Win44 Privacy Policy – LGPD Data Protection

1Personal Data Controller

For the purposes of Law No. 13,709/2018 (LGPD), the controller of the personal data of players registered on the win44.world platform is Win44. All decisions regarding how your data is collected, stored, used, and shared are made by Win44, which bears full responsibility for the processing carried out within the limits of this Policy and applicable Brazilian law.

To reach our data protection team, email suporte@win44.world with the subject "LGPD Request" or use the live chat available 24 hours a day, 7 days a week, directly on the Win44 platform.

2Data We Collect

2.1 Data provided directly by you

During registration and use of the Win44 platform, we collect the following data that you provide to us directly:

• Identification: full name, CPF, date of birth, and identity document photo (RG, CNH, or passport) when requested for KYC verification;
• Contact: email address, mobile number, full residential address including ZIP code;
• Financial: payment method data used (Pix key linked to CPF, credit and debit card data processed by certified payment partners, account details for TED transfers);
• Account: your chosen username, notification preferences, and responsible gaming settings you have configured.

2.2 Automatically collected data

When you access and browse the Win44 platform, we automatically collect:

• IP address and approximate geographic location;
• Browser type and version, operating system, and device type (mobile, tablet, or desktop);
• Pages visited, session duration, navigation sequence, and interactions with platform features;
• Betting history, games accessed, deposits and withdrawals made;
• Session data and authentication tokens to keep your login securely active.

2.3 Data We Do Not Collect

Win44 does not collect, request, or store sensitive data such as racial or ethnic origin, religious beliefs, political opinions, health data, or facial biometrics. We will never ask for full banking passwords, token numbers, or two-factor authentication codes from external accounts.

3How We Use Your Data

Personal data collected by Win44 is used exclusively for the following purposes:

Win44 does not use your data to build behavioral profiles for sale to external advertisers, for price discrimination based on personal data, or for any purpose not described in this Policy without your prior authorization.

4Legal Bases for Processing

Every personal data processing operation carried out by Win44 is grounded in at least one of the legal bases set out in Art. 7 of the LGPD. We rely on the following bases:

• Contract performance (Art. 7º, V): data required to create your account, process deposits via Pix, boleto, or card, process withdrawals, and deliver the sports betting and casino services you have contracted;
• Legal obligation (Art. 7, II): identity verification (KYC), anti-money laundering compliance, financial record retention, and communication with regulatory authorities as required by Brazilian law, including Law No. 14,790/2023 (Gaming Legal Framework);
• Consent (Art. 7, I): sending marketing communications and promotions by email or phone — you may withdraw this consent at any time through your Win44 account settings or via the unsubscribe link included in every communication;
• Legitimate interest (Art. 7, IX): improving the platform experience, personalizing relevant content, preventing fraud, and monitoring for responsible gaming purposes, provided these interests do not override your fundamental rights and freedoms.

5Data Sharing with Third Parties

5.1 Necessary operational partners

To operate the Win44 platform and deliver the contracted services, we share data with strictly necessary partners, always under appropriate confidentiality and data protection agreements:

• Payment processors: the minimum data required to process transactions via Pix, boleto bancário, credit and debit card, PicPay, Mercado Pago, and TED. No full card data is stored directly by Win44 — we use PCI-DSS certified gateways;
• Identity verification providers (KYC): documents submitted for verification are processed by specialized partners in compliance with international privacy standards;
• Game providers: Pragmatic Play, PG Soft, Spribe, Evolution, and other integrated providers receive only anonymous session identifiers — no personally identifiable data;
• Cloud infrastructure and hosting: servers hosting the Win44 platform operate under contracts that include data protection clauses compatible with the LGPD.

5.2 Public authorities

Win44 may be legally required to share data with Brazilian public authorities — such as the Financial Activities Control Council (COAF), the Federal Revenue Service, or the Judiciary — when duly required by legal or court order. In such cases, only the specifically requested data is provided, and you will be notified whenever legally permitted.

5.3 What we never do

Win44 never sells, rents, exchanges, or transfers your personal data to marketing companies, data brokers, third-party advertising networks, or any other entity for commercial purposes beyond those described in this Policy.

6Data Storage and Security

6.1 Security infrastructure

Win44 players' personal data is stored on secure servers protected by the following layers:

• In-transit encryption with TLS 1.3 / SSL 256-bit across all communications between your device and the platform;
• Encryption at rest for sensitive data stored in the database;
• Role-based access control — only Win44 team members with a proven operational need can access data, and all access is recorded in auditable logs;
• Continuous monitoring of unauthorized access attempts, with automatic alerts to the security team;
• Encrypted backups with geographic redundancy to ensure data integrity in the event of technical failures.

6.2 User responsibility

The security of your Win44 account also depends on you. We strongly recommend: using a strong, unique password (with upper and lowercase letters, numbers, and symbols), never sharing your login credentials with anyone, using secure Wi-Fi networks when accessing the platform on mobile, and logging out when using shared devices. If you suspect unauthorized access, contact support immediately via live chat.

7Cookies and Tracking Technologies

7.1 What they are and what they do

Cookies are small text files stored in your browser when you access the Win44 platform. We use cookies and similar technologies for the following purposes:

• Essential cookies: keep your session active after login, store language preferences and accessibility settings. Without them, the Win44 platform will not work properly. They cannot be disabled while you are using the site;
• Performance cookies: collect anonymous information about how pages are used — which sections are visited most, average session time, and errors encountered. We use this data to continuously improve the platform;
• Functionality cookies: remember preferences you've set, such as sports favorites, preferred odds, and display settings;
• Responsible gaming cookies: record session timeout alerts and limits you've configured in your account dashboard, ensuring that responsible gaming controls work correctly across sessions.

7.2 Cookie management

You can manage and delete cookies at any time through your browser settings. The most widely used browsers in Brazil — Chrome on Android, Safari on iOS, Firefox, and Edge — let you configure which types of cookies are accepted. Note that disabling essential cookies may prevent the Win44 platform from functioning properly.

7.3 No external advertising tracking

Win44 does not use tracking pixels from third-party advertising networks (such as Meta Pixel or Google Ads) to build behavioral profiles outside the platform for targeted advertising purposes. Browsing data collected through our cookies is used exclusively to improve your experience within the Win44 platform.

8Your Rights as a Data Subject (LGPD)

The LGPD grants you, as the data subject, a robust set of rights over the information Win44 holds about you. See each right below and how to exercise it:

• Confirmation and access (Art. 18, I and II): you may request confirmation that we process your data and obtain a copy of the information we hold about you in a readable format;
• Correction (Art. 18, III): if any of your personal data is incorrect, incomplete, or out of date, you may request a correction. Basic account information can be updated directly from your Win44 account dashboard;
• Anonymization, blocking, or deletion (Art. 18, IV): unnecessary, excessive, or non-LGPD-compliant data may be anonymized, blocked, or deleted upon justified request;
• Portability (Art. 18, V): you may request the portability of your personal data to another controller, in a structured and interoperable format, where technically feasible;
• Deletion of data processed under consent (Art. 18, VI): data processed solely on the basis of your consent may be deleted upon request, except where retention is required by a legal obligation;
• Information on sharing (Art. 18, VII): you have the right to know which public and private entities Win44 shares your data with;
• Withdrawal of consent (Art. 18, IX): consent given for marketing communications may be withdrawn at any time, at no cost and without providing a reason.

9Data Retention

Win44 retains your personal data for the minimum period necessary for each purpose, in compliance with all mandatory legal deadlines. See the main retention periods applied:

• Registration and active account data: retained for as long as the account remains active. After voluntary account closure, identifiable data is anonymized or deleted within 90 days, except for data that must be retained by legal obligation;
• Financial records (deposits, withdrawals, and betting history): retained for a minimum of 5 years after the transaction, in compliance with Brazilian anti-money laundering legislation and tax obligations;
• Identity verification documents (KYC): retained for a minimum of 5 years after the end of the contractual relationship, in accordance with sector regulatory requirements;
• Access and security logs: retained for 6 months, in accordance with the Brazilian Internet Civil Rights Framework (Law No. 12,965/2014);
• Support communications: retained for up to 2 years for quality assurance and dispute resolution purposes.

Once retention periods expire, data is securely deleted or irreversibly anonymized so it can no longer be linked to any specific individual.

10Minors

The Win44 platform is intended exclusively for individuals aged 18 or older. We do not knowingly collect personal data from minors and do not permit account registration or use of our services by anyone under 18 under any circumstances.

The identity verification (KYC) process includes date of birth confirmation and may require a photo ID to verify legal age. Any account found to belong to a minor will be closed immediately, with the balance withheld to meet legal obligations and the relevant authorities notified where applicable.

If you become aware that a minor has accessed or registered on the Win44 platform, please contact our support team immediately via live chat or at suporte@win44.world. We take this matter extremely seriously.

11International Data Transfer

To operate the Win44 platform with quality and availability, some of our infrastructure partners and technology providers may process data on servers located outside Brazil. When this occurs, Win44 ensures that international data transfers meet the requirements of Art. 33 of the LGPD through:

• Exclusive engagement of providers that meet international data protection standards equivalent to or higher than those required by the LGPD;
• Inclusion of standard data protection contractual clauses in all agreements with partners that carry out international transfers;
• Preference for providers established in countries recognized by the ANPD (Autoridade Nacional de Proteção de Dados) as offering an adequate level of data protection.

You may request information about which partners carry out international transfers and the safeguards in place by emailing suporte@win44.world with the subject line "International Data Transfer – LGPD".

12Changes to this Privacy Policy

Win44 may update this Privacy Policy periodically to reflect changes in data processing practices, Brazilian legislation, or the services offered. Any relevant update that affects your rights will be communicated at least 7 days in advance by email to all players with an active account.

The date of the last update is always shown at the top of this page. Continued use of the Win44 platform after any changes take effect constitutes acceptance of the updated Policy. If you disagree with any changes, you may close your account before the effective date, as described in the Terms and Conditions.

13Contact and Data Protection Officer (DPO)

Win44 has appointed a Data Protection Officer (DPO) as provided under Art. 41 of the LGPD. To exercise your data subject rights, clarify questions about this Policy, or submit any privacy-related request, please use the channels below:

• Email: suporte@win44.world (subject: "LGPD Request") — response within 15 business days;
• Live chat: available 24 hours a day, 7 days a week, directly on the Win44 platform — for urgent account security issues;
• Complaints to the ANPD: if you believe your rights have been violated after contacting Win44, you may file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd.

We respond to all LGPD requests within 15 business days. In complex cases requiring further investigation, we may extend this period by an additional 15 days, with prior notice to the requester.