Dwin44 Privacy Policy – How Your Data Is Protected

1Who We Are and How We Fit Within the LGPD

Dwin44 is a digital entertainment platform offering Sports Betting, Live Casino, crash games, slots, and jackpots for adult users in Brazil. For the purposes of the General Data Protection Law, dwin44 acts as controller of the personal data collected during use of the Platform — meaning dwin44 determines the purposes and means of processing.

This Privacy Policy applies to all users who access, browse, or register on dwin44. By creating an account, you confirm that you have read and understood this document. If you have any questions before proceeding, please contact us at contato@dwin44.click.

2What Data We Collect

Dwin44 collects personal data in three main situations: when you register on the Platform, when you use the available services, and when you interact with support. Below is an overview of the data processed:

Dwin44 does not collect sensitive data such as racial origin, religious belief, political opinion, or health data, except where strictly required for regulatory compliance and supported by an appropriate legal basis.

3How We Use Your Data

Every piece of data collected by dwin44 has a specific, justified purpose. We do not process information beyond what is necessary for each use. The main purposes are:

• Service delivery: create and manage your account, process deposits via Pix, boleto, card, PicPay, Mercado Pago, or TED, and record your bets and gameplay;
• Identity verification (KYC): confirm that you are over 18 years of age, resident in Brazil, and that the registration details you have provided are accurate;
• Fraud prevention: identify anomalous usage patterns, multiple accounts linked to the same CPF, and money laundering attempts;
• Account communications: send deposit and withdrawal confirmations, security alerts, and important Platform updates;
• Marketing (with consent): send personalized offers about dwin44 promotions, bonuses, and news — only if you have opted in to receive such communications;
• Responsible gambling: monitor usage patterns that may indicate problematic behavior and activate available protection tools;
• Legal obligations: comply with requirements from regulatory, tax, and judicial authorities under applicable Brazilian law.

4Legal Basis for Processing

The LGPD requires that all personal data processing be grounded in a valid legal basis. At dwin44, the primary legal bases used are:

• Contract performance (Art. 7, V): processing necessary to deliver the services you agreed to when creating your account — registration, betting, deposits, withdrawals, and support;
• Compliance with a legal obligation (Art. 7, II): processing required by law, such as age verification, anti-money laundering measures, and compliance with judicial requests;
• Legitimate interest (art. 7, IX): fraud prevention, Platform security, and internal analysis that improves the user experience, in full respect of your fundamental rights;
• Consent (Art. 7, I): sending marketing communications and using non-essential cookies — both of which can be revoked at any time.

5Data Sharing with Third Parties

Dwin44 does not sell personal data. Sharing occurs only in the following situations, always limited to the minimum necessary purpose:

5.1 Operational Partners

Technology vendors that provide services essential to the Platform's operation — including payment processors (financial institutions enabling Pix, TED, and boleto in Brazil), game providers (casino, slots, crash games), and cloud services. All are contractually required to uphold dwin44's and the LGPD's security and privacy standards.

5.2 Identity verification

Specialized KYC (Know Your Customer) services used to verify user identity and prevent fraud, particularly for higher-value withdrawals.

5.3 Competent Authorities

When required by court order or a request from a law enforcement or regulatory authority, dwin44 provides the data necessary to comply with the legal determination. To the extent permitted by law, the user is notified of the disclosure.

6How Long We Retain Your Data

Dwin44 retains personal data for the minimum time necessary for each purpose, respecting mandatory legal retention periods. The main retention rules are:

• Active account data: retained for as long as the account remains active and for up to 5 years after closure, for use in administrative or judicial proceedings;
• Financial records: retained for 5 years after the transaction, in accordance with tax and anti-money laundering legislation;
• KYC data: retained for a minimum of 5 years after account closure, in compliance with regulatory requirements;
• Security logs: retained for up to 6 months, unless required for specific investigations;
• Marketing communications: retained until consent is withdrawn; after withdrawal, data is removed from active lists within 10 business days.

Once retention periods expire, data is securely deleted or irreversibly anonymized.

7Cookies and Tracking Technologies

Dwin44 uses cookies and similar technologies to ensure the Platform functions correctly, improve the user experience, and, with your consent, personalize content and analyze site usage. The types of cookies used are:

7.1 Essential Cookies

Required for the basic operation of the Platform — keeping your session active, remembering language preferences, and ensuring login security. These cannot be disabled without affecting your ability to use the site.

7.2 Performance Cookies

Collect anonymous information about how users navigate dwin44 — pages visited, load times, and errors encountered — to help us continuously improve the Platform. They do not identify individual users.

7.3 Preference cookies

Store user preferences such as interface settings, favorite games, and applied filters, so you do not have to redo those choices on every visit.

7.4 Marketing cookies (with consent)

Used to display relevant content about dwin44 promotions based on your browsing history. Enabled only with your explicit consent, which can be revoked at any time in the Platform's cookie settings.

8Data Security

Dwin44 applies robust technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or accidental destruction. Key measures include:

• 256-bit SSL encryption on all connections between users and servers;
• Password storage using secure hashing algorithms — no password is ever stored in plain text;
• Two-factor authentication (2FA) available and recommended for all users;
• Continuous monitoring of access and intrusion attempts;
• Internal access to personal data is restricted based on the principle of least privilege — only staff members who need the data to perform their role are granted access;
• Periodic vulnerability testing and security audits.

In the event of a security incident that may affect your data, dwin44 will notify the National Data Protection Authority (ANPD) and the affected users within the timeframes established by the LGPD, with clear information about what occurred and the measures taken.

9Your Rights as a Data Subject (LGPD)

The General Data Protection Law grants you, as a data subject, a set of rights that dwin44 is fully committed to upholding. To exercise any of the rights listed below, send your request to contato@dwin44.click with your registered CPF and the specific right you wish to exercise. Requests are processed within up to 15 business days.

• Confirmation and access: confirm whether we process your data and obtain a full copy of it;
• Rectification: correct inaccurate or outdated data;
• Anonymization, blocking, or deletion: for data that is unnecessary, excessive, or processed in violation of applicable rules;
• Portability: receive your data in a structured format for transfer to another controller;
• Permanent deletion: request the deletion of data processed on the basis of consent, subject to any legal retention obligations;
• Sharing information: know which entities your data is shared with;
• Information on non-consent: be informed of the option to withhold consent and the consequences of doing so;
• Withdrawal of consent: withdraw consent given for processing activities based on that legal ground;
• Objection: object to processing carried out in violation of the LGPD;
• Review of automated decisions: request human review of decisions made solely through automated processing that affect your interests.

10Minors

Dwin44 is a platform intended exclusively for users aged 18 and over. We do not intentionally collect personal data from minors. Account registration requires age confirmation and CPF verification, which prevent access by underage individuals.

If you are the guardian of a minor and suspect they have created an account on dwin44, please contact us immediately at contato@dwin44.click. The account will be closed and all of the minor's data will be deleted as quickly as possible, subject only to mandatory legal retention periods.

11Changes to This Privacy Policy

Dwin44 may periodically update this Privacy Policy to reflect changes in data processing practices, legal requirements, or improvements to the services offered. When significant changes occur, you will be notified via your registered email or through a prominent notice on the Platform at least 7 calendar days in advance.

The date of the most recent update is always shown at the top of this document and in the metadata panel of this page. We recommend reviewing this Policy periodically to stay informed about how your data is handled at dwin44.

12Contact, DPO & Complaint Channels

12.1 Data Protection Officer (DPO)

Dwin44 has appointed a Data Protection Officer (DPO) responsible for handling data subject requests, providing guidance on LGPD compliance, and serving as the communication channel with the National Data Protection Authority (ANPD). You can reach the DPO by email at contato@dwin44.click — please use the subject line: "Privacy – LGPD".

12.2 General privacy support

For general questions about this Policy or the processing of your data, dwin44 support is available 24 hours a day, 7 days a week, in Brazilian Portuguese, via live chat on the Platform or by email at contato@dwin44.click.

12.3 Complaint to the ANPD

If, after contacting dwin44, you believe your rights as a data subject have not been properly addressed, you have the right to file a complaint with the National Data Protection Authority (ANPD), the regulatory body responsible for the LGPD in Brazil.