Privacy Policy — twc18

1. About This Privacy Policy

1.1 This Privacy Policy ("Policy") describes how twc18 ("twc18", "we", "our", "us") collects, processes, stores, and protects the personal data of individuals ("Members", "Users", "you") who register for and use the twc18 online betting and casino platform accessible at twc18.net.

1.2 twc18 acts as the data controller in respect of personal data collected through the twc18 platform. As data controller, twc18 determines the purposes and means of processing your personal data in accordance with applicable data protection laws.

1.3 By creating a twc18 account, using any twc18 product or service, or interacting with the twc18 website, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

1.4 This Policy should be read alongside the twc18 Terms & Conditions and Responsible Gaming Policy.

2. Personal Data We Collect

2.1 twc18 collects personal data that is necessary to provide our services, comply with legal obligations, and maintain the integrity of our platform. The categories of personal data we collect include:

2.1.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (for mandatory age verification — all Members must be 21 or older);
• Malaysian MyKad number or passport number;
• Email address and mobile phone number;
• Residential address in Malaysia.

2.1.2 KYC Verification Documents

• Scanned copy or photograph of your Malaysian MyKad, passport, or other government-issued photo ID;
• Proof of address document (utility bill, bank statement, or similar issued within 90 days);
• Source of funds documentation where required by our anti-money laundering procedures.

2.1.3 Financial Data

• Payment method details (Touch n Go eWallet account reference, Boost account reference, bank account details for withdrawal processing);
• Deposit and withdrawal transaction records;
• Betting history, game play records, and account balance information.

2.1.4 Technical & Usage Data

• IP address, device identifiers, and browser type;
• Operating system and device model;
• Pages visited, time spent on pages, and navigation paths within the twc18 platform;
• Login timestamps and session duration data;
• Geolocation data (city-level) derived from IP address.

2.1.5 Communications Data

• Records of live chat, email, and support ticket interactions with the twc18 customer support team;
• Promotional communication preferences.

3. How We Use Your Personal Data

3.1 twc18 uses your personal data for the following purposes:

• Account management: Creating, maintaining, and administering your twc18 member account;
• Age and identity verification: Complying with our mandatory 21+ age verification requirement and KYC obligations;
• Service delivery: Processing your bets, game play, deposits, and withdrawals in MYR;
• Fraud prevention: Detecting, investigating, and preventing fraudulent activity, money laundering, and platform abuse;
• Responsible gaming: Monitoring betting patterns to identify potential problem gambling behaviour and applying self-exclusion or intervention measures where appropriate;
• Legal compliance: Meeting obligations under applicable international gaming authority licensing requirements and anti-money laundering regulations;
• Customer support: Responding to your enquiries and resolving disputes;
• Platform improvement: Analysing usage data to improve the twc18 platform, products, and user experience;
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications.

3.2 twc18 will not use your personal data for any purpose that is incompatible with those stated above without first notifying you and, where required, obtaining your consent.

4. Legal Basis for Processing

4.1 twc18 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform our contract with you (the twc18 Terms & Conditions), including account operation, bet processing, and payment handling;
• Legal obligation: Processing required to comply with applicable laws and regulatory requirements, including KYC, age verification, and anti-money laundering obligations;
• Legitimate interests: Processing for fraud prevention, platform security, and improving our services, where these interests are not overridden by your privacy rights;
• Consent: Processing for direct marketing communications, where you have provided explicit consent that can be withdrawn at any time.

5. Data Sharing & Disclosure

5.1 twc18 does not sell, rent, or trade your personal data to third-party marketing organisations. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment service providers: Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank, and FPX payment processors — for the purpose of processing your deposits and withdrawals;
• Identity verification providers: Third-party KYC and age verification service providers who assist in verifying your identity documents;
• Game content providers: Game studios whose products are offered on the twc18 platform may receive anonymised or aggregated game play data for audit and integrity purposes;
• Regulatory authorities: Where required by law or regulatory obligation, twc18 may disclose personal data to international gaming authority regulators, anti-money laundering authorities, or law enforcement agencies;
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and IT infrastructure vendors who process data solely on twc18's behalf under binding data processing agreements;
• Professional advisers: Legal counsel, auditors, and compliance consultants under obligations of confidentiality.

5.2 Any third party with whom twc18 shares personal data is required to maintain appropriate technical and organisational security measures and to process data only in accordance with twc18's instructions.

6. Cookies & Tracking Technologies

6.1 twc18 uses cookies and similar tracking technologies to operate the platform, remember your session, and analyse usage patterns. The types of cookies we use include:

• Strictly necessary cookies: Required for the twc18 platform to function. These cannot be disabled as they are essential for login sessions, account security, and payment processing;
• Functional cookies: Remember your preferences such as language settings, game lobby display preferences, and odds format;
• Analytics cookies: Collect anonymised data about how Members use the twc18 platform, which pages are visited most, and where users encounter difficulties — used to improve the platform experience;
• Session security cookies: Used to detect and prevent fraudulent login attempts and session hijacking.

6.2 You can control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the twc18 platform.

7. Data Retention

7.1 twc18 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations.

7.2 Specifically:

• Account data and transaction records are retained for a minimum of five (5) years following account closure, as required by applicable anti-money laundering regulations;
• KYC and identity verification documents are retained for a minimum of five (5) years following the completion of the relevant verification process;
• Communication records (chat logs, email correspondence) are retained for three (3) years;
• Technical and usage data (logs, IP addresses) are retained for twelve (12) months.

7.3 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data.

8. Data Security

8.1 twc18 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and twc18 servers;
• AES-256 encryption for sensitive data at rest in our databases;
• Role-based access controls ensuring that only authorised twc18 personnel can access personal data, on a need-to-know basis;
• Regular penetration testing and vulnerability assessments of the twc18 platform infrastructure;
• Multi-factor authentication requirements for all twc18 administrative system access;
• Continuous security monitoring and intrusion detection systems.

8.2 In the event of a personal data breach that poses a risk to your rights and freedoms, twc18 will notify affected Members and relevant regulatory authorities within the timeframes required by applicable law.

8.3 You are responsible for maintaining the security of your own twc18 account credentials. twc18 will never ask you to provide your password via email, live chat, or telephone. If you receive any such request, please report it to [email protected] immediately.

9. Your Data Rights

9.1 Subject to applicable law, you have the following rights in respect of your personal data held by twc18:

• Right of access: You may request a copy of the personal data twc18 holds about you;
• Right to rectification: You may request correction of any inaccurate or incomplete personal data;
• Right to erasure: You may request deletion of your personal data where there is no legitimate reason for twc18 to continue processing it, subject to our legal retention obligations;
• Right to restriction: You may request that twc18 restrict the processing of your personal data in certain circumstances;
• Right to data portability: You may request a copy of your personal data in a structured, machine-readable format;
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time;
• Right to withdraw consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

9.2 To exercise any of these rights, please contact the twc18 Data Protection team via live chat in your account dashboard or by emailing [email protected]. We will respond to all valid requests within thirty (30) calendar days.

9.3 twc18 will not charge a fee for handling data rights requests, except in cases of manifestly unfounded or excessive requests.

10. Children's Privacy

10.1 The twc18 platform is strictly for adults aged 21 years and older. twc18 does not knowingly collect personal data from individuals under the age of 21.

10.2 If twc18 becomes aware that personal data has been collected from a person under 21 years of age, that account will be immediately suspended, the personal data will be deleted, and any deposits will be returned subject to verification procedures.

10.3 If you believe that a minor may have registered a twc18 account, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

11. International Data Transfers

11.1 twc18 operates internationally and may transfer your personal data to servers or service providers located outside Malaysia. Where such transfers occur, twc18 ensures that appropriate safeguards are in place to protect your data, including:

• Standard contractual clauses approved by relevant data protection authorities;
• Transfer to countries recognised as providing an adequate level of data protection;
• Binding corporate rules where applicable.

11.2 By using the twc18 platform, you consent to the transfer of your personal data to countries outside Malaysia as described in this section, where such transfers are necessary for the provision of twc18 services.

12. Changes to This Privacy Policy

12.1 twc18 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or platform operations.

12.2 Where changes are material, twc18 will notify Members by email to their registered address and/or by prominent notice on the twc18 platform at least seven (7) days prior to the effective date of the updated Policy.

12.3 The "Last updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the twc18 platform after the effective date constitutes your acceptance of the updated Policy.

13. Contact & Data Protection Enquiries

13.1 If you have any questions, concerns, or complaints about this Privacy Policy or the way twc18 handles your personal data, please contact our Data Protection team:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via your twc18 account dashboard after login
• Response Time: Typically within 1 hour during business hours (9AM–11PM MYT); data rights requests within 30 calendar days

13.2 twc18 takes all privacy complaints seriously. We will investigate your complaint and provide a written response. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.