Privacy Policy surgawin – Protecting Our Members' Data

1 Introduction

Surgawin is fully committed to safeguarding the privacy and personal data security of every member on our platform. We understand that your trust is not something to be taken lightly — especially when it concerns personal and financial information.

This Privacy Policy is written in language we've made as clear as possible, so you truly understand what happens to your data — not just dense legal text that's hard to follow. We believe transparency is the best way to build lasting trust.

This document explains what types of data we collect, why we need it, how we store and protect it, when we may share it, and what your rights are as the data owner. If anything is unclear, our support team is available to answer your questions at any time.

2 Personal Data We Collect

We only collect data that is strictly necessary to provide you with a safe, legal, and high-quality service. Below are the categories of data we collect and their purposes:

3 How We Collect Data

Your data is collected through several channels, all of which are transparent and conducted with your knowledge:

• Account registration — When you complete the registration form, basic information such as your name, email, and phone number is immediately stored in our system with encryption.
• KYC Process — When you upload identity documents for verification, the data is processed by our KYC team and stored in accordance with applicable security standards.
• Financial transactions — Every deposit and withdrawal you make records the transaction data necessary for audit, security, and regulatory compliance purposes.
• Gaming activity — Your interactions with games on the platform are automatically recorded for service analytics and suspicious behavior detection purposes.
• Cookies & similar technologies — When you access our website or app, device and session technical information is automatically collected.
• Support communications — Conversations with our support team (including live chat and email) may be stored for service quality improvement purposes.

4 How We Use Your Data

Every piece of data we collect has a clear and limited purpose. We do not use your data for purposes unrelated to surgawin's services. The full purposes of data use are as follows:

• Account operations — Allow you to log in to your account, verify your identity, process deposits and withdrawals, and manage your account preferences.
• Security and fraud prevention — Detect unusual activity, verify account ownership, and protect your funds from unauthorized access.
• Legal obligation compliance — Comply with anti-money laundering (AML) regulations, KYC requirements, and report to relevant authorities when required.
• Service improvement — Analyze usage patterns to improve the interface, speed up the system, and add features more relevant to our members.
• Communication — Send important account notifications, security updates, and promotional information if you have provided your consent.
• Responsible gaming — Monitor gameplay patterns to identify signs of problematic gaming behavior and offer appropriate assistance.

5 Data Storage and Security

Surgawin uses enterprise-grade cloud infrastructure to store member data. All data is stored on servers located in certified data centers with multi-layered physical and digital security.

The security measures we implement include:

• Data encryption at rest using AES-256
• Data encryption in transit using TLS 1.3
• Employee data access is restricted based on job requirements (principle of least privilege)
• Audit logs for every access to sensitive member data
• Regular security testing by internal teams and independent third parties
• Intrusion detection system and 24/7 security monitoring

Your data is retained for as long as your account is active and for any period required by applicable regulations. Once the retention period ends, data is securely deleted using non-recoverable deletion methods.

6 Sharing Data with Third Parties

We do not sell or rent your personal data to anyone. However, in the course of operating the platform, there are situations where we need to share certain data with trusted third parties:

• Payment service providers — To process deposits and withdrawals, relevant financial data is shared with banks and digital wallet providers partnering with us, bound by strict confidentiality agreements.
• KYC verification service providers — Technology partners assisting with identity verification only receive the data necessary and are held to the security standards we set.
• Gaming platform providers — Minimal technical data required to run games may be shared with game provider partners in accordance with existing technical integrations.
• Legal authority — We will share data with authorized legal authorities if required by applicable law, court order, or financial crime investigation.

7 Cookies and Tracking Technologies

Surgawin uses cookies and similar technologies to enhance your platform experience, maintain the security of your login session, and analyze website performance in aggregate. Cookies are small files stored on your device when you access our services.

Types of cookies we use:

• Essential cookies — Required for core platform functions to operate properly, including maintaining your login session and security preferences. These cookies cannot be disabled.
• Functional cookies — Store your preferences such as display language and notification settings so you don't need to reconfigure them each time you log in.
• Analytical cookies — Help us understand how members use the platform in an aggregated and anonymized manner, so we can continually improve the gaming experience.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may significantly affect platform functionality.

8 Your Rights as a Data Owner

As a surgawin member, you hold a number of rights regarding your personal data that we fully respect. You may exercise these rights at any time through our support team:

9 Minor User Protection

Surgawin's services are strictly intended for individuals aged 18 and above. We do not knowingly collect or store personal data from individuals who do not meet this minimum age requirement.

If we become aware that data from users under 18 years of age has entered our system, we will immediately delete that data and close the account in question. Our KYC process is designed to detect and prevent registration by underage users.

10 Privacy Policy Updates

Surgawin may update this Privacy Policy from time to time to reflect changes in our operational practices, regulatory updates, or service improvements. Any material changes will be communicated to members via platform notifications or registered email.

The "Effective Date" at the top of this page will always reflect the latest active version. We encourage you to periodically review this page to stay informed about how your data is managed.

Continued use of surgawin's services after an updated Privacy Policy is published constitutes acceptance of the revised policy. If you do not agree with the changes, you may stop using the services and submit an account closure request to our team.