HibikiWin Privacy Policy

HibikiWin ("we", "us", "our", "the Company", "the Platform") is committed to protecting the privacy and personal data of all individuals who access or use our online gaming and sports betting services at hibikiwin.cam. This Privacy Policy ("Policy") explains, in transparent and accessible language, how we collect, use, store, share, and otherwise process personal data in connection with your use of the Platform.

This Policy applies to all registered players, visitors to the Platform, and any individual whose personal data is processed by HibikiWin in connection with the provision of our services. By registering an account, depositing funds, or otherwise using any feature of HibikiWin, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions and Responsible Gambling Policy, both of which form part of the complete agreement governing your use of HibikiWin.

For the purpose of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — an individual who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, or online identifier.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means HibikiWin, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" means any third party that processes personal data on behalf of HibikiWin pursuant to written instructions and data processing agreements.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they signify agreement to the processing of their personal data.
• "KYC" (Know Your Customer) means the mandatory identity and document verification process undertaken to comply with anti-money laundering (AML) and licensing obligations.
• "Cookie" means a small text file placed on your device by the Platform to facilitate session management, analytics, and user experience personalisation.

HibikiWin collects personal data across several categories, as detailed in the table below. We collect only what is necessary for the specified purpose and do not collect data speculatively or without clear justification.

HibikiWin collects personal data through the following means:

4.1 Directly From You

The majority of personal data we hold is provided directly by you when you: register an account on the Platform; complete KYC verification by uploading identity documents; make a deposit or withdrawal using methods such as Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, or Hong Leong; contact our support team via live chat or email; or respond to any survey, promotion, or feedback request we make available.

4.2 Automatically via Technology

When you visit or use the Platform, certain technical data is collected automatically through our servers, analytics tools, and cookies — including your IP address, device type, browser version, pages visited, session duration, and in-game activity. This data is collected to maintain platform security, detect fraud, and improve your user experience.

4.3 From Third Parties

We may receive personal data about you from authorised third-party service providers, including: identity verification and KYC service providers; payment processors and e-wallet operators; fraud prevention and AML screening services; and analytics providers operating under data processing agreements with HibikiWin. In each case, we verify that the third party has a lawful basis for sharing data with us.

HibikiWin processes your personal data for the following specific and documented purposes:

• Account Management: Creating, maintaining, verifying, and administering your registered player account, including processing deposits and withdrawals in MYR and supported cryptocurrencies.
• Regulatory Compliance: Fulfilling our obligations under applicable international gaming licensing requirements, anti-money laundering (AML) regulations, and KYC mandates — including age verification to enforce our strict 21+ minimum age policy.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, account takeover attempts, money laundering, and other prohibited conduct that threatens the integrity of the Platform or the safety of our players.
• Service Improvement: Analysing aggregated usage data to understand how the Platform is used, identify technical issues, improve game performance, and develop new features that better serve our Malaysian player community.
• Responsible Gambling: Monitoring wagering patterns and account behaviour to identify players who may be at risk, enabling our responsible gambling team to intervene appropriately and provide access to support resources.
• Customer Support: Responding to your queries, complaints, and support requests in a timely and effective manner, and maintaining records of interactions for quality assurance and dispute resolution.
• Marketing Communications: Sending you information about promotions, bonuses, and new features — but only where you have explicitly opted in to receive such communications. You may withdraw marketing consent at any time.
• Legal Proceedings: Establishing, exercising, or defending legal claims arising in connection with your use of the Platform.

HibikiWin processes personal data on the following legal grounds, depending on the specific purpose of processing:

• Performance of Contract: Processing that is necessary to provide you with the services you have requested — including account management, payment processing, and game delivery — is based on the contractual relationship established when you register and accept our Terms & Conditions.
• Legal Obligation: Processing required for us to comply with our regulatory obligations under applicable international gaming licensing conditions, AML laws, and KYC requirements is carried out on the basis of legal obligation.
• Legitimate Interests: Fraud prevention, platform security, responsible gambling monitoring, and service improvement activities are carried out on the basis of HibikiWin's legitimate interests, provided those interests do not override your fundamental rights and freedoms.
• Consent: Marketing communications and certain non-essential cookie placements are processed solely on the basis of your explicit, freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

HibikiWin does not sell, rent, or otherwise commercially exploit your personal data. We share your data only in the following limited and clearly defined circumstances:

7.1 Service Providers (Data Processors)

We engage third-party companies to provide services on our behalf — including KYC and identity verification providers, payment processors (covering e-wallets such as Touch 'n Go and GrabPay as well as FPX-connected banks), hosting and infrastructure providers, customer support platform providers, and fraud detection services. These parties act as data processors under written agreements that restrict their use of your data to the specific service they provide for us.

7.2 Regulatory and Law Enforcement Authorities

Where required by applicable law, court order, or the instructions of a competent regulatory or law enforcement authority, we may disclose personal data without prior notice to you. We will, where legally permissible, attempt to notify you of any such disclosure.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of HibikiWin's business assets, personal data held about registered players may be transferred to the acquiring entity. We will provide reasonable advance notice of any such transfer and the applicable privacy terms of the successor entity.

HibikiWin retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable licensing conditions and legal obligations. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of the active account relationship plus a minimum of five (5) years following account closure, as required under applicable AML and gaming licensing obligations.
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with international financial record-keeping requirements.
• KYC Documentation: Retained for five (5) years from the date of account closure or the completion of the relevant verification process, whichever is later.
• Support Communications: Retained for three (3) years from the date of the interaction for quality assurance and dispute resolution purposes.
• Marketing Preferences and Consent Records: Retained until consent is withdrawn plus an additional two (2) years for audit trail purposes.
• Technical and Usage Logs: Typically retained for twelve (12) months for security and fraud prevention purposes, unless a longer period is required for an active investigation.

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

HibikiWin implements and maintains a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the Platform is encrypted in transit using current-generation TLS protocols.
• AES-256 Encryption at Rest: Sensitive personal and financial data stored on our servers is encrypted at rest using AES-256 symmetric encryption.
• Access Controls: Personal data is accessible only to authorised personnel who require it for their specific job function. Access is granted on a least-privilege basis and reviewed regularly.
• Penetration Testing: Our systems undergo regular independent security testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: We maintain a documented data breach response plan. In the event of a security incident involving personal data, we will take prompt remedial action and notify affected individuals and relevant authorities as required by applicable law.

Notwithstanding these measures, no internet-based system can be guaranteed to be completely secure. You are also responsible for keeping your account login credentials confidential and for using a strong, unique password for your HibikiWin account.

HibikiWin uses cookies and similar tracking technologies to deliver, maintain, and improve the Platform. A "cookie" is a small text file placed on your device when you visit the Platform. Cookies enable us to recognise your browser, maintain your session, and remember your preferences.

10.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for core Platform functionality, including maintaining your login session and processing transactions. These cannot be disabled without preventing you from using the Platform.
• Analytics Cookies: Used to collect anonymised data about how visitors interact with the Platform — page views, session duration, navigation paths — helping us identify areas for improvement. Deployed only with your consent.
• Functional Cookies: Enable personalisation features such as language preferences, display settings, and previously viewed game history. Deployed only with your consent.
• Security Cookies: Used to detect suspicious activity, prevent fraud, and protect the Platform and its users. These are strictly necessary and cannot be disabled.

10.2 Managing Your Cookie Preferences

You can manage and withdraw your consent for non-essential cookies at any time through your account settings or by adjusting your browser's cookie settings. Disabling certain non-essential cookies may affect the functionality and personalisation of your Platform experience, but will not prevent you from accessing the core services.

HibikiWin respects your rights as a data subject. You may exercise any of the following rights by contacting our Data Protection team at [email protected]. We will respond to all valid requests within a reasonable timeframe, and no later than thirty (30) days from receipt.