Privacy Policy

This Privacy Policy ("Policy") is issued by Zuswin ("the Company", "we", "us", or "our") and applies to all personal data collected from individuals ("you", "your", or "Player") who access, register on, or interact with the Zuswin online gaming platform at zuswin.cam, including any associated mobile applications and customer support channels.

Zuswin is committed to processing personal data responsibly, transparently, and in compliance with applicable data protection principles. We recognise that our players — whether they are logging in from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, or Shah Alam — deserve clear, honest information about how their data is handled.

This Policy explains what categories of personal data we collect, the purposes for which we process that data, the legal bases we rely upon, how long we retain data, and the rights you hold in relation to your personal information. It should be read alongside our Terms & Conditions, which govern the overall relationship between you and Zuswin.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information that relates to an identified or identifiable natural person, directly or in combination with other data held by the Company.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" means Zuswin as the entity that determines the purposes and means of processing your personal data.
• "Data Processor" means a third party that processes personal data on behalf of Zuswin, under a written data processing agreement.
• "Sensitive Data" means personal data that requires enhanced protection, including government-issued identity documents, financial account details, and health information relevant to responsible gambling interventions.
• "Consent" means freely given, specific, informed, and unambiguous agreement to the processing of personal data for a stated purpose, which may be withdrawn at any time.
• "Cookie" means a small text file placed on your device by the Zuswin platform for functional, security, or analytical purposes.
• "Platform" refers to the Zuswin website at zuswin.cam, its mobile interface, and all associated digital services.

Zuswin collects the following categories of personal data in the course of operating the Platform and fulfilling our legal obligations:

We do not collect payment card data directly. Card-based transactions, where available, are processed exclusively by PCI-DSS compliant third-party payment gateways that do not transmit full card details to Zuswin's systems.

Zuswin collects personal data through the following channels and mechanisms:

• Direct Submission: Data you provide when registering an Account, completing KYC verification, submitting a withdrawal request, contacting support, or participating in a promotion.
• Automated Technical Collection: Data gathered automatically when you access the Platform, including IP addresses, device identifiers, browser fingerprints, and session activity logs, via server logs and first-party cookies.
• Payment Processor Notifications: Confirmation data passed to Zuswin by third-party payment processors (such as FPX network participants including Maybank, CIMB, Public Bank, and Hong Leong Bank, and e-wallet operators) upon successful transaction processing. Full account credentials are never transmitted to Zuswin.
• KYC & Identity Verification Providers: Where automated document verification tools are used to expedite the KYC process, those providers may return structured identity data to Zuswin for Account records.
• Responsible Gambling Monitoring: Behavioural data generated by the Platform's internal responsible gambling systems, which monitor session duration, betting patterns, and loss velocity against player-set thresholds.

Zuswin processes your personal data for the following clearly defined purposes. We do not use personal data for any purpose that is incompatible with those stated below:

• Account Registration & Management: To create, maintain, and administer your Zuswin Account, including authentication, balance management, and communication of account-related notices.
• Identity & Age Verification (KYC): To confirm that you meet the 21+ age requirement, verify your identity as required by our licensing obligations, and satisfy anti-money laundering obligations.
• Payment Processing: To facilitate MYR deposits and withdrawals through your chosen payment method (including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank2u, CIMB Clicks, and USDT), and to maintain accurate financial records.
• Platform Security & Fraud Prevention: To detect, investigate, and prevent unauthorised account access, bonus abuse, multi-accounting, money laundering, and other prohibited conduct outlined in our Terms & Conditions.
• Customer Support: To respond to enquiries, resolve disputes, and maintain records of support interactions for quality assurance and complaint handling purposes.
• Regulatory Compliance: To meet our obligations under applicable gaming licence conditions, anti-money laundering regulations, and applicable data protection requirements, including mandatory record retention periods.
• Responsible Gambling: To monitor player behaviour against responsible gambling risk indicators, administer self-exclusion requests, apply deposit limits, and proactively contact players displaying signs of problem gambling.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the Platform's functionality, performance, and user experience.
• Marketing Communications: To send you promotional offers, bonus notifications, and personalised recommendations — only where you have given explicit consent and have not subsequently withdrawn it.

Each processing activity carried out by Zuswin is grounded in one or more of the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you — including Account management, payment processing, and access to games — is carried out on the basis that it is necessary to provide the services you have agreed to.
• Legal Obligation: Processing undertaken to comply with binding legal requirements, including KYC / AML verification, record retention mandated by our licence, and responses to lawful authority requests.
• Legitimate Interests: Processing where we have a legitimate business interest that is not overridden by your privacy rights, including fraud prevention, platform security monitoring, responsible gambling oversight, and internal analytics using anonymised data.
• Consent: Processing for marketing communications and the use of non-essential cookies, which is carried out only with your explicit, withdrawable consent. Where consent is the legal basis, you may withdraw it at any time without affecting the lawfulness of prior processing.

Zuswin does not sell, rent, or trade your personal data. We share personal data only in the following circumstances:

• Licensed Payment Processors: We share the minimum data necessary with payment providers (including FPX network banks, Touch 'n Go eWallet, Boost, GrabPay, and DuitNow operators) to process your transactions. These providers are contractually bound to use your data solely for payment facilitation and to maintain appropriate security standards.
• KYC & Identity Verification Partners: Where identity document verification is performed by a third-party automated tool, relevant identity data is transmitted to that provider under a written data processing agreement, subject to strict confidentiality obligations.
• Regulatory & Law Enforcement Authorities: We are required by our licensing obligations and applicable law to disclose certain data to gaming regulators, financial intelligence units, and law enforcement agencies upon receipt of a lawful request. We cannot notify you of such disclosures where doing so would compromise an investigation.
• Professional Advisers: Lawyers, auditors, and compliance consultants engaged by Zuswin may access personal data on a strictly need-to-know basis and are bound by professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or restructuring of Zuswin's business, personal data may be disclosed to prospective acquirers under confidentiality undertakings. You will be notified of any material change in data controller before the transfer completes.

All third parties with whom Zuswin shares personal data are required to maintain at minimum the same standard of data protection as Zuswin applies internally. We do not knowingly permit third-party processors to use your data for their own independent purposes.

Zuswin retains personal data for no longer than is necessary for the purposes for which it was collected, subject to the following standard retention periods:

• Active Account Data: Retained for the full duration of your Account's existence on the Platform.
• KYC & Identity Documents: Retained for a minimum of five years following Account closure, as required by anti-money laundering regulations applicable under our gaming licence.
• Transaction Records: Retained for a minimum of seven years following each transaction date, consistent with standard financial record-keeping obligations.
• Customer Support & Complaints Records: Retained for three years from the date of final resolution of the relevant matter.
• Responsible Gambling Records: Self-exclusion records and deposit limit histories are retained for a minimum of five years to enable our compliance and responsible gambling teams to act in the player's best interest if a re-registration attempt is made.
• Marketing Consent Records: Retained for three years from the date of consent or from the date of the most recent marketing interaction, whichever is later.
• Technical & Log Data: Typically retained for 12 months from the date of collection, subject to extension where required for an active investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that renders it impossible to re-identify the individual. Anonymised or aggregated data may be retained indefinitely for statistical analysis purposes.

Zuswin implements a layered security framework to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• Encryption in Transit: All data transmitted between your device and the Zuswin Platform is protected using TLS 1.3 (Transport Layer Security). Outdated protocol versions (TLS 1.0, TLS 1.1, and SSL) are disabled.
• Encryption at Rest: Personal data and identity documents stored on Zuswin's servers are encrypted using AES-256 encryption. Decryption keys are stored separately from encrypted data with strict access controls.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis. All access is role-based and subject to multi-factor authentication. Access events are logged and periodically reviewed.
• Payment Data Tokenisation: Financial account identifiers (bank account numbers, e-wallet IDs) are tokenised — stored as irreversible cryptographic tokens rather than in their original form.
• Penetration Testing: The Platform undergoes regular third-party penetration testing and vulnerability assessments. Critical findings are remediated on a priority basis.
• Data Breach Response: Zuswin maintains a documented data breach response procedure. In the event of a breach affecting your rights or freedoms, we will notify you without undue delay in accordance with applicable obligations.

Zuswin uses cookies and similar first-party tracking technologies to operate and improve the Platform. We do not use third-party advertising cookies or cross-site tracking tools.

The cookies we use fall into the following categories:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, CSRF protection tokens, and security identifiers. These cookies cannot be disabled without rendering the Platform unusable. No consent is required for strictly necessary cookies.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and responsible gambling configuration states. These are set only with your consent.
• Performance & Analytics Cookies: First-party analytics cookies that help us understand how players navigate the Platform — which pages are visited most, where sessions end, and how features perform. Data collected is aggregated and anonymised. These require your consent.

You may review and adjust your cookie preferences at any time through the Cookie Settings panel accessible from the footer of the Platform. Withdrawing consent from non-essential cookies will not affect your ability to use core Platform features.

Zuswin does not use browser fingerprinting for tracking beyond security purposes (specifically, to detect account takeover attempts through unusual device changes).

Subject to applicable data protection law and certain exemptions (including those necessary for our legal compliance and anti-money laundering obligations), you hold the following rights in relation to your personal data:

To exercise any of the above rights, please submit a written request to the Zuswin Compliance team using the contact details in Section 15. We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days. Where a request is complex or numerous, this period may be extended by a further 60 days with prior notification.

We may ask you to verify your identity before processing any data subject request to protect against fraudulent or unauthorised requests.

Zuswin is strictly an adult platform. We do not knowingly collect, process, or retain personal data from any individual under the age of 21. Our platform is not directed at persons under 21 years of age, and we actively enforce the 21+ age restriction through KYC identity and age verification at the account registration stage.

If we become aware — through our KYC process, parental report, or any other means — that an Account has been registered by or used by a person under the age of 21, we will immediately suspend the Account, initiate a review, return any deposited funds to the originating payment method as appropriate, and permanently close the Account. Any data collected in relation to that Account will be retained only to the minimum extent required by our legal obligations before being securely deleted.

If you believe a minor has accessed the Zuswin Platform using your Account credentials or by creating their own Account, please contact our support team immediately at [email protected] (plain text — not a link) so that we can act promptly.

Zuswin's primary data infrastructure is hosted in secure data centres. In certain circumstances, personal data may be processed by our licensing authority, compliance infrastructure, or certain service providers located outside Malaysia. Where such transfers occur, Zuswin ensures that appropriate safeguards are in place to maintain an equivalent level of data protection to that applied within our own systems.

Safeguards may include:

• Written data processing agreements incorporating standard data protection clauses.
• Transfers only to jurisdictions that maintain an adequate data protection framework.
• Technical controls (such as encryption) that protect data during and after transfer regardless of the legal framework of the receiving jurisdiction.

You may request details of the specific safeguards applicable to any international transfer of your personal data by contacting our Compliance team as described in Section 15.

Zuswin may update this Privacy Policy from time to time to reflect changes in our data processing practices, platform features, legal obligations, or regulatory guidance. The "Last Updated" date at the top of this document will be revised whenever a material change is made.

Where a proposed change is material — meaning it substantially alters your rights or the way we handle your data — we will notify you by email to the address registered to your Account and by displaying a prominent notice on the Platform at least 14 days before the revised Policy takes effect.

Minor updates that do not materially affect your rights (such as formatting improvements, typographical corrections, or clarifications of existing practices without substantive change) may take effect immediately upon publication.

Your continued use of the Platform following the effective date of a revised Policy constitutes your acknowledgement of the updated terms. If you do not accept a material update, you may close your Account before the effective date by contacting our support team.

We encourage you to review this Policy periodically. The current version is always accessible at zuswin.cam/privacy-policy.

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or wish to raise a data-related complaint, please contact the Zuswin Compliance and Data Protection team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, through your Account dashboard. Best for general queries and urgent account matters.
• Email: [email protected] (plain text — copy and paste into your email client; do not click). For formal data subject requests, please use the subject line: "Data Subject Request — [Your Account Username]".

Upon receipt of a formal data subject request, our Compliance team will:

1. Acknowledge receipt within 5 business days and issue a reference number.
2. Verify your identity to protect against fraudulent requests.
3. Provide a substantive written response within 30 calendar days, with an extension of up to 60 additional days for complex cases, with prior notice.

If you are not satisfied with the outcome of a data-related complaint handled by Zuswin's internal Compliance team, you may escalate the matter to the relevant data protection authority in accordance with the procedures of your applicable jurisdiction.