Privacy Policy

1. Who we are

This Privacy Policy explains how [公司法定名称，待填] ("we", "us", "our") collects, uses, shares and protects personal data when you use wingoaaal.xyz and our related services (the "Service").

For the purposes of the EU/UK General Data Protection Regulation (GDPR), we are the data controller in respect of the personal data described below.

2. Data we collect

We collect the following categories of personal data. We do not sell your personal data.

• Account data — email address, username, date of birth (to verify you are 18+), hashed password, language and display preferences.
• Identity verification (KYC) data — where required by applicable anti-money-laundering law: your name, date of birth, residential address, nationality, government-issued identity document images, and a liveness/selfie check. This data is collected and verified by our identity-verification provider on our behalf.
• Transaction and betting data — deposits, withdrawals, bets placed, odds and markets, balances, bonuses, and the crypto wallet addresses you use with the Service.
• Blockchain data — public blockchains are permanent and transparent. On-chain transactions involving the wallet addresses you use are publicly visible to anyone, and we cannot delete or alter data recorded on a blockchain. This applies to on-chain data independently of our own records.
• Technical and device data — IP address, approximate location derived from IP, device type, operating system, browser, language, and unique device/installation identifiers.
• Usage data — pages and features used, referring URL, session timestamps and duration, and interactions with promotions or communications.
• Free prediction game data — if you play the Free Prediction Challenge without an account, your browser generates a random guest key that is stored in local storage. The guest key is pseudonymous: it is not your name, email address or wallet address, and we do not use it to identify you outside the game. We link it to your match picks, prediction score and leaderboard position. If you sign in, those entries are linked to your account instead. Clearing this site's local storage removes the guest key and starts a new guest profile.
• Communications — messages you send to our support team and records of our responses.
• Risk and compliance data — records of checks we are legally required to perform, including sanctions and politically-exposed-person screening, fraud indicators, and self-exclusion or responsible-gambling settings.

3. How and why we use your data

Under GDPR we must have a "legal basis" for each use. The table below sets out our purposes and the corresponding legal bases.

Where we rely on consent, you may withdraw it at any time — for cookies, use the "Cookie settings" link in the footer; for marketing, use the unsubscribe link in any message or contact us.

Where we rely on legitimate interests, we have balanced those interests against your rights. You may object at any time (see section 10).

4. Sharing your data

We share personal data only as described here, and only with parties bound by written agreements requiring appropriate confidentiality and security.

• Identity verification and compliance providers — to perform KYC, sanctions screening and AML checks.
• Blockchain analytics providers — to trace the origin of funds and detect fraudulent or high-risk wallets, as required for AML compliance.
• Payment and custody providers — to process deposits and withdrawals and to operate hot/cold wallets.
• Cloud hosting and infrastructure providers — our servers and databases are hosted by third parties.
• Analytics providers — Google Analytics, loaded only after you consent to analytics cookies.
• Email and communication providers — to send transactional and (with consent) marketing messages.
• Professional advisers — auditors, insurers, and legal advisers, under duties of confidentiality.
• Regulators, courts and law enforcement — where we are legally required to disclose, or where necessary to establish or defend legal claims.
• A successor entity — if we are acquired, merge, or transfer assets, personal data may be transferred as part of that transaction, subject to this Policy.

We do not sell your personal data, and we do not share it with third parties for their own independent marketing purposes.

5. Cookies and similar technologies

We use cookies and similar storage technologies. They fall into three categories:

Our free prediction game also uses browser local storage (not a cookie) to remember a random guest key that links your picks to this device. It contains no name, email or wallet address, is not readable by other websites, and is not used for advertising. You can remove it at any time by clearing this site's local storage — you will then continue as a new guest in the game.

You can change or withdraw your cookie choices at any time using the "Cookie settings" link in the footer of every page. Withdrawing consent stops future processing; it does not affect the lawfulness of processing carried out before withdrawal.

You can also control cookies through your browser settings, although blocking strictly necessary cookies will prevent parts of the Service from working.

6. International transfers

Some of our service providers are located outside the European Economic Area (including in the United States). Where we transfer personal data outside the EEA or the UK, we rely on appropriate safeguards — principally the European Commission's Standard Contractual Clauses, together with supplementary measures where required (such as encryption in transit and at rest). You may request a copy of the relevant safeguards by contacting us.

7. How long we keep your data

We keep personal data only as long as necessary for the purposes described above, including to meet legal, regulatory and tax requirements. Gambling and anti-money-laundering law generally requires us to retain identification and transaction records for a minimum period after the end of the relationship.

When a retention period ends we delete or irreversibly anonymise the data, unless a longer period is required by law or we need it to establish, exercise or defend legal claims.

8. Security

We use technical and organisational measures designed to protect personal data, including encryption in transit (TLS) and at rest, hashed passwords, access controls limiting personal data to personnel who need it, network restrictions on our production systems, logging and monitoring, and periodic review of our providers.

No method of transmission or storage is completely secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, you, without undue delay.

9. Automated decision-making and profiling

We use automated processing to detect fraud, bonus abuse and money-laundering risk. These checks may result in your account being flagged for manual review, having withdrawals held, or being restricted. Where a decision is based solely on automated processing and produces legal or similarly significant effects, you have the right to obtain human intervention, express your point of view and contest the decision — contact us using the details in section 12.

10. Your rights

Subject to applicable law, you have the right to:

• Access — obtain a copy of the personal data we hold about you.
• Rectification — have inaccurate or incomplete data corrected.
• Erasure — have your data deleted where there is no overriding legal reason for us to keep it. Note that AML and gambling record-keeping obligations often prevent immediate deletion.
• Restriction — ask us to limit how we use your data while a concern is resolved.
• Portability — receive data you provided to us in a structured, machine-readable format, or have it transmitted to another controller.
• Object — object to processing based on our legitimate interests, and to direct marketing at any time.
• Withdraw consent — at any time, where processing is based on consent (including analytics cookies).
• Complain — lodge a complaint with your local supervisory authority. If you are in the EU/EEA you can find yours at edpb.europa.eu; in the UK, the Information Commissioner's Office (ico.org.uk).

To exercise any of these rights, contact us at [privacy@你的域名，待填]. We will respond within one month, and may extend this by up to two further months for complex requests, telling you if we do. We may need to verify your identity before acting, and in limited cases we may refuse a request where the law requires us to retain the data or where an exemption applies.

11. Age restriction, responsible gambling and identity checks

• The Service is strictly for adults. You must be at least 18 years old. We ask you to confirm your age before entering, and we may ask for documentary proof at any time. Accounts found to belong to minors are closed and any funds are handled in accordance with applicable law.
• We are required by anti-money-laundering law to verify your identity before you can withdraw, and in some circumstances before you can deposit or bet. This is a legal obligation and not optional.
• We provide responsible-gambling tools, including deposit limits, session reminders, time-outs and self-exclusion. Please see our Responsible Gambling page. If gambling is affecting your life, support is available.

12. Changes to this Policy

This Policy is version 2.0. If we make material changes — for example, a new purpose of processing or a new category of recipient — we will update this page, revise the "last updated" date, and where required ask you to renew your consent (our cookie banner does this automatically when the policy version changes). We encourage you to review this page periodically.

13. Contact us

Questions, requests or complaints about privacy: [privacy@你的域名，待填]

General support: see our Help Centre.

Postal address: [注册地址，待填]

Related policies

Terms & Conditions · AML Policy · Responsible Gambling

Last updated: February 2026