jiwin Privacy Policy — How We Protect Your Personal Data

This Privacy Policy ("Policy") describes how jiwin collects, uses, stores, shares, and protects personal data provided by or generated through the use of the jiwin online gaming Platform, accessible at jiwin.bio. This Policy applies to all registered Players, visitors, and individuals who interact with jiwin in any capacity, including Pakistani players accessing the Platform via mobile or desktop.

By registering a jiwin Account, depositing funds, or otherwise using the jiwin Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the jiwin Platform immediately.

This Policy should be read in conjunction with jiwin's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference and together form the complete agreement governing your use of jiwin.

For the purposes of this Privacy Policy, jiwin acts as the data controller in respect of all personal data collected through the jiwin Platform. jiwin is an internationally licensed online gaming operator. All data processing activities are conducted in accordance with the conditions of jiwin's international gaming licence and applicable data protection standards.

Where jiwin engages third-party payment processors, game providers, or KYC service providers to assist in delivering Platform services, those third parties operate as data processors acting on jiwin's documented instructions. jiwin remains responsible for ensuring that all data processors meet the required data protection standards.

jiwin collects personal data in the following categories, depending on how you interact with the Platform:

jiwin does not collect sensitive personal data (such as racial or ethnic origin, religious beliefs, or biometric data) except where specifically required by KYC regulatory obligations under our international gaming licence. We do not collect data about minors — the jiwin Platform is strictly for players aged 21 and above.

jiwin uses the personal data it collects for the following specific purposes:

• Account Management: Creating and maintaining your jiwin Account, verifying your identity and age (21+ requirement), processing login authentication, and managing Account security including two-factor authentication.
• Payment Processing: Facilitating deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT (TRC-20). This requires sharing relevant financial data with our licensed payment processing partners.
• KYC & AML Compliance: Conducting mandatory Know Your Customer verification and ongoing Anti-Money Laundering transaction monitoring as required by jiwin's international gaming licence conditions.
• Service Delivery: Providing access to casino games, PSL cricket betting markets, slot games, fishing titles, live dealer tables, and all other jiwin Platform features.
• Responsible Gaming: Monitoring gaming behaviour patterns to identify potential problem gambling indicators, enforcing deposit limits and self-exclusion requests, and ensuring the 21+ age restriction is upheld.
• Promotions & Bonuses: Administering welcome bonuses, reload offers, and other promotions for which you are eligible, including verifying wagering requirement completion.
• Customer Support: Responding to queries, complaints, and responsible gaming requests submitted through live chat or support email.
• Fraud Prevention & Security: Detecting and investigating suspicious activity, multi-accounting, bonus abuse, and financial fraud on the Platform.
• Platform Improvement: Analysing aggregated usage data to improve Platform performance, game selection, and the overall Pakistani player experience.
• Legal Compliance: Meeting jiwin's obligations under its international gaming licence, including reporting requirements to the licence-issuing authority and cooperation with lawful regulatory enquiries.

jiwin processes your personal data on the following legal bases:

• Contractual Necessity: The majority of jiwin's data processing activities — including Account creation, payment processing, KYC verification, and game delivery — are necessary to perform the contract between you and jiwin as set out in the Terms & Conditions. Without this processing, jiwin cannot provide its gaming services to you.
• Legal Obligation: Certain processing activities are required to comply with jiwin's obligations under its international gaming licence, including KYC identity verification, AML transaction monitoring, age verification (21+), and responsible gaming intervention protocols. This data cannot be withheld by you without jiwin being obliged to restrict or close your Account.
• Legitimate Interests: jiwin processes technical and usage data for fraud prevention, Platform security, and service improvement on the basis of its legitimate interests as an online gaming operator, provided those interests do not override your fundamental privacy rights.
• Consent: Where jiwin processes your data for marketing communications or non-essential cookies, it does so on the basis of your freely given, specific, and informed consent. You have the right to withdraw this consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

jiwin does not sell, rent, or trade your personal data to any third party for commercial purposes. jiwin shares your personal data only in the following limited circumstances, and only to the minimum extent necessary:

• Payment Processors: jiwin shares relevant financial data with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT network operators solely to process your deposit and withdrawal transactions. These processors are bound by their own data protection obligations.
• KYC / Identity Verification Providers: jiwin uses licensed third-party KYC service providers to verify the identity and age of Pakistani players as required under its international gaming licence. CNIC data and identity documents are processed by these providers under strict confidentiality obligations.
• Game Content Providers: jiwin's game library is supplied by licensed third-party providers. Where a game is delivered via a provider's live streaming infrastructure (e.g. live dealer tables), limited session data may be processed by the provider to deliver the game experience.
• Regulatory & Licensing Authorities: jiwin is obligated to share data with its licence-issuing authority and, where lawfully required, with financial intelligence units or law enforcement agencies in connection with AML investigations or court orders.
• Fraud Prevention Networks: jiwin participates in industry-standard responsible gaming and fraud prevention information-sharing initiatives. Anonymised or pseudonymised data may be shared with these networks to identify multi-accounting, bonus abuse, and financial crime patterns.
• Business Transfers: In the event of a corporate restructure, merger, or acquisition involving jiwin's operating entity, your personal data may be transferred to the successor entity. You will be notified of any such transfer and given the opportunity to close your Account if you do not wish your data to be transferred.

As an internationally licensed gaming platform, jiwin's data processing infrastructure may be hosted in data centres located outside of Pakistan. Where personal data is transferred internationally, jiwin ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy.

These safeguards include:

• Contractual data protection clauses incorporated into all agreements with international data processors and sub-processors, requiring them to handle jiwin player data in accordance with jiwin's Privacy Policy standards.
• Technical security controls including end-to-end encryption of data in transit (TLS 1.3) and at rest (AES-256), ensuring that data transferred internationally cannot be accessed by unauthorised parties during transmission.
• Limiting international data transfers to those strictly necessary for the operational, KYC, and compliance activities described in this Policy — no bulk data transfers are made to overseas parties for commercial purposes.

jiwin retains your personal data for only as long as is necessary for the purposes for which it was collected, subject to the following minimum retention obligations arising from jiwin's international gaming licence:

• Account Data (Identity & Contact): Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in accordance with AML record-keeping requirements.
• Financial Transaction Records: All deposit, withdrawal, and wager records are retained for a minimum of five (5) years from the date of the transaction, as required by anti-money-laundering regulations applicable to jiwin's licence.
• KYC Documents: CNIC copies, proof of address, and source-of-funds documentation are retained for five (5) years from the date of submission or Account closure, whichever is later.
• Communications Data (Live Chat / Email): Support communications are retained for two (2) years from the date of the interaction, unless the communication relates to a formal complaint or investigation, in which case it is retained for five (5) years.
• Technical & Usage Data: Log files and session data are retained for thirteen (13) months from the date of collection, after which they are either deleted or anonymised for analytical purposes.
• Marketing Consent Records: Where you have opted in to marketing communications, records of your consent and any subsequent opt-out requests are retained for the duration of your Account plus two (2) years.

Upon the expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard data destruction procedures. Where data has been anonymised, the resulting anonymised dataset is no longer personal data and may be retained indefinitely for analytical purposes.

jiwin uses cookies and similar tracking technologies on the jiwin Platform for the purposes described in this section. A cookie is a small text file placed on your device when you visit a website. Cookies allow websites to recognise your device, remember your preferences, and collect basic usage data.

jiwin uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the operation of the jiwin Platform. They enable core functions such as session management, login authentication, and security features. These cookies cannot be disabled as they are required for the Platform to function. No personal data beyond your session identifier is stored in strictly necessary cookies.
• Performance & Analytics Cookies: jiwin uses analytics cookies to collect aggregated, anonymised data about how Pakistani players use the Platform — such as which pages are most visited, how long sessions last, and which game categories are most popular. This data is used solely to improve Platform performance and the player experience. It is not shared with advertisers.
• Functional Cookies: These cookies remember your preferences — such as your language setting, preferred payment method display, and responsible gaming reminder settings — so you do not need to reset them on each visit.
• Marketing Cookies: jiwin does not deploy third-party advertising cookies or permit external advertisers to place tracking cookies on the jiwin Platform. If jiwin introduces any first-party promotional cookies in the future, your explicit consent will be sought before they are activated.

As a jiwin player, you have the following rights in respect of your personal data. jiwin is committed to honouring these rights promptly and without unnecessary delay:

• Right of Access: You have the right to request a copy of all personal data jiwin holds about you. jiwin will provide this within 30 calendar days of receiving a verified request.
• Right to Rectification: If any personal data jiwin holds about you is inaccurate or incomplete, you have the right to request correction. You can update basic contact details directly through your jiwin Account settings.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data. jiwin will comply where there is no overriding legal or regulatory obligation to retain the data. Note that transaction records and KYC documents must be retained for the periods described in Section 8 above.
• Right to Restriction of Processing: You may request that jiwin restricts its processing of your data in certain circumstances — for example, if you contest the accuracy of the data or object to its processing while jiwin considers your objection.
• Right to Data Portability: Where jiwin processes your data by automated means on the basis of your consent or contractual necessity, you may request that jiwin provide your data in a structured, machine-readable format.
• Right to Object: You have the right to object to jiwin's processing of your data where that processing is based on legitimate interests. jiwin will cease such processing unless it can demonstrate compelling legitimate grounds that override your rights.
• Right to Withdraw Consent: Where jiwin processes your data on the basis of your consent (e.g. marketing communications or non-essential cookies), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to the withdrawal.

To exercise any of these rights, please contact the jiwin Data Protection team via 24/7 live chat on the Platform or by email at [email protected]. jiwin may request proof of identity before processing a data rights request to ensure that personal data is not disclosed to an unauthorised party.

jiwin implements technical and organisational security measures appropriate to the risk level of its data processing activities. These measures are reviewed and updated regularly in line with evolving cybersecurity standards. Key security controls in place on the jiwin Platform include:

• Transport Layer Security (TLS 1.3): All data transmitted between your device and jiwin's servers — including login credentials, payment data, and KYC documents — is encrypted using TLS 1.3, the current industry gold standard for secure web communications.
• AES-256 Encryption at Rest: Personal data and financial records stored on jiwin's servers are encrypted at rest using AES-256, making them unreadable to any party without the corresponding decryption key.
• Two-Factor Authentication (2FA): jiwin offers optional 2FA for all player Accounts, adding a second verification layer at login. jiwin strongly recommends that all Pakistani players enable 2FA to protect their Accounts.
• Access Controls: Access to jiwin's internal systems and player data is restricted on a strict need-to-know basis. jiwin staff are granted the minimum level of data access necessary to perform their designated functions.
• Penetration Testing: jiwin's Platform infrastructure undergoes regular third-party penetration testing and security audits to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: jiwin maintains a documented data breach response procedure. In the event of a breach that is likely to affect your rights and freedoms, jiwin will notify affected players without undue delay and report the breach to the relevant regulatory authority as required under jiwin's international licence conditions.

The jiwin Platform is strictly intended for individuals aged 21 years or older. jiwin does not knowingly collect personal data from any individual under the age of 21. Age verification is a mandatory step in the jiwin KYC process, and Accounts belonging to individuals found to be under 21 years of age will be closed immediately with all funds forfeited in accordance with jiwin's Terms & Conditions.

If you are a parent or guardian and believe that a person under the age of 21 has registered an Account with jiwin or otherwise provided personal data to jiwin, please contact jiwin support immediately via live chat or at [email protected]. jiwin will take immediate steps to verify the situation and, where confirmed, delete all data associated with the minor's Account.

The jiwin Platform may, from time to time, contain references to or links from third-party services — such as payment provider portals (JazzCash, EasyPaisa) or game provider interfaces. This Privacy Policy applies solely to the jiwin Platform and does not extend to any third-party websites, applications, or services.

jiwin is not responsible for the privacy practices of any third-party service. When you navigate to a third-party platform — for example, the JazzCash payment portal to complete a deposit — you are subject to that platform's own privacy policy and terms. jiwin strongly recommends that you review the privacy policies of any third-party services you interact with in connection with your jiwin Account.

jiwin reserves the right to update this Privacy Policy at any time to reflect changes in its data processing activities, applicable law, or international gaming licence conditions. The "Last Updated" date at the top of this page will be revised whenever a material change is made to the Policy.

Where changes are material — for example, changes to the categories of data collected, the purposes for which it is used, or the third parties with whom it is shared — jiwin will notify registered Pakistani players via a prominent notification on the Platform or by email to the address registered on their Account, giving at least seven (7) calendar days' notice before the revised Policy takes effect.

Continued use of the jiwin Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must cease use of the Platform and may request Account closure in accordance with Section 12 of the jiwin Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or jiwin's handling of your personal data, please contact the jiwin Data Protection team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week on the jiwin Platform. This is the fastest route for urgent data protection matters.
• Support Email: [email protected] — please note this is displayed as plain text contact information only and is not a clickable link.
• Languages: jiwin's Data Protection team can assist Pakistani players in both English and Urdu.