Privacy Policy gdwon – Personal Data Protection for Malaysian Members

Welcome to the gdwon Privacy Policy. We, the management team of the gdwon platform operating under the domain gdwon.app, care deeply about the privacy of every member and user who interacts with our platform.

This Privacy Policy explains in detail how gdwon collects, processes, stores, uses, and protects your personal information when you register, access, or use any of our services — whether through the gdwon.app website, the Android or iOS mobile app, or our official communication channels.

By registering an account or continuing to use the gdwon platform, you confirm that you have read and fully understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the platform and contact us for further inquiries.

This policy applies in conjunction with Terms and Conditions gdwon and should be read together with that document for a complete understanding of your rights and responsibilities as a member of our platform.

Gdwon collects various categories of personal data depending on the type of interaction you have with our platform. Below is a detailed table of the data categories collected:

Gdwon collects your personal data through several primary channels depending on how you interact with our platform:

3.1 Direct Collection from You

Data is collected directly when you:

• Completing the new account registration form on gdwon.app or our mobile app.
• Submitting identity verification documents during the KYC (Know Your Customer) process.
• Making deposits or withdrawals via supported payment methods.
• Contacting the customer support team via live chat or email.
• Updating your account profile information through the account management panel.
• Participating in promotional programmes, contests or surveys we conduct.

3.2 Automatic Collection

Some data is collected automatically when you use the gdwon platform, including technical data such as IP address, device information, and usage patterns via cookies and similar tracking technologies. This data helps us improve the user experience and detect suspicious activity.

3.3 Trusted Third Parties

In certain situations, gdwon may receive information about you from trusted third parties, such as payment service providers for transaction verification, identity verification agencies for KYC requirements, or competent authorities when required by law.

Gdwon uses your personal data solely for legitimate purposes related to platform operations. We will not use your data beyond the scope stated below:

• Account Management: Creating, verifying and maintaining your gdwon member account securely.
• KYC & AML Compliance: Meeting the identity verification and Anti-Money Laundering (AML) requirements established under Malaysian law.
• Transaction Processing: Processing deposits, withdrawals and all financial transactions accurately and securely.
• Customer Support: Providing effective technical support and customer service across all our communication channels.
• Platform Security: Detecting and preventing fraud, multi-account abuse, cyberattacks and other suspicious activities.
• Service Improvement: Analysing usage patterns to improve platform design, performance and the overall user experience.
• Important Communications: Sending account-related notifications, policy updates, security alerts and relevant promotional information (subject to your communication preferences).
• Legal Compliance: Fulfilling legal obligations, regulations and directives from competent authorities as they apply from time to time.

Gdwon does not sell or trade member personal data to any third party. However, in the course of platform operations, we may share data with the following parties within a limited and controlled scope:

5.1 Technology Service Providers

Technical infrastructure service providers — including cloud computing, cybersecurity and data analytics — that assist us in operating the gdwon platform. All such providers are bound by strict data confidentiality agreements and may only use your data for the specific services rendered to gdwon.

5.2 Payment Providers

Required financial information is shared with licensed payment providers such as FPX, Touch 'n Go, GrabPay and Boost solely to process your deposit and withdrawal transactions securely and efficiently.

5.3 Statutory Authorities

Gdwon may be required to disclose certain information to authorities such as the police, courts, or regulatory bodies when there is a valid legal requirement, as well as in cases involving financial crime, fraud, or money laundering investigations.

5.4 Business Transfers

In the event of any acquisition, merger, or asset sale involving gdwon, member personal data may be transferred to the relevant new entity. In such cases, members will be notified in advance and an equivalent privacy policy will apply.

The security of your personal data is gdwon's top priority. We implement multiple layers of technical and organisational safeguards to keep your data protected at all times:

• 256-bit SSL Encryption: All communications between your device and gdwon servers are secured with industry-grade encryption protocols.
• Encrypted Data Storage: Sensitive data such as financial information and KYC documents are stored in encrypted format on protected servers.
• Strict Access Controls: Only authorised gdwon staff who have undergone comprehensive privacy training are permitted to access members' personal data.
• 24/7 Monitoring: Security monitoring systems operate around the clock to detect and respond promptly to any threats or unusual activity.
• Two-Factor Authentication (2FA): gdwon's internal systems use multi-factor authentication to prevent unauthorized access to data storage systems.
• Regular Audits: gdwon's security systems and data handling practices undergo regular internal and external audits to ensure ongoing compliance.

Under Malaysia's Personal Data Protection Act 2010, you have the following rights regarding your personal data held by gdwon:

To submit any request relating to the rights above, please contact the gdwon privacy team by email at [email protected] or via in-app live chat. gdwon will process your request within 30 business days from the date a complete request is received.

Gdwon uses cookies and similar tracking technologies to enhance the user experience, ensure platform security, and better understand member usage patterns.

8.1 Types of Cookies Used

• Essential Cookies: Required for core platform functions such as login authentication, secure sessions, and security. These cookies cannot be disabled as they are essential to platform operation.
• Performance Cookies: Collecting anonymised information on how members use the platform to help us identify technical issues and improve performance.
• Functional Cookies: Storing your preferences such as language, region and display settings to deliver a more personalised experience.
• Analytics Cookies: Helping us understand aggregate traffic patterns and user behaviour for the continuous improvement of the gdwon platform.

8.2 Managing Cookie Preferences

You can manage or disable non-essential cookies through your web browser or mobile device settings. Please note that disabling certain cookies may affect the functionality and user experience of the gdwon platform.

The gdwon platform is a service designed exclusively for adults aged 18 Years & Above. gdwon strictly does not knowingly collect, process, or store personal data of individuals under the age of 18.

If you are a parent or guardian who becomes aware that your child has registered or provided their personal data to gdwon without your consent, please contact us immediately at [email protected]. gdwon will take prompt action to delete that information from our records.

Registering with false information to circumvent this age restriction is a serious violation of gdwon's Terms and Conditions and may result in legal action.

In operating the gdwon platform, some of your personal data may be processed or stored on servers located outside Malaysia. Such transfers are only carried out with adequate safeguards in place, including:

• Ensuring recipient countries provide a level of data protection comparable to Malaysia.
• Executing binding data protection agreements with all international data recipients.
• Using recognised data transfer mechanisms such as approved Standard Contractual Clauses.

Gdwon ensures that any cross-border data transfer is carried out in accordance with applicable legal requirements and with a level of protection equivalent to or higher than that required by Malaysia's PDPA.

Gdwon reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our data handling practices, updated legal requirements, or platform service improvements.

When significant changes occur, gdwon will:

• Updating the "Last Updated" date at the top of this page.
• Sending notifications to members via registered email or in-app notifications.
• For highly material changes, requesting your re-confirmation of consent before those changes take effect.

You are encouraged to review this Privacy Policy periodically to stay informed about how gdwon protects your information. Continued use of the platform after any changes take effect will be considered acceptance of the updated terms.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how gdwon handles your personal data, do not hesitate to reach us through the following channels:

Gdwon is committed to resolving any privacy concerns you may have promptly, transparently, and professionally. Formal complaints relating to personal data protection may also be submitted to Department of Personal Data Protection Malaysia (JPDP) if you are not satisfied with our response.