusion Detection: Our platform infrastructure is monitored 24 hours a day by automated intrusion detection and prevention systems, supplemented by periodic third-party security audits.
• Vulnerability Management: cawan4d conducts regular vulnerability assessments and penetration testing. Identified vulnerabilities are remediated according to a risk-based prioritisation framework.
• Incident Response: We maintain a documented data breach incident response plan. In the event of a confirmed breach, affected users will be notified without undue delay in accordance with applicable notification obligations.

While cawan4d takes all reasonable precautions to protect your Personal Data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your Account password and for ensuring your device and network are reasonably secured before accessing the Platform.

The cawan4d Platform is strictly intended for persons aged 21 years and above. We do not knowingly collect, process, or retain Personal Data from individuals below this age threshold. Age verification is a mandatory component of our KYC process, and we take all reasonable technical and procedural steps to prevent underage persons from registering or using the Platform.

If cawan4d becomes aware that Personal Data has been collected from a person below the age of 21 — whether through registration misrepresentation, fraudulent identity documentation, or any other means — we will immediately suspend the associated Account, delete the collected data to the extent permissible by law, and retain only such records as may be necessary for fraud reporting or regulatory compliance purposes.

If you are a parent or guardian and believe that a person under your care may have accessed or registered on the cawan4d Platform, please contact our support team immediately at [email protected].

cawan4d reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable law, regulatory guidance, or Platform operations. The "Last Reviewed" date at the top of this Policy will be updated to reflect the most recent revision.

Where changes are material — meaning they substantially affect your rights or the way we process your Personal Data — we will notify you via email to your registered address or via a prominent notice displayed on the Platform prior to the change taking effect. For non-material changes, continued use of the Platform following the updated Policy's effective date will constitute acceptance of the revised terms.

We recommend reviewing this Privacy Policy periodically to remain informed of our current data practices. Archived versions of prior policies are available upon written request to our support team.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the manner in which cawan4d processes your Personal Data, please contact us through the following channels:

• Email (Data Rights & Privacy Enquiries): [email protected] — please include "Privacy Enquiry" or "Data Rights Request" in the subject line
• Live Chat: Available directly through the cawan4d Platform interface, 24 hours a day, 7 days a week
• Responsible Gambling Concerns: If your query relates to responsible gambling tools or self-exclusion, please visit our dedicated Responsible Gambling page

We are committed to resolving all privacy-related enquiries promptly and fairly. If you are dissatisfied with our response to a privacy complaint, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.