Privacy Policy — 119win: Your Data, Protected

1.Data Controller

The 119win, operator of the platform available at 119win.best, is the controller of personal data collected from registered users and site visitors. For the purposes of this Privacy Policy, "controller" means the entity that determines the purposes and means of processing personal data, as defined by the General Data Protection Law (LGPD – Law No. 13.709/2018).

All communications regarding the processing of your personal data may be directed to the support channel of 119win by email privacidade@119win.best or via live chat available 24 hours a day on the platform. For data protection matters, our compliance team will respond within 15 business days, as required by the LGPD.

2.Data We Collect

The 119win collects personal data at various points during your interaction with the platform. The categories of data collected and the circumstances in which collection takes place are detailed below:

2.1 Registration Data

• Full name;
• Email address;
• CPF (Individual Taxpayer Registry);
• Date of birth;
• Mobile phone number;
• Full residential address (zip code, street, number, complement, neighborhood, city, state).

2.2 Identity Verification Data (KYC)

• Government-issued photo ID (RG, CNH, or passport) — front and back;
• Proof of address;
• Proof of ownership of the payment method;
• Selfie with ID document, when requested for advanced verification.

2.3 Financial Data

• Pix key registered for deposits and withdrawals;
• Bank account details (bank, branch, account number) for TED transfers via Nubank, Itaú, Bradesco, Banco do Brasil, or others;
• Last digits of the credit or debit card used;
• History of deposits, withdrawals, and bets placed on the platform;
• Amounts and dates of all financial transactions.

2.4 Platform Usage Data

• IP address and approximate geographic location;
• Device type and version (mobile, tablet, desktop);
• Operating system and browser version;
• Pages visited and time spent on each;
• Games accessed, bets placed, and session history;
• Access logs and activity records for security purposes.

2.5 Communication Data

• Live chat support conversation history;
• Emails exchanged with the support team;
• Records of complaints and service requests.

3.How We Use Your Data

The data collected by the 119win are used solely for the purposes described below. We do not use your data for any other purpose without informing you in advance and, where required, without obtaining your consent:

• Account management: registration, authentication, access to services, and user profile management;
• Financial processing: deposits via Pix, bank slip, credit/debit card, PicPay, Mercado Pago, and BRL withdrawals to registered payment methods;
• Identity verification: KYC process for fraud prevention, anti-money laundering compliance, and adherence to regulatory requirements;
• Customer support: support, query resolution, and complaint handling via live chat or email;
• Platform security: detection of suspicious activity, fraud prevention, and protection of service integrity;
• Legal compliance: compliance with legal, regulatory, and competent authority obligations;
• Product improvement: aggregated and anonymized usage analysis to improve the platform experience;
• Relevant communications: sending information about your account, promotions, and 119win updates, when you have authorized receipt.

The 119win follows the principle of data minimization: we collect only what is strictly necessary for the stated purposes. Data that is no longer needed is deleted or anonymized as described in section 9 of this policy.

4.Legal Basis for Data Processing

Under the LGPD, all personal data processing must be based on a valid legal ground. The 119win processes your personal data based on the following legal grounds:

• Contract performance (art. 7º, V, LGPD): processing is necessary to perform the platform usage agreement you accepted at registration — this includes processing bets, deposits, withdrawals, and account management;
• Compliance with a legal obligation (art. 7º, II, LGPD): data processed to comply with anti-money laundering regulations (Law No. 9.613/1998), COAF requirements, and other applicable regulatory obligations;
• Legitimate interest (art. 7, IX, LGPD): processing necessary for platform security, fraud prevention, and service improvement, provided it does not override your fundamental rights;
• Consent (art. 7º, I, LGPD): for sending marketing communications, promotions, and newsletters, based on your express consent, which may be withdrawn at any time.

5.Data Sharing with Third Parties

The 119win does not sell, rent, or transfer your personal data to third parties for commercial purposes. Data sharing takes place only in the strictly necessary situations described below, and always with appropriate contractual and legal safeguards:

5.1 Operational Partners

To operate the platform, the 119win uses third-party services that may access personal data to the extent necessary to perform their functions:

• Payment processors: partners responsible for processing Pix, bank slip, credit/debit card, PicPay, Mercado Pago, and TED transactions receive the financial data required to process payments in BRL;
• KYC providers: specialized identity verification companies that process documents submitted during the verification process;
• Game providers: companies such as Pragmatic Play, NetEnt, Microgaming, Playtech, and Evolution that supply casino games and slots receive session data necessary to record gameplay history;
• Infrastructure services: cloud hosting providers, CDN services, and security solutions that ensure the technical operation of the platform.

All operational partners of 119win are contractually required to handle personal data with the same level of protection demanded by the LGPD and this policy.

5.2 Legal Obligations

The 119win may share personal data with public authorities, regulatory bodies, or government entities when required by law, court order, competent authority request, or for defense in administrative and judicial proceedings. This includes mandatory disclosures to the Financial Activities Control Council (COAF) in accordance with anti-money laundering legislation.

6.International Data Transfers

Some of the technology and infrastructure partners that 119win may be located outside Brazil. When this occurs, international transfers of personal data are carried out only to countries or organizations that offer an adequate level of protection, as assessed by the National Data Protection Authority (ANPD), or through the adoption of standard contractual clauses that ensure protection equivalent to that required by the LGPD.

On all international transfers, the 119win retains control over how your data is processed and contractually requires international recipients to adopt security measures consistent with Brazilian data protection law.

7.Cookies and Tracking Technologies

The 119win uses cookies and similar technologies to ensure the platform functions correctly, improve the user experience, and analyze service performance. The types of cookies used are:

7.1 Strictly Necessary Cookies

These are cookies essential to the platform's operation: they keep your session active after login, remember your language preferences, and ensure financial transactions are processed securely. These cookies cannot be disabled without affecting your use of the platform.

7.2 Performance and Analytics Cookies

Collect information about how users interact with the 119win — most visited pages, load times, errors encountered — in aggregated and anonymous form. This data is used solely to improve the platform.

7.3 Functionality Cookies

They remember your interface preferences, such as language and notification settings, making your experience more personalized without collecting personally identifiable data.

You can manage your cookie settings through your account preferences panel or your browser settings. Disabling strictly necessary cookies may affect the normal functioning of the platform.

8.Data Security

Protecting users' personal data is an operational priority for 119win. We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, destruction, alteration, or improper disclosure:

• Encryption in transit: all communications between your device and the platform use 256-bit TLS/SSL encryption;
• Encryption at rest: sensitive data stored on 119win's servers is encrypted prior to storage;
• Access control: only staff with a legitimate need are granted access to users' personal data, with mandatory multi-factor authentication;
• Continuous monitoring: intrusion detection and anomaly monitoring systems operate around the clock to identify suspicious activity;
• Security audits: periodic vulnerability assessments and penetration tests are conducted by specialized firms;
• Data segregation: financial data and identification data are stored in separate systems with independent access controls.

9.Data Retention and Deletion

The 119win retains your personal data for as long as necessary to fulfill the purposes for which it was collected, in compliance with applicable legal obligations:

9.1 Retention Periods

• Active account data: kept for as long as the account remains active on the platform;
• Financial transaction data: retained for at least 5 years after the transaction, as required by tax and anti-money laundering legislation;
• KYC data: retained for at least 5 years after account closure, in accordance with COAF regulations;
• Security logs: retained for 12 months for incident investigation purposes;
• Support communication history: retained for 24 months for quality assurance purposes.

9.2 Data Deletion

After the required retention period ends, data is securely deleted using methods that prevent recovery. Data that no longer needs to be kept in identifiable form may be anonymized and used for statistical purposes and platform improvement.

You may request the deletion of your personal data through the privacy channel of 119win. Requests will be fulfilled within the legal deadline of 15 business days, except where retention is required by law — in which case 119win will inform you of the legal grounds for retaining the data.

10.Your Rights as a Data Subject (LGPD)

The LGPD grants you a set of rights over your personal data processed by the 119win. You may exercise any of these rights at any time by emailing privacidade@119win.best or via the platform's live chat:

• Access: you may request confirmation that 119win processes your data and receive a copy of the information we hold about you;
• Correction: you may request the correction of personal data that is incomplete, inaccurate, or out of date;
• Anonymization, blocking, or deletion: you may request that data which is unnecessary, excessive, or processed in violation of the LGPD be anonymized, blocked, or deleted;
• Portability: you have the right to request the transfer of your data to another service provider, in a structured and commonly used format;
• Information on data sharing: you may request information about the entities with which 119win shares your data;
• Consent withdrawal: where processing is based on your consent, you may withdraw it at any time;
• Objection: you may object to processing carried out on other legal grounds in the event of non-compliance with the LGPD;
• Complaint to the ANPD: you have the right to file a complaint with the National Data Protection Authority (ANPD) if you believe your rights are not being respected.

11.Data of Minors

The 119win is a platform intended exclusively for individuals aged 18 years of age or older. We do not knowingly collect, process, or store personal data from users under 18.

If you believe a user under 18 has created an account at 119win or provided personal data to the platform, contact us immediately at privacidade@119win.best. Upon receiving such a report, the 119win will take the necessary steps to verify the situation, close the account, and delete the related data.

Age verification is a mandatory part of the registration process. All users are required to declare that they are 18 years of age or older, and the platform may request supporting documentation at any time during the KYC process.

12.Communications and Marketing

The 119win may send communications about promotions, bonuses, platform updates, and information about Brasileirão, Copa do Brasil, Libertadores, progressive jackpots, and other content relevant to bettors, provided you consented to receive them at registration or later through your account settings.

Communications related to your account — deposit confirmations, processed withdrawal notices, security alerts, KYC verification updates, and support responses — are considered operational communications and are sent regardless of your marketing preferences, as they are necessary for the performance of your platform usage agreement.

To unsubscribe from marketing communications from 119win, you may:

• Clicking the unsubscribe link in any marketing email you receive;
• Update your communication preferences in your account settings panel;
• Submit a request by email to privacidade@119win.best.

Opting out of marketing communications does not affect the operation of your account or the receipt of essential operational communications.

13.Security Incidents

In the event of a security incident that may pose a significant risk or harm to data subjects — such as unauthorized access, leakage, destruction, or improper alteration of personal data — the 119win will take the following measures:

• Contain the incident and mitigate its effects as quickly as possible;
• Assess the impact on affected data subjects;
• Notify the National Data Protection Authority (ANPD) within the timeframe required by the LGPD;
• Notify affected users in a clear and transparent manner about the nature of the incident, the data involved, and the steps taken to address the situation;
• Log the incident, the identified causes, and the actions taken, as required by the LGPD.

To report any suspected security incident related to your account at 119win, please get in touch immediately via the platform's live chat or by emailing segurança@119win.best.

14.Changes to This Privacy Policy

The 119win may update this Privacy Policy periodically to reflect changes in data processing practices, applicable legislation, or the services offered. The date of the most recent update is always shown at the top of this document.

When significant changes are made that affect your rights as a data subject, the 119win will notify users by email at least 7 days before the new terms take effect. For minor changes, notification may be given solely through a notice on the platform.

Continued use of the platform after the effective date of any changes constitutes acceptance of the updated Privacy Policy. If you disagree with the changes, you may close your account and request deletion of your data before the effective date.

15.Contact, DPO, and Privacy Channel

The 119win has appointed a Data Protection Officer (DPO) responsible for overseeing the platform's data protection practices and serving as the communication channel between data subjects and the ANPD.

To exercise your rights as a data subject, clarify questions about this Privacy Policy, submit complaints, or request information about the processing of your personal data, please contact us through the following channels:

• Privacy email: privacidade@119win.best
• General support email: suporte@119win.best
• Live chat: available 24/7 directly on the 119win platform

All requests are responded to within 15 business days. For urgent requests related to security incidents, support is prioritized.