Privacy Policy — ugdewa

1 Introduction

This Privacy Policy ("Policy") describes how ugdewa ("ugdewa", "the Platform", "we", "us", "our"), operator of the website located at https://ugdewa.asia, collects, processes, stores, and protects personal data provided by or relating to its members ("you", "your", "the Member") in the course of providing online casino, sports betting, and associated services.

ugdewa is committed to maintaining the highest standards of data protection and privacy. We process personal data only where we have a lawful basis to do so, and only to the extent necessary for the purposes described in this Policy. We do not sell, rent, or otherwise commercialise your personal data to third-party marketing organisations.

This Policy applies to all users of the ugdewa platform, including members from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and all other locations from which the platform is accessed. If you do not agree with the terms of this Policy, you should not create or continue to use an ugdewa account.

2 Definitions

For the purposes of this Privacy Policy, the following terms shall carry the meanings assigned below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, residential address, date of birth, payment details, and device identifiers.
• "Processing" means any operation performed on personal data, whether or not by automated means, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means ugdewa, which determines the purposes and means of processing personal data collected through the platform.
• "Data Processor" means any third party that processes personal data on behalf of ugdewa, acting under our written instructions and subject to appropriate contractual safeguards.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement by which the data subject signifies acceptance of the processing of their personal data for a stated purpose.
• "KYC Data" means identity verification documentation and supporting information collected as part of the Know Your Customer process, including government-issued identification and proof of address.
• "Cookies" means small data files stored on your device by your web browser when you visit the ugdewa platform, used to remember preferences and support analytics.

3 Data We Collect

ugdewa collects personal data in several categories, each serving a specific and necessary purpose. The table below summarises the categories of personal data we may collect from members:

4 How We Collect Data

ugdewa collects personal data through the following means:

Data you provide directly when you register an account, complete the KYC verification process, make a deposit or withdrawal request, contact our support team, or participate in promotions. This includes all information entered into account registration forms, identity verification submissions, and payment instructions.

Data collected automatically when you access and interact with the ugdewa platform. This includes technical and usage data gathered via cookies, web beacons, log files, and similar tracking technologies embedded in the platform. For full details, refer to Section 10 (Cookies & Tracking).

In limited circumstances, ugdewa may receive personal data about you from third-party sources, including:

• Identity verification and fraud screening service providers used during KYC;
• Payment processors and financial institutions in connection with deposit and withdrawal transactions (e.g., Maybank, CIMB, Public Bank, Hong Leong);
• E-wallet providers (Touch 'n Go eWallet, Boost, GrabPay) in connection with payment processing;
• DuitNow and FPX networks in connection with bank transfer transactions.

Data received from third parties is processed in accordance with this Policy and, where applicable, is subject to additional verification to ensure accuracy.

5 Data Processing & Use

ugdewa processes your personal data exclusively for the following purposes:

To create, maintain, and administer your ugdewa account, including verifying your identity, managing your Account balance, processing transactions, and providing access to platform features appropriate to your membership tier.

To process deposits and withdrawals via your chosen payment methods, including DuitNow, Touch 'n Go eWallet, Boost, GrabPay, FPX bank transfer, Maybank2u, CIMB Clicks, Public Bank online banking, Hong Leong Connect, and cryptocurrency channels where applicable.

To fulfil our obligations under applicable anti-money laundering (AML) and counter-terrorist financing (CTF) regulations, including maintaining transaction records, conducting risk assessments, and submitting mandatory reports to relevant regulatory authorities where required.

To detect, investigate, and prevent fraudulent activity, unauthorised account access, bonus abuse, and other security threats. This includes automated monitoring of unusual transaction patterns, login anomalies, and device fingerprinting.

To monitor gaming activity for indicators of problem gambling, enforce self-imposed limits set by members, and facilitate self-exclusion requests in accordance with ourResponsible Gambling Policy.

To respond to support enquiries, resolve disputes, and improve the quality of our customer service. Support communications may be retained for quality assurance purposes.

Where you have provided explicit consent, to send promotional offers, bonus notifications, and platform updates relevant to your interests. You may withdraw marketing consent at any time by contacting our support team or updating your Account preferences.

To analyse aggregated and anonymised usage data for the purpose of improving platform functionality, game selection, user experience, and payment method availability.

6 Legal Basis for Processing

ugdewa processes personal data on the following legal bases, as applicable:

• Contractual Necessity: Processing required to perform our obligations under the agreement between ugdewa and the Member, including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML/CTF obligations, KYC requirements, and regulatory reporting duties.
• Legitimate Interests: Processing for the purposes of fraud prevention, platform security, and general business operations, where such interests do not override your fundamental privacy rights.
• Consent: Processing for marketing communications and certain non-essential cookie categories, where your explicit consent has been obtained. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

ugdewa does not sell, rent, or trade your personal data to third parties. We may share your data with the following categories of recipients, solely for the purposes described in this Policy:

Carefully selected third-party service providers engaged to perform specific functions on our behalf, including payment processing partners, identity verification service providers, cybersecurity firms, cloud hosting providers, and customer support software operators. All such providers are contractually obligated to process your data only on our instructions and to maintain appropriate security standards.

Where ugdewa is legally compelled to disclose personal data by a court order, regulatory directive, or lawful request from a law enforcement authority, we will comply with such obligations. We will, where legally permitted, notify you of any such disclosure.

In the event of a merger, acquisition, or sale of all or part of ugdewa's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and your rights under this Policy will be preserved.

8 Data Retention

ugdewa retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account Data: Retained for the duration of your Account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with financial regulatory obligations.
• KYC Documentation: Retained for the duration of your Account and for a period of at least five (5) years following account closure.
• Support Communications: Retained for a period of three (3) years from the date of the interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing Preferences: Retained until you withdraw consent or for a period of two (2) years from the last recorded marketing interaction, whichever is earlier.

Once the applicable retention period has expired, personal data is securely deleted or anonymised such that it can no longer be attributed to an identifiable individual.

9 Data Security

ugdewa implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. Our security framework includes, but is not limited to:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and ugdewa servers is encrypted using industry-standard TLS protocols.
• Encrypted Data Storage: Personal data and financial records held on our servers are stored in encrypted form. Sensitive fields such as payment credentials are subject to additional encryption layers.
• Access Controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis. All staff with access to member data are subject to confidentiality obligations and regular security training.
• Two-Factor Authentication: Available to all members for account login to provide an additional layer of security beyond passwords.
• Continuous Monitoring: Our security team operates continuous monitoring of platform activity to detect and respond to anomalies, intrusion attempts, and suspicious transaction patterns in real time.
• Vulnerability Management: Regular security assessments, penetration testing, and vulnerability scans are conducted to identify and remediate potential weaknesses in the platform's infrastructure.

Despite these measures, no data transmission or storage system can guarantee absolute security. In the event of a data breach that poses a material risk to your rights, ugdewa will notify affected members and relevant authorities in accordance with applicable data protection law.

10 Cookies & Tracking Technologies

The ugdewa platform uses cookies and similar tracking technologies to provide a functional, secure, and personalised user experience. The categories of cookies we use are as follows:

These cookies are essential for the operation of the platform and cannot be disabled. They are used to maintain your login session, remember your Account preferences, and ensure the security of your Account. No consent is required for these cookies.

These cookies enable enhanced functionality on the platform, such as remembering your preferred language, game filters, and display settings. Disabling these cookies may affect the quality of your experience but will not prevent access to core platform features.

With your consent, we use analytical cookies to collect aggregated data about how members interact with the platform. This data — which cannot identify individual users — helps us understand which features are most used, identify navigation issues, and prioritise platform improvements.

You may manage your cookie preferences at any time through your browser settings. Most modern browsers allow you to block or delete cookies; however, please note that disabling strictly necessary cookies will impair your ability to log in and use the platform. For instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

11 Your Rights

Subject to applicable data protection law, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact ugdewa's support team using the details in Section 15.

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data held about you.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may request that we delete your personal data. This right is subject to limitations where processing is required for legal or regulatory compliance purposes.
• Right to Restriction of Processing: You may request that we restrict the processing of your personal data in certain circumstances, for example while the accuracy of the data is being verified.
• Right to Data Portability: Where processing is based on your consent or on a contractual basis, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on our legitimate interests, including processing for direct marketing purposes. Where you object to marketing, we will cease processing your data for that purpose immediately.
• 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 the withdrawal.

12 Protection of Minors

We implement active age verification procedures during account registration and KYC as part of our commitment to protecting minors. If you are a parent or guardian and believe that a minor has created an account on ugdewa, please contact our support team immediately.

13 Cross-Border Data Transfers

The ugdewa platform is operated using cloud infrastructure and service providers that may be located in jurisdictions outside Malaysia. In such cases, your personal data may be transferred to and processed in countries outside your country of residence. Where such transfers occur, ugdewa ensures that appropriate safeguards are in place, including:

• Contractual clauses that impose equivalent data protection obligations on the recipient;
• Use of service providers located in jurisdictions with adequate data protection frameworks;
• Technical and organisational measures ensuring the security of data in transit and at rest.

For further information about the safeguards applied to any specific cross-border transfer, please contact our support team.

14 Policy Amendments

ugdewa reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. Members will be notified of material changes via a notice on the platform homepage or by email to their registered address. The "Last Updated" date at the top of this page will reflect the date of the most recent revision.

Continued use of the ugdewa platform following notification of any amendment to this Policy constitutes your acceptance of the revised terms. If you do not agree with any amendment, you should cease using the platform and contact our support team to request account closure.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ugdewa, please contact our Data Protection team through the following channels:

• Email: [email protected] — Subject line: "Privacy Enquiry" or "Data Rights Request" (plain text — not a clickable link)
• Live Chat: Available 24/7 via the platform interface. Average response time under 90 seconds for data-related queries.

We are committed to resolving all privacy-related enquiries promptly and transparently. We will acknowledge receipt of your query within 2 business days and provide a substantive response within 30 calendar days, subject to complexity.