jwin Privacy
Policy

1 Data Controller Information

For the purposes of this Privacy Policy, the data controller responsible for the collection and processing of your personal information is jwin, the operator of the online betting and gaming platform accessible at https://jwin.club. As data controller, jwin determines the purposes and means by which your personal data is processed, and is accountable for ensuring that such processing is lawful, fair, and transparent.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way jwin handles your personal data, you may contact the jwin privacy team at any time using the details set out in Section 11 of this document. jwin is committed to responding to all privacy enquiries promptly and will acknowledge receipt of your communication within 5 business days.

2 Personal Data We Collect

jwin collects personal data from you in three principal ways: information you provide directly during account registration and use; information collected automatically when you access the platform; and information received from third parties such as payment processors in the course of transaction processing.

The following table summarises the categories of personal data jwin collects and the context in which each category is gathered:

jwin collects only the minimum personal data required to operate your account safely, process your transactions, comply with applicable legal obligations, and provide you with a high-quality gaming experience. We do not collect sensitive personal data such as medical records, ethnic origin, or political opinions.

Where jwin requests identity verification documents — such as a National Identity Card (NID), passport, or driving licence — this is a standard Know Your Customer (KYC) procedure necessary to confirm your age, identity, and place of residence. Providing accurate verification documents is a condition of continued account access and withdrawal eligibility.

3 How We Use Your Data

jwin processes your personal data only for defined, legitimate purposes. We do not use your data in ways that are incompatible with the purpose for which it was originally collected. The following list sets out the specific purposes for which jwin processes your data, together with the legal basis for each:

• Account creation and management: To register your account, verify your identity, maintain your player profile, and facilitate your access to all jwin products and services. Legal basis: performance of a contract.
• Transaction processing: To process deposits, withdrawals, and any related payment verification via bKash, Nagad, Rocket, Upay, Visa, and Mastercard. Legal basis: performance of a contract.
• Customer support: To respond to your queries, complaints, and account-related requests via email and live chat. Legal basis: performance of a contract; legitimate interest.
• Legal compliance: To comply with anti-money-laundering (AML) obligations, age verification requirements, fraud prevention duties, and any applicable regulatory requirements. Legal basis: legal obligation.
• Security and fraud prevention: To monitor account activity for suspicious behaviour, detect unauthorised access, investigate potential fraud, and protect the integrity of the jwin platform. Legal basis: legitimate interest.
• Platform improvement: To analyse usage patterns, identify technical issues, and improve the overall performance and usability of the jwin website and apps. Legal basis: legitimate interest.
• Responsible gaming: To identify signs of problem gambling behaviour, apply player-requested deposit limits or self-exclusion orders, and contact players proactively where there is evidence of at-risk activity. Legal basis: legal obligation; legitimate interest.
• Marketing communications: To send you promotional offers, bonus notifications, and updates about new games or features — but only where you have given your explicit consent at the time of registration or subsequently through your account settings. Legal basis: consent. You may withdraw consent at any time.

4 Data Sharing and Disclosure

jwin does not sell, rent, or trade your personal data to third parties for their own commercial purposes under any circumstances. However, jwin may share your personal data with trusted third parties in the following limited circumstances:

• Payment processors: We share necessary financial data with payment service providers — including bKash, Nagad, Rocket, Upay, Visa, and Mastercard — solely for the purpose of processing your deposit and withdrawal transactions. These providers operate under their own privacy policies and data protection obligations.
• Identity verification partners: Where KYC verification is required, we may share identity documents with third-party verification service providers who assist with document authentication. These partners are contractually bound to process your data only for the purpose of verification.
• Game software providers: Information necessary to facilitate game sessions (such as a session token and stake amounts) may be shared with our game content partners, including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and Spribe. These providers do not receive your full identity details.
• Legal and regulatory authorities: jwin may disclose your personal data to law enforcement agencies, financial intelligence units, or regulatory bodies where required by law, by court order, or where jwin has a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or harm to individuals.
• Business continuity: In the event of a merger, acquisition, or sale of all or part of jwin's business, your personal data may be transferred to the successor entity, subject to equivalent privacy protections.

All third parties with whom jwin shares personal data are required to implement appropriate technical and organisational security measures, and to process your data solely for the specific purpose for which it has been shared. jwin does not permit third parties to use your data for their own independent marketing or commercial purposes.

5 Cookies and Tracking Technologies

The jwin website uses cookies and similar tracking technologies to ensure the platform functions correctly, to remember your preferences, and to gather aggregate analytics data that helps us understand how players use the site. A cookie is a small text file placed on your device when you visit a website; it allows the site to recognise your browser on subsequent visits.

jwin uses the following categories of cookies:

jwin does not use advertising or cross-site tracking cookies. The analytics data collected is aggregated and anonymised wherever possible; it is used solely for internal platform improvement purposes and is not shared with advertising networks.

You may control or disable cookies at any time through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in or completing transactions on the jwin platform. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.

6 Data Retention Periods

jwin retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply to the principal categories of data held by jwin:

• Account and identity data: Retained for the duration of your active account relationship with jwin, plus a minimum of 5 years following account closure to comply with anti-money-laundering record-keeping requirements.
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, in accordance with applicable financial record-keeping obligations.
• KYC verification documents: Retained for a minimum of 5 years from the date of verification, and for the full duration of any ongoing investigation or legal proceedings in which the documents are relevant.
• Technical and usage data: Typically retained for 13 months on a rolling basis for analytics purposes, after which it is aggregated or deleted.
• Customer support communications: Retained for 3 years from the date of the last interaction, to allow for follow-up and dispute resolution.
• Marketing consent records: Retained for the duration of your consent, plus 2 years following withdrawal to evidence the consent lifecycle.

Upon expiry of the applicable retention period, your personal data is either securely and permanently deleted from jwin's systems, or anonymised in a manner that makes re-identification impossible. Anonymised data may be retained indefinitely for aggregate statistical analysis.

7 How We Secure Your Data

jwin implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security infrastructure includes:

• Transport Layer Security (TLS 1.3): All data transmitted between your browser or device and the jwin servers is encrypted using TLS 1.3, the current industry standard for secure web communications.
• At-rest encryption: Sensitive personal data stored in jwin's databases — including identity documents and financial details — is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data within jwin's internal systems is strictly limited to authorised personnel who require it to perform their job functions. Role-based access controls (RBAC) are enforced, and all data access events are logged for audit purposes.
• Network security: jwin's infrastructure is protected by firewalls, intrusion detection systems (IDS), and regular penetration testing to identify and remediate vulnerabilities proactively.
• Incident response: jwin maintains a documented data breach response plan. In the event of a security incident that poses a material risk to your personal data, jwin will notify affected players without undue delay.
• Staff training: All jwin personnel who handle personal data receive regular training on data protection obligations and security best practices.

While jwin takes every reasonable precaution to protect your personal data, no internet-based platform can guarantee absolute security. You play an important role in protecting your own data by maintaining the confidentiality of your account password and by reporting any suspected unauthorised access to [email protected] immediately.

8 Your Rights as a Player

As a jwin player whose personal data is processed by jwin, you hold the following rights with respect to your personal information. jwin is committed to facilitating the exercise of these rights promptly and without unnecessary barriers:

• Right of access: You have the right to request a copy of the personal data that jwin holds about you. Upon receipt of a valid access request, jwin will provide you with a summary of your data within 30 days.
• Right to rectification: If any personal data held by jwin about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You may update many details directly via your account profile page.
• Right to erasure ("right to be forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where you believe the data has been processed unlawfully. Please note that jwin may be required to retain certain data for legal compliance reasons even following an erasure request.
• Right to restrict processing: You may request that jwin restricts the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or where you object to processing based on legitimate interest.
• Right to data portability: Where processing is based on your consent or on a contractual basis, you have the right to receive your personal data in a structured, commonly used, machine-readable format, and to request that it be transmitted to another controller where technically feasible.
• Right to object: You have the right to object to the processing of your personal data where jwin relies on legitimate interest as the legal basis. You also have the absolute right to object to direct marketing at any time, including profiling carried out for direct marketing purposes.
• Right to withdraw consent: Where jwin's processing of your personal data is based on your consent (for example, marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of any processing carried out prior to withdrawal.

To exercise any of the rights listed above, please submit your request in writing to [email protected] with the subject line "Data Rights Request — [Your Account Username]". jwin will acknowledge your request within 5 business days and aim to fulfil it within 30 calendar days. In complex cases, this period may be extended by a further 30 days, in which case jwin will notify you of the extension and the reason for it.

9 Third-Party Services

The jwin platform integrates third-party game software from providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers operate their game engines independently and may process limited technical data (such as session identifiers and stake amounts) as part of the game delivery process. jwin does not share your full identity or financial data with game providers.

Payment processing is handled by third-party financial service providers including bKash, Nagad, Rocket, and Upay for local mobile financial services, and Visa and Mastercard for international card payments. When you initiate a deposit or withdrawal, you will interact with these providers' own systems. jwin encourages you to review the privacy policies of your chosen payment provider to understand how they handle your financial data.

jwin is not responsible for the privacy practices or data handling procedures of any third-party service provider. The inclusion of third-party services on the jwin platform does not constitute an endorsement of their privacy policies. Any concerns about third-party data handling should be directed to the relevant provider.

10 Updates to This Privacy Policy

jwin reviews this Privacy Policy regularly and reserves the right to update or amend it at any time to reflect changes in our data processing practices, changes in applicable law, or changes to the services offered on the platform. The "Last Updated" date at the top of this document will be revised each time the policy is amended.

Where changes to this Privacy Policy are material — meaning they significantly affect the way your personal data is collected, used, or shared — jwin will notify registered players via the email address associated with their account before the changes take effect. For minor updates such as clarifications or corrections to existing provisions, the revised policy will simply be published on this page without advance notice.

Your continued use of the jwin platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this policy, you should cease using the platform and contact [email protected] to request account closure and data deletion.

11 Contact Our Privacy Team

If you have any questions, concerns, or requests relating to this Privacy Policy, the way jwin handles your personal data, or the exercise of your data rights, please contact the jwin privacy team using the details below. We are committed to responding to all privacy enquiries professionally and within the timeframes stated in this policy.

• Email: [email protected] (subject line: "Privacy Enquiry")
• Data rights requests: [email protected] (subject line: "Data Rights Request — [Username]")
• Formal complaints: [email protected] (subject line: "Formal Privacy Complaint — [Username]")
• Response time: Acknowledgement within 5 business days; full response within 30 calendar days
• Support hours: 24 hours a day, 7 days a week, in English and Bengali
• Players served: Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Cox's Bazar, and all regions across Bangladesh

jwin treats all privacy complaints seriously. Where a complaint cannot be resolved to your satisfaction through direct correspondence with the jwin privacy team, you retain the right to escalate the matter to the appropriate data protection authority in your jurisdiction.