u2w2 Privacy Policy

This Privacy Policy (hereinafter referred to as "the Policy") describes the practices of u2w2 (hereinafter referred to as "u2w2", "we", "our", or "us") with respect to the collection, processing, storage, use, and disclosure of personal data relating to users (hereinafter referred to as "you", "Player", or "User") of the u2w2 online gaming platform accessible at https://u2w2.cam (hereinafter referred to as "the Platform").

u2w2 recognises the importance of protecting the privacy of our Players. We are committed to operating the Platform in a manner that respects your personal data and complies with the applicable data protection and privacy standards relevant to our operations. This Policy applies to all data collected through the Platform, including data submitted during account registration, gameplay, payment processing, and communications with our support team.

By accessing the Platform, registering an account, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and you consent to the data practices described herein. This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform generally.

For the purposes of this Policy, the following terms shall carry the meanings set out below:

u2w2 collects the following categories of Personal Data in connection with the operation of the Platform:

u2w2 does not collect or process special categories of Personal Data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) except where strictly required for age and identity verification purposes, and only in accordance with applicable legal requirements.

u2w2 collects Personal Data through the following channels:

• aDirect submission: Data you provide when completing the account registration form, submitting KYC documentation, making a deposit or withdrawal request, contacting our support team, or completing any other form on the Platform.
• bAutomated collection: Technical and Usage Data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies embedded in the Platform.
• cThird-party sources: Identity and financial verification data received from KYC service providers and payment processors in connection with account verification and fraud prevention obligations. u2w2 may also receive data from fraud detection and anti-money-laundering screening services.
• dPublic sources: In limited circumstances, u2w2 may collect data from publicly available sources to fulfil regulatory compliance obligations, including sanctions list screening.

u2w2 processes Personal Data strictly for the purposes set out below. We do not process your data for purposes incompatible with those originally stated without obtaining fresh consent or establishing a new legal basis.

u2w2 relies on the following legal bases for processing Personal Data, as applicable to each processing purpose:

• aContractual necessity: Processing required to perform the contract between u2w2 and the Player — including account registration, payment processing, and gameplay facilitation.
• bLegal obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC verification, anti-money-laundering screening, and mandatory reporting to relevant authorities.
• cLegitimate interests: Processing carried out in furtherance of u2w2's legitimate business interests, including fraud prevention, Platform security, product improvement, and responsible gambling monitoring — provided such interests are not overridden by the Player's fundamental rights.
• dConsent: Processing of data for marketing communications and non-essential cookies, where consent has been expressly obtained. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

u2w2 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes under any circumstances. Personal Data may be disclosed to third parties only in the following strictly limited circumstances:

• aPayment processors: To facilitate MYR deposits and withdrawals via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank, Hong Leong Connect, and cryptocurrency networks, we share necessary payment and identity data with the relevant payment processing partners.
• bKYC and identity verification providers: To fulfil identity verification obligations, we share relevant documentation and personal details with our contracted KYC service providers operating under binding data processing agreements.
• cRegulatory authorities: We may be required by law, court order, or regulatory directive to disclose Personal Data to competent authorities, including gaming regulators and financial intelligence units. Such disclosures are made only to the extent strictly required.
• dTechnology service providers: We engage third-party providers for Platform infrastructure, analytics, fraud detection, and customer support tools. These providers act as Data Processors and are contractually bound to process Personal Data only on u2w2's instructions.
• eBusiness transfers: In the event of a merger, acquisition, or sale of substantially all of u2w2's assets, Personal Data held by u2w2 may form part of the transferred assets. Affected Players will be notified prior to any such transfer where practicable.

u2w2 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or for as long as required by applicable legal, regulatory, or contractual obligations. The following standard retention periods apply:

• aAccount data and transaction records are retained for a minimum of five (5) years from the date of account closure, in compliance with applicable anti-money-laundering and gaming regulatory requirements.
• bKYC documentation is retained for the period required under applicable identity verification regulations, typically a minimum of five (5) years from the date of the last transaction.
• cCustomer support communications are retained for a minimum of two (2) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• dMarketing preference data is retained until you withdraw consent or request erasure, whichever is earlier.
• eCookie and technical data generated by non-essential cookies is retained for periods specified in our Cookie Notice, typically between 30 days and 24 months depending on the cookie category.

Upon expiry of the relevant retention period, Personal Data will be securely deleted or anonymised such that it can no longer be associated with an identifiable individual.

u2w2 implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. These measures are reviewed and updated regularly in line with evolving best practices and threat landscapes.

• aEncryption: All data transmitted between your device and the Platform is encrypted using industry-standard 256-bit SSL/TLS protocols. Data stored on u2w2 servers is encrypted at rest where technically feasible.
• bAccess controls: Access to Personal Data within u2w2 is restricted on a need-to-know basis. Staff with access to sensitive data are subject to confidentiality obligations and undergo regular privacy training.
• cTwo-factor authentication: Two-factor authentication (2FA) is available for Player accounts and is required for internal staff accessing data management systems.
• dVulnerability management: The Platform undergoes regular security assessments and penetration testing. Known vulnerabilities are remediated in accordance with a defined patching schedule.

Notwithstanding the above, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. If you have reason to believe that your account has been compromised, please contact our support team immediately.

The u2w2 Platform uses cookies and similar tracking technologies to enable core functionality, remember your preferences, and analyse Platform usage. Cookies are categorised as follows:

• aStrictly necessary cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impacting Platform functionality.
• bFunctional cookies: Used to remember your preferences such as language settings, display options, and login status. Disabling these may affect your experience on the Platform.
• cAnalytics cookies: Used to collect aggregate, anonymised data about how Players interact with the Platform. This helps us understand which features are used most frequently and identify areas for improvement.
• dMarketing cookies: Used to track your visits to the Platform and assist in delivering relevant promotional communications. These are only activated with your explicit consent.

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to refuse or delete cookies. Please note that disabling certain cookie categories may affect the functionality of the Platform.

Subject to applicable law and certain exceptions, you hold the following rights in relation to your Personal Data held by u2w2:

• aRight of Access: You may request a copy of the Personal Data u2w2 holds about you, together with information about how it is processed. We will respond to verified access requests within thirty (30) calendar days.
• bRight to Rectification: If your Personal Data is inaccurate or incomplete, you may request that it be corrected. You may also update certain account details directly through your account settings.
• cRight to Erasure: In certain circumstances, you may request deletion of your Personal Data. This right is subject to u2w2's legal obligations to retain certain records (see Section 8).
• dRight to Restrict Processing: You may request that u2w2 restrict processing of your Personal Data in defined circumstances, such as while a dispute is being resolved.
• eRight to Data Portability: Where processing is based on consent or contractual necessity, you may request that Personal Data be provided to you in a commonly used, machine-readable format.
• fRight to Object: You may object to processing carried out on the basis of legitimate interests, including direct marketing. An objection to marketing will be actioned immediately.
• gRight to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time by contacting us. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of the above rights, please contact our Data Protection team using the details in Section 15. We may ask you to verify your identity before actioning any request. Requests that are manifestly unfounded or excessive may be refused or subject to a reasonable administrative fee.

The u2w2 Platform is strictly intended for use by individuals aged twenty-one (21) years and above. u2w2 does not knowingly collect Personal Data from individuals under the age of 21. Account registration requires submission of date of birth, and all accounts are subject to mandatory KYC age verification before withdrawals are processed.

If u2w2 becomes aware that Personal Data has been collected from a person under the age of 21, such data will be deleted from our systems and the associated account will be immediately closed. Deposits made by underage individuals will be returned where possible, subject to completion of identity verification.

u2w2 operates internationally and engages service providers located in various jurisdictions. Accordingly, your Personal Data may be transferred to and processed in countries other than Malaysia. Where such transfers occur, u2w2 takes steps to ensure that appropriate safeguards are in place to protect your Personal Data to a standard equivalent to that provided under applicable data protection laws, including through the use of contractual clauses and data processing agreements with recipient entities.

By using the Platform, you acknowledge and consent to the transfer of your Personal Data to jurisdictions that may have different data protection laws than those of Malaysia, subject to the safeguards described in this Section.

u2w2 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or operational requirements. The "Last Updated" date at the top of this page will be revised to reflect the date of any material changes.

Where material changes are made to this Policy that significantly affect how we process your Personal Data, we will provide reasonable prior notice via a prominent Platform notification or by email to your registered address. For minor amendments — such as typographical corrections or additions to existing disclosures that do not substantially alter your rights — no prior notice will be provided, and the amended Policy will take effect upon publication.

Continued access to or use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Privacy Policy.