1. Introduction
This Privacy Policy ("Policy") describes how surewim ("the Company", "we", "us", or "our"), operating the online gaming and sports betting platform accessible at https://surewim.cam, collects, processes, stores, and shares personal data relating to individuals ("Players", "you", or "your") who access or use our Platform.
surewim is committed to handling all personal data in a manner that is transparent, lawful, and consistent with the reasonable expectations of our Players. This Policy is incorporated by reference into ourTerms & Conditions and should be read alongside those Terms.
By registering an Account on the surewim Platform or by continuing to use the Platform after this Policy has been updated, you acknowledge that you have read and understood this Policy and that you consent to the processing of your personal data as described herein, to the extent that consent is required as a legal basis for any such processing.
Malaysian Players: surewim processes the personal data of Malaysian players including but not limited to data collected in connection with DuitNow, FPX, and local bank transfers via Maybank, CIMB, Public Bank, and Hong Leong. All such data processing is carried out in accordance with the standards described in this Policy and applicable international data protection principles.
2. Definitions
The following definitions apply throughout this Privacy Policy:
Any information that directly or indirectly identifies a living individual, including but not limited to: full name, Malaysian Identity Card (MyKad) number, passport number, date of birth, residential address, email address, mobile number, IP address, device identifiers, and financial account details.
Any operation performed on Personal Data, including collection, storage, organisation, structuring, alteration, retrieval, disclosure, transmission, restriction, erasure, or destruction.
surewim, as the entity that determines the purposes and means by which Personal Data is processed. surewim acts as Data Controller for all Personal Data collected through the Platform.
A third party that processes Personal Data on behalf of surewim in accordance with the Company's instructions, including payment gateway operators, KYC verification service providers, and cloud infrastructure providers.
A freely given, specific, informed, and unambiguous indication of a Player's agreement to the processing of their Personal Data for a specified purpose, provided by a clear affirmative act such as ticking a consent box or completing account registration.
Identity verification documentation provided by a Player as part of the Know Your Customer process, including copies of government-issued identification documents, proof of address, and payment method verification materials.
3. Data We Collect
surewim collects Personal Data through several channels, including directly from Players at registration and during ongoing use of the Platform, and automatically through technical means when you interact with the Platform. The categories of data we collect are described in the table below:
| Data Category | Specific Data Points | Collection Method |
|---|---|---|
| Identity Data | Full name, date of birth, nationality, MyKad or passport number, photograph | Registration form; KYC document upload |
| Contact Data | Email address, mobile phone number, residential address | Registration form; account profile updates |
| Financial Data | Bank account name and number, e-wallet account identifiers (Touch 'n Go, Boost, GrabPay), DuitNow ID, FPX transaction references, deposit and withdrawal history | Payment processing; transaction records |
| Gaming Activity Data | Game sessions, wager amounts, win/loss records, bonus usage, betting history | Platform interaction; automatic logging |
| Technical Data | IP address, device type, browser type and version, operating system, screen resolution, session duration, referal URL | Automatic collection via server logs and cookies |
| Communications Data | Live chat transcripts, support ticket contents, email correspondence, feedback submissions | Customer support interactions |
| Preference Data | Preferred language (Bahasa Melayu, English, Mandarin), preferred game categories, marketing communication preferences, responsible gambling settings | Account settings; Platform interactions |
surewim does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where such data is contained within identity documents submitted for KYC purposes, in which case such data is handled with additional care and accessed only by authorised compliance personnel.
4. How We Use Your Data
surewim processes your Personal Data for the following purposes:
To register your Account, verify your identity, maintain your account profile, authenticate your login sessions, and facilitate account recovery where required.
To facilitate deposits and withdrawals via DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank, and cryptocurrency channels (BTC, USDT). Transaction data is shared with the relevant payment service providers only to the extent necessary to execute the transaction.
To verify that you meet the minimum age requirement of 21 years, to confirm your identity as required by anti-money-laundering ("AML") obligations, and to satisfy any reporting requirements imposed by our licensing authority or competent regulatory bodies.
To detect, prevent, and investigate fraudulent activity, money laundering, account takeover attempts, bot usage, and other prohibited conduct as defined in our Terms & Conditions. Technical data including IP addresses and device fingerprints is processed for this purpose.
To respond to your enquiries, complaints, and account-related requests submitted via live chat, email, or any other support channel. Support communications are logged for quality assurance and training purposes.
To identify patterns of gaming behaviour that may indicate problem gambling, to facilitate the use of self-imposed tools (deposit limits, cooling-off periods, self-exclusion), and to honour any self-exclusion request made by a Player or by a designated third party on a Player's behalf.
Where you have given explicit consent, to send you promotional communications regarding new games, bonus offers,Hari Raya promotions, and other relevant updates. You may withdraw your marketing consent at any time by updating your account communication preferences or contacting our support team.
To analyse aggregated and anonymised usage data for the purpose of improving Platform functionality, game selection, payment options, and user experience. Individual Player data used for this purpose is anonymised before analysis wherever practicable.
5. Legal Basis for Processing
surewim processes your Personal Data one or more of the following legal bases, as applicable to each processing activity:
- Contractual Necessity: Processing required to enter into and perform our contract with you, including account creation, payment processing, game provision, and withdrawal processing.
- Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money-laundering obligations, age verification requirements, and reporting obligations to our licensing authority.
- Legitimate Interests: Processing carried out in furtherance of surewim's legitimate business interests, including fraud prevention, platform security, and analytics — provided such interests are not overridden by your fundamental privacy rights.
- Consent: Processing carried out on the basis of your freely given and explicit consent, primarily in connection with direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing that occurred before withdrawal.
6. Data Sharing & Disclosure
surewim does not sell, rent, or trade your Personal Data to third parties. We may share your Personal Data with the following categories of recipients, strictly as necessary for the purposes described in this Policy:
Operators of DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong Bank, and cryptocurrency networks, for the purpose of processing deposits and withdrawals to from your Account.
Third-party KYC service providers engaged to assist with identity verification and document authentication. These providers operate under strict data processing agreements with surewim and are prohibited from using your KYC data for any purpose other than verification.
Cloud hosting, data storage, and platform technology providers who process data on surewim's behalf under data processing agreements. Access to Personal Data by these providers is limited to what is strictly necessary for the provision of their services.
Competent regulatory bodies, law enforcement authorities, and financial intelligence units, where surewim is legally obligated to disclose Personal Data in connection with AML investigations, fraud inquiries, court orders, or similar legal processes. surewim will notify affected Players of such disclosure where it is legally permitted to do so.
Legal, accounting, and auditing advisors who are bound by professional confidentiality obligations, where access to Personal Data is necessary for the provision of their professional services to surewim.
All third parties with whom surewim shares Personal Data are required to maintain appropriate technical and organisational security measures and to process such data only in accordance with surewim's instructions and this Policy.
7. Payment Data
surewim processes payment data in connection with all deposit and withdrawal transactions conducted through the Platform. The following practices apply specifically to financial and payment-related data:
- surewim does not store full bank account numbers or full credit card numbers on its own systems. Payment processing is handled by designated payment service providers operating under applicable payment security standards.
- Transaction metadata — including transaction reference numbers, amounts, timestamps, and payment method identifiers — is retained by surewim for a period of not less than five (5) years from the date of the transaction, as required by applicable AML and regulatory record-keeping obligations.
- For DuitNow and FPX transactions, surewim receives confirmation data from the payment gateway confirming the sending bank, transaction amount, and account name associated with the transaction. This data is used for withdrawal reconciliation and AML monitoring purposes.
- E-wallet transactions via Touch 'n Go eWallet, Boost, and GrabPay result in the receipt of account identifiers and transaction confirmation data sufficient to process your withdrawal request to the correct account.
- Cryptocurrency transaction data (BTC, USDT wallet addresses and transaction hashes) is retained in connection with each deposit or withdrawal and is used for AML screening and blockchain transaction verification.
8. Cookies & Tracking Technologies
The surewim Platform uses cookies and similar tracking technologies to operate core Platform functionality, maintain your session, detect fraudulent activity, and analyse aggregated usage patterns. The following categories of cookies are used:
Strictly necessary for the Platform to function. These cookies maintain your login session, remember your game lobby preferences, and facilitate secure payment transactions. They cannot be disabled without impairing Platform functionality.
Used to collect anonymised and aggregated data about how Players use the Platform — including which pages are most visited, how long sessions last, and which game categories are most popular. This data is used exclusively to improve the Platform experience.
Used to identify device characteristics and detect patterns associated with fraudulent access attempts, bot activity, and account takeovers. These cookies are essential to Platform security and cannot be disabled.
Used to remember your language preference (Bahasa Melayu, English, or Mandarin), preferred currency display, and other interface settings so that you do not need to re-select these preferences each time you visit the Platform.
You may manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of parts of the surewim Platform, including game loading and payment processing pages.
9. Data Retention
surewim retains Personal Data for no longer than is necessary to fulfil the purpose for which it was collected, subject to the following minimum retention periods required by applicable regulatory obligations:
- Account Data and KYC Documents: Retained for a minimum of five (5) years from the date of account closure or the last transaction, whichever is later, as required by AML regulations applicable to our licensing regime.
- Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction for AML, tax, and regulatory reporting purposes.
- Customer Support Communications: Retained for a period of two (2) years from the date of the communication, or for such longer period as may be required in connection with an open dispute or legal proceedings.
- Marketing Consent Records: Retained for the duration of your Account and for a period of one (1) year following withdrawal of consent, to demonstrate compliance with consent obligations.
- Session and Technical Logs: Retained for a period of ninety (90) days from the date of collection for security analysis purposes, after which they are deleted or anonymised.
Upon expiry of the applicable retention period, Personal Data is either permanently deleted from surewim's systems or irreversibly anonymised such that it can no longer be linked to any identifiable individual.
10. Data Security
surewim implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:
- 256-bit SSL/TLS encryption for all data transmitted between your browser or mobile device and the surewim Platform;
- Encryption of sensitive Personal Data at rest, including KYC documents and financial records, using industry-standard encryption algorithms;
- Multi-factor authentication for all administrative access to surewim's internal systems containing Personal Data;
- Role-based access controls ensuring that surewim personnel can only access the Personal Data categories necessary for the performance of their specific job functions;
- Regular penetration testing and security audits conducted by independent third-party security specialists;
- Real-time intrusion detection and DoS protection systems monitoring the Platform infrastructure24/7;
- Formal data breach response procedures including notification protocols to affected Players and relevant authorities where required by applicable law.
Your Responsibilities: While surewim implements robust security measures on its end, you are responsible for maintaining the confidentiality of your Account login credentials. surewim will never ask for your password via live chat, email, or any other communication channel. If you suspect your Account has been accessed without your authorisation, contact our support team immediately via live chat.
11. Your Rights
Subject to applicable data protection law and any overiding regulatory retention obligations (particularly AML-related requirements), you hold the following rights in respect of your Personal Data held by surewim:
Right of Access
You may request a copy of the Personal Data surewim holds about you, together with information about how it is processed and with whom it is shared.
Right to Rectification
You may request correction of inaccurate or incomplete Personal Data held on your Account or in our KYC records.
Right to Erasure
You may request deletion of your Personal Data where it is no longer required for the purpose for which it was collected, subject to applicable regulatory retention requirements.
Right to Restrict Processing
You may request that we restrict our processing of your Personal Data in certain circumstances, such as while we verify the accuracy of data you have contested.
Right to Data Portability
Where processing is based on your consent or contractual necessity, you may request your Personal Data in a structured, commonly used, and machine-readable format.
Right to Object
You may object to processing of your Personal Data carried out on the basis of legitimate interests, including for direct marketing purposes. Marketing objections take effect immediately.
To exercise any of the above rights, please contact our support team via live chat or at [email protected]. We will respond to verified requests within thirty (30) calendar days. In some cases, we may require you to verify your identity before we can fulfil a data subject request.
12. Minors & Age Verification
The surewim Platform is strictly for individuals who are at least 21 years of age. surewim does not knowingly collect or process Personal Data from individuals under the age of 21.
Age verification is a mandatory component of the KYC process. No withdrawal will be processed from any Account until the Account holder has submitted and received approval of identity documentation confirming that they are at least 21 years of age.
If surewim becomes aware, or has reasonable grounds to suspect, that Personal Data belonging to a person under the age of 21 has been collected, surewim will:
- Immediately suspend the relevant Account;
- Delete or destroy all Personal Data associated with the underage Account as soon as reasonably practicable, to the extent permitted by regulatory record-keeping obligations;
- Return any deposited funds to the payment source from which they originated; and
- Take such other steps as may be required by applicable law or our licensing authority.
If you believe that an individual under the age of 21 has registered an Account on the surewim Platform, please contact us immediately via live chat or at [email protected].
13. International Data Transfers
surewim's Platform infrastructure and certain Data Processors engaged by surewim may be located in countries outside Malaysia. Where Personal Data is transferred to a country outside the jurisdiction in which it was collected, surewim takes steps to ensure that an appropriate level of data protection is in place, including by:
- Entering into data processing agreements with recipient entities that incorporate standard contractual clauses or equivalent data protection provisions;
- Ensuring that cloud infrastructure and hosting providers operate under internationally recognised data protection certifications;
- Restricting the categories of Personal Data transferred internationally to the minimum necessary for the specific processing purpose.
If you have concerns about the international transfer of your Personal Data, please contact our support team for further information about the safeguards in place for any specific transfer.
14. Policy Amendments
surewim reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or Platform operations. Where amendments are material, surewim will use reasonable endeavours to notify registered Players by email to the address associated with their Account or by posting a prominent notice on the Platform prior to the changes taking effect.
The "Last Updated" date displayed at the top of this page reflects the most recent date on which a material revision was made. Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not accept the revised Policy, you must discontinue use of the Platform and close your Account.
15. Contact & Data Requests
For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the surewim Data Privacy team through the following channels:
Available 24/7 via the surewim Platform. Our live chat agents can assist with general privacy queries, data subject access requests, and urgent Account-related data concerns. Live chat is available in Bahasa Melayu, English, and Mandarin. Average response time: 3–5 minutes.
For formal data subject requests, complaints, or written correspondence regarding this Policy, please contact us at: [email protected]. Please include "Privacy Request" in the subject line of your email and provide sufficient information to enable us to verify your identity and locate your Account.
surewim aims to acknowledge all Privacy-related enquiries within five (5) business days and to resolve substantive requests within thirty (30) calendar days of receipt. Where a request is complex or where we receive a high volume of requests, we may extend this period by a further thirty (30) days with prior notification to you.
Please note that surewim does not operate a telephone support line. All formal data requests should be submitted via live chat or email. This ensures that your request is properly logged and handled in accordance with our data subject request procedures.
Play with Confidence on surewim
Now you know exactly how your data is handled. Join hundreds of thousands of Malaysian players who trust surewim for secure, fast, and fair online gaming. Aged 21 and above only.