Privacy Policy – tpower2

1. Who We Are

tpower2 ("we", "us", "our") is the operator of the online gaming platform accessible at tpower2.win, licensed by an international gaming authority. tpower2 acts as the data controller in respect of personal data collected from Members and visitors of the Platform. This Privacy Policy applies to all personal data processed by tpower2 in connection with the operation of tpower2.win, including its casino, sportsbook, poker, and any other services offered through the Platform.

This Policy should be read alongside the tpower2 Terms & Conditions, which governs the contractual relationship between tpower2 and its Members. Where capitalised terms are used in this Policy without definition, they carry the same meaning as defined in the Terms & Conditions.

2. Personal Data We Collect

tpower2 collects the following categories of personal data from Members and Platform visitors:

tpower2 does not collect Special Categories of personal data (such as racial or ethnic origin, health data, or biometric data) except where strictly required by applicable anti-money-laundering legislation and only to the minimum extent necessary.

3. How We Collect Your Data

tpower2 collects personal data through the following means:

• Directly from you — when you register an Account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or respond to a promotion or survey.
• Automatically — when you access the Platform, our servers automatically log Technical Data including your IP address, device identifiers, session durations, and pages visited. This data is collected via server logs and, where applicable, cookies and similar tracking technologies.
• From third parties — we may receive identity verification confirmation from KYC service providers, fraud screening signals from payment processors, and geolocation data from IP intelligence services. We do not purchase marketing data lists from third-party data brokers.

4. Purposes of Processing

tpower2 processes your personal data for the following purposes:

• Account management — to create, administer, and maintain your tpower2 Member account, including authentication and session management.
• Service delivery — to provide you with access to games, sportsbook markets, live casino tables, poker, and all other Platform features.
• Payment processing — to process deposits and withdrawals in MYR via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and other supported payment channels.
• KYC and identity verification — to verify your identity and age as required under tpower2's gaming licence and applicable anti-money-laundering laws.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent transactions, multi-accounting, bonus abuse, and other prohibited conduct.
• Legal and regulatory compliance — to fulfil obligations under our gaming licence, applicable Malaysian law, anti-money-laundering requirements, and instructions from competent regulatory or law enforcement authorities.
• Responsible gaming — to monitor gaming patterns, administer self-exclusion tools, enforce deposit and loss limits, and identify members who may be exhibiting signs of problem gambling behaviour.
• Customer support — to respond to your queries, complaints, and requests for account assistance.
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates where you have provided your consent. You may withdraw consent at any time by contacting support.
• Platform improvement — to analyse aggregated usage patterns, game performance, and Member behaviour to improve the Platform's functionality and content offering.

5. Legal Bases for Processing

tpower2 processes your personal data under the following legal bases:

• Performance of contract — processing necessary to fulfil our obligations to you under the Terms & Conditions, including account management, game access, and payment processing.
• Legal obligation — processing required to comply with our gaming licence conditions, anti-money-laundering regulations, and other applicable laws.
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where these interests are not overridden by your fundamental rights and freedoms.
• Consent — processing for marketing communications and any non-essential cookies, where we have obtained your prior consent. Consent is freely given and may be withdrawn at any time without detriment to your account standing.

6. Data Sharing and Disclosure

tpower2 does not sell your personal data to third parties. We share your data only in the following circumstances and with the following categories of recipients:

• Payment processors and e-wallet providers — to process your MYR deposits and withdrawals via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX partner banks, and other integrated payment channels. Each payment provider operates under its own privacy policy and processes your data only to the extent required to complete the transaction.
• KYC and identity verification service providers — third-party providers engaged by tpower2 to verify identity documents and screen Members against sanctions and PEP (politically exposed persons) lists as required by our licence.
• Game providers and software licensors — game providers whose titles are hosted on or linked from the tpower2 Platform may receive pseudonymous session data for technical and audit purposes. No directly identifying information is shared with game providers beyond what is technically necessary.
• Regulatory and law enforcement authorities — tpower2 will disclose personal data to gaming regulators, financial intelligence units, and law enforcement agencies where required by law or by the terms of our gaming licence. We report suspicious transactions in accordance with applicable anti-money-laundering obligations.
• Professional advisers — legal advisers, auditors, and insurers engaged by tpower2 in the ordinary course of business, subject to strict confidentiality obligations.
• Business successors — in the event of a merger, acquisition, or transfer of the tpower2 business, Member data may be transferred to the successor entity, subject to equivalent data protection commitments.

7. International Data Transfers

tpower2's platform infrastructure and some of its third-party service providers may be located outside Malaysia. Where personal data is transferred outside Malaysia, tpower2 ensures that appropriate safeguards are in place in accordance with applicable data protection requirements, including contractual protections equivalent to those required under Malaysian law.

Where transfers occur to jurisdictions without an adequacy determination, tpower2 implements standard contractual clauses or equivalent mechanisms to ensure your data receives an equivalent level of protection to that applicable in Malaysia.

8. Data Retention

tpower2 retains your personal data for as long as your Account remains active and for the minimum period required by our gaming licence and applicable law after Account closure. Specifically:

• Identity and KYC documents: retained for a minimum of five years from the date of Account closure, as required by anti-money-laundering regulations.
• Transaction and gaming activity records: retained for a minimum of five years from the date of each transaction.
• Marketing consent records: retained for the duration of consent plus three years for compliance purposes.
• Customer support communications: retained for three years from the date of the last interaction.

After the applicable retention period, personal data is securely deleted or anonymised in accordance with tpower2's data disposal procedures.

9. Your Rights

Subject to applicable law, you have the following rights with respect to your personal data held by tpower2:

• Right of access — to request a copy of the personal data tpower2 holds about you.
• Right of rectification — to request correction of inaccurate or incomplete personal data.
• Right to erasure — to request deletion of your personal data, subject to our legal obligations to retain certain data under our gaming licence.
• Right to restrict processing — to request that tpower2 limit the processing of your data in certain circumstances.
• Right to data portability — to receive a copy of data you have provided to tpower2 in a structured, machine-readable format.
• Right to withdraw consent — to withdraw any consent you have given for marketing communications or non-essential cookies at any time, without affecting the lawfulness of prior processing.
• Right to object — to object to processing based on legitimate interests, including profiling for direct marketing purposes.

To exercise any of these rights, please contact tpower2 at [email protected]. We will respond to all valid requests within 30 days. Where requests are complex or numerous, we may extend this period by a further 30 days with notice.

10. Cookies and Tracking Technologies

tpower2 uses cookies and similar technologies to operate the Platform and improve Member experience. The following categories of cookies are used:

• Strictly necessary cookies — required for login session management, security tokens, and basic Platform functionality. These cannot be disabled without impairing the Platform's core operation.
• Functional cookies — store your preferences such as language settings, currency display, and game lobby filters to enhance your session experience.
• Analytics cookies — collect anonymised usage statistics to help tpower2 understand how Members use the Platform and identify areas for improvement. These are subject to your consent.
• Security cookies — used by fraud detection systems to identify and flag anomalous session behaviour.

You can manage or withdraw your consent to non-essential cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the tpower2 Platform.

11. Children's Privacy

tpower2 is strictly an adult platform. The minimum age for registration and use of any tpower2 service is 21 years. tpower2 does not knowingly collect personal data from individuals under the age of 21. Where tpower2 becomes aware that a Member is under 21, the Account will be immediately suspended and all personal data collected will be deleted, subject to any legal obligation to retain records of the age violation for compliance purposes.

Age verification is conducted as part of the mandatory KYC process for all new Members.

12. Data Security

tpower2 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and tpower2 servers
• Encryption of sensitive data fields (including passwords, which are stored as bcrypt hashes) at rest
• Access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security audits and penetration testing of the Platform infrastructure
• Multi-factor authentication options available to all Members
• Intrusion detection systems and real-time monitoring of Platform access logs

In the event of a personal data breach that poses a risk to your rights and freedoms, tpower2 will notify the relevant supervisory authority and, where required, affected Members in accordance with applicable data protection law.

13. Updates to This Privacy Policy

tpower2 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, applicable law, or the tpower2 Platform's functionality. Where changes are material, tpower2 will notify Members via email or a prominent notice on the Platform prior to the change taking effect. The "Last Updated" date at the top of this page will be revised to reflect each update. Continued use of the Platform after an updated Privacy Policy is published constitutes your acceptance of the revised terms.

14. Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by tpower2, please contact our Data Protection team:

Email: [email protected]

We will acknowledge all privacy-related enquiries within 48 hours and provide a substantive response within 30 days. If you are unsatisfied with our response, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction.