Privacy Policy of 81win — Data Protection

This Privacy Policy describes how the 81win (platform available at 81win.best) collects, stores, uses, shares, and protects the personal data of its users. This document was prepared in compliance with the General Personal Data Protection Law (LGPD — Law No. 13.709/2018) and other applicable Brazilian legislation.

This Policy applies to all users who access or use the 81win platform — whether on mobile, desktop, or any other device — including unregistered visitors, registered users, and promotion participants. By using 81win, you confirm that you have read and understood this Privacy Policy.

81win acts as personal data controller collected through the platform. When data is processed by technical partners (such as payment providers and game suppliers), they act as data processors, bound by contracts that ensure the same level of protection required by the LGPD.

81win collects only the data necessary for the purposes described in this Policy, in accordance with the LGPD's data minimization principle. The data collected falls into the following categories:

Data provided directly by you:

• Full name, date of birth, and CPF (Cadastro de Pessoa Física).
• Email address and mobile phone number.
• Full residential address (street, number, unit, ZIP code, city, state).
• Identity documents (RG, CNH, or passport) and proof of address, collected during the KYC verification process.
• Selfie with identity document for liveness check when required.
• Banking details and payment information — such as Pix key, credit/debit card details, and bank account for wire transfers — required to process deposits and withdrawals.
• Communications sent to 81win support via chat, email, or any other channel.

Data collected automatically during platform use:

• IP address and approximate geographic location.
• Device identifiers (UUID, IMEI in apps, browser fingerprint).
• Access data — date, time, pages visited, session duration, and actions taken on the platform.
• Device information — operating system, browser type, screen resolution, mobile carrier.
• Betting data — amount, market, event, outcome, financial transaction history.
• Cookie and similar technology data, as detailed in Section 8 of this Policy.

81win does not collect sensitive data such as racial or ethnic origin, religious beliefs, health data, or facial biometrics, except where strictly necessary for identity verification and with the user's explicit consent.

Data collected by 81win is used exclusively for the following purposes:

• Account creation and management: registration, authentication, password recovery, and user profile management.
• Service delivery: processing of Sports Betting, casino games, slots, crash games, and other platform products.
• Financial transaction processing: deposits via Pix, boleto, credit/debit card, Mercado Pago, PicPay, and TED; withdrawals and financial reconciliation.
• Identity verification (KYC): compliance with legal obligations to prevent money laundering and terrorism financing, as required by Brazilian law.
• Fraud prevention and security: detection of unauthorized access, duplicate accounts, bonus abuse, and other irregular activity.
• Responsible gambling: monitoring of behavioral patterns to proactively identify at-risk users and apply appropriate control tools.
• Compliance with legal obligations: responding to requests from competent authorities, compliance with the LGPD, and applicable tax and regulatory legislation.
• Service communications: notifications about transactions, account updates, changes to the Terms and Conditions, and essential operational communications.
• Direct marketing: sending promotions, offers, and news — exclusively when you have given express consent, which may be withdrawn at any time.
• Platform improvement: analysis of aggregated and anonymized data to improve the user experience and develop new products.

81win does not use your personal data for purposes incompatible with those listed above without prior notice and, where required, obtaining fresh consent.

As required by the LGPD, each personal data processing operation carried out by 81win has a specific legal basis. The main legal bases used are:

When the legal basis is consent, you have the right to withdraw it at any time without affecting any processing carried out beforehand. You can withdraw consent for marketing directly in your account settings or by emailing contato@81win.best.

81win does not sell or transfer your personal data to third parties for their own commercial purposes. Sharing occurs only in the following situations, all of which are backed by appropriate contractual safeguards:

• Payment processors: to process deposits via Pix, boleto, credit/debit cards, Mercado Pago, PicPay, and TED, the data required for each transaction is shared with the relevant financial institutions (Nubank, Itaú, Bradesco, Banco do Brasil, and others) and payment operators. These partners are regulated by the Brazilian Central Bank.
• Identity verification (KYC) providers: to comply with anti-money laundering legal obligations, your identity documents may be processed by KYC verification providers certified in Brazil.
• Game providers: session information and bet results are shared with providers such as Pragmatic Play, PG Soft, Hacksaw Gaming, and Spribe to the extent necessary for the games to function. These providers are subject to international data protection regulations.
• Technology infrastructure: cloud service, cybersecurity, and technical analytics providers that operate strictly as data processors under 81win's instructions.
• Competent authorities: data may be disclosed to Brazilian judicial, law enforcement, regulatory, or tax authorities when required by law, court order, or applicable regulation.

In all data-sharing instances, 81win requires partners to maintain security and confidentiality standards equivalent to those adopted by the platform, formalized in data processing agreements with specific protection clauses.

Personal data collected by 81win is retained for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum legal retention periods:

• Registration and identity data (KYC): retained for a minimum of 5 (five) years after account closure, as required by Brazilian anti-money laundering legislation (Law No. 9.613/1998 and COAF regulations).
• Financial transaction history: retained for a minimum of 5 (five) years for tax and regulatory compliance purposes.
• Betting history and gaming sessions: retained for a minimum of 1 (one) year for audit, dispute resolution, and responsible gambling purposes.
• Access and security logs: retained for 6 (six) months pursuant to the Marco Civil da Internet (Law No. 12,965/2014).
• Support communication data: retained for 2 (two) years for quality assurance and resolution of any disputes.
• Marketing data (with consent): retained until consent is withdrawn or for a maximum of 2 (two) years without interaction.

Once the applicable retention periods have expired, data is securely deleted or anonymized for use in aggregated statistical analysis. Data whose minimum legal retention period has not yet expired cannot be deleted upon request, but 81win will clearly explain the reason for retention.

81win implements technical and organizational measures proportionate to the risk to protect your personal data against unauthorized access, loss, alteration, or improper disclosure. Key measures include:

• 256-bit SSL/TLS Encryption across all communications between the user's device and 81win's servers.
• Encryption at rest for sensitive data stored in the platform's databases.
• Multi-factor authentication (MFA) for all internal employee access to systems containing personal data.
• Role-based access control (RBAC): each 81win employee accesses only the data strictly necessary for their role.
• Continuous monitoring of unauthorized access attempts, brute-force attacks, and anomalous behavior, 24 hours a day.
• Periodic security testing (penetration testing and vulnerability audits) carried out by independent external teams.
• Encrypted backups with secure retention and recovery procedures tested on a regular basis.
• Staff training on data protection and information security best practices, conducted on a regular basis.

Despite all measures in place, no system is completely immune to threats. In the event of a security incident affecting your data, 81win will follow the procedure described in Section 12 of this Policy.

On your end, 81win recommends using a strong, unique password for your account, enabling two-factor authentication (2FA) in your settings, and never sharing your credentials with anyone.

81win uses cookies and similar technologies to ensure the platform works correctly and to improve the user experience. The types of cookies used are described below:

81win does not use third-party advertising cookies nor tracking technologies for retargeting purposes on external platforms. Optional analytics cookies can be disabled in your browser settings (Chrome, Safari, Firefox, etc.) or in the privacy preference center available on the platform.

Cookie-like technologies — such as browser localStorage and device fingerprinting — are used exclusively for security and authentication purposes, following the same principles described above.

The LGPD grants you, as a data subject, the following rights regarding the processing carried out by 81win:

• Right of access: request confirmation that your data is being processed and obtain a copy of the personal data 81win holds about you.
• Right to correction: request the correction of incomplete, inaccurate, or outdated data.
• Right to anonymization, blocking, or deletion: request that data which is unnecessary, excessive, or processed in violation of the LGPD be anonymized, blocked, or deleted.
• Right to data portability: receive your data in a structured, interoperable format for transfer to another controller, where technically feasible.
• Right to information about data sharing: find out which public and private entities 81win shares your data with.
• Right to withdraw consent: withdraw previously given consents at any time, without affecting the lawfulness of processing carried out before the withdrawal.
• Right to object: object to processing based on legitimate interest where there is disagreement with the balancing assessment carried out by 81win.
• Right to review automated decisions: request human review of decisions made solely by automated processes that affect your interests.
• Right to petition the ANPD: file a complaint with the National Data Protection Authority (ANPD) if you believe your rights are not being respected.

To exercise any of these rights, please contact the Data Protection Officer (DPO) of 81win by email contato@81win.best, clearly stating the right you wish to exercise and the data it concerns. The response deadline is up to 15 business days from the date the request is received.

The 81win platform is intended exclusively to users aged 18 and over. 81win does not intentionally collect personal data from children or minors and does not allow anyone under 18 to register or use its services.

During registration, your CPF and date of birth are collected to verify that you meet the minimum age requirement. If the date of birth provided indicates the user is underage, registration is immediately blocked. The KYC process carried out before the first withdrawal includes document verification that confirms the user's age.

If 81win identifies, by any means, that a user under 18 has gained access to the platform, the account will be immediately suspended and the balance returned to the original payment method following an investigation. Any data inadvertently collected from minors will be deleted as soon as the situation is identified.

If you are the guardian of a minor and believe they may have accessed the 81win platform, please contact us immediately at contato@81win.best so we can act quickly.

81win prioritizes storing and processing data on servers located in Brazil. When transferring data to countries outside Brazilian territory is necessary — for example, for processing by game providers such as Pragmatic Play and PG Soft, which operate in international jurisdictions — 81win ensures that such transfers occur only when:

• The recipient country must provide a level of personal data protection in accordance with the LGPD, as recognized by the ANPD.
• The receiving operator must offer sufficient guarantees of compliance with LGPD principles and rights, formalized in contracts or equivalent instruments.
• The transfer is necessary for the contract performance between you and 81win (for example, to run a slot game from an international provider).
• The data subject's consent is obtained in a specific and explicit manner for the transfer in question, where required.

81win maintains an up-to-date record of all international data transfers carried out, available for review by the DPO upon a substantiated request.

In the event of a security incident that could result in significant risk or harm to data subjects — such as unauthorized access, leakage, or improper destruction of personal data — 81win will immediately take the following steps:

• Immediate containment: activation of the incident response plan to limit impact and preserve evidence for investigation.
• Notification to the ANPD: notification to the National Data Protection Authority within the timeframe established by current regulations, including a description of the affected data, the number of data subjects involved, and the measures taken.
• Notification to affected data subjects: email notification to users whose data was compromised, detailing the nature of the incident, the data involved, the potential risks, and the steps 81win is taking.
• Investigation: conducting a technical and forensic investigation to identify the cause, scope, and parties responsible for the incident.
• Remediation: implementation of corrective measures to prevent the recurrence of the incident and strengthen existing protections.

If you notice any suspicious activity on your 81win account or believe your credentials have been compromised, contact us immediately via live chat or by email at contato@81win.best.

To exercise your rights as a data subject, clarify questions about this Privacy Policy, or report concerns related to the processing of personal data, please contact 81win's Data Protection Officer (DPO):

For requests related to exercising your LGPD rights, we recommend sending an email with: (1) your full name, (2) the CPF registered with 81win, (3) the right you wish to exercise, (4) a description of the data you are referring to. We may request additional documentation to verify your identity before processing the request, as a security measure.

For general operational support — questions about deposits, withdrawals, bonuses, bets, and how the platform works — use the live chat available on 81win, which operates 24 hours a day, 7 days a week.

81win may periodically update this Privacy Policy to reflect changes in data processing practices, applicable Brazilian legislation, or ANPD regulatory requirements. All material updates will be communicated via:

• Email to the email address registered on your account, with at least 7 (seven) calendar days before taking effect, when the changes materially impact your rights or the processing of your data.
• Important notice on the 81win platform when logging in, during the transition period.
• Revision date update at the top of this page, always reflecting the most recent version.

We recommend reviewing this Policy periodically, even when there has been no active communication — especially before sharing new data with 81win. The version currently published on this page is always the one in effect.

Continued use of the 81win platform after updates to this Policy take effect constitutes acceptance of the new terms. If you do not agree with the changes, you may close your account before the effective date — any available real-money balance will be returned as normal.