WinWin Privacy Policy

WinWin collects personal information that is needed to provide online services, comply with law, and protect the platform and users.

Types of personal data collected

WinWin may collect and process:

• Identification data: full name, date of birth, nationality, and copies of identification documents when required for verification.
• Contact details: address, mobile number, email address, and preferred language.
• Account data: username, encrypted password, account settings, communication preferences.
• Transaction data: payment method details (for example, masked card numbers, mobile financial service account, bank details), deposits, withdrawals, betting and gaming history.
• Technical data: IP address, device identifiers, browser type, operating system, access time, and log files.
• Responsible gaming data: self-exclusion status, limits, and related communications.

Purposes of collection and processing

Personal data is collected and processed to:

• Create and manage user accounts for the online platform.
• Verify identity and age and help prevent fraud or misuse.
• Process payments, payouts, and transaction records.
• Provide customer support and respond to user requests.
• Improve website functionality, security, and user experience.
• Meet legal, tax, anti-money laundering, and regulatory obligations in Bangladesh and other relevant jurisdictions.

Technical and organisational protection measures

To safeguard information, WinWin uses appropriate technical and organisational measures, including:

• Encryption for data in transit and at rest where reasonable and required.
• Role-based access controls so that only authorised staff can see necessary information.
• Secure data centres and backup procedures.
• Regular monitoring of systems for security incidents.
• Internal policies, staff training, and confidentiality obligations.

Despite these measures, no online system can guarantee absolute protection. WinWin reduces risk by applying industry-recognised standards and continuous monitoring.

User rights over personal information

Subject to applicable law, users in Bangladesh have the right to:

• Request confirmation whether their personal data is held.
• Access information about how their data is used.
• Request correction of inaccurate or incomplete data.
• Request deletion of data where there is no legal or contractual need to retain it.
• Object to certain types of processing, such as direct marketing.
• Withdraw consent where processing is based on consent, without affecting earlier lawful processing.

Requests can be sent using the contact details given in this Policy. WinWin may require identification documents to confirm the requester and protect user privacy.

Compliance with Bangladesh laws

WinWin aims to handle personal data in line with:

• Applicable laws and regulations of Bangladesh, including rules related to information technology, financial services, and anti-money laundering.
• International data protection principles such as lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

Where there is a conflict between this Policy and mandatory local law, the applicable law of Bangladesh will prevail to the extent of the conflict.

Personal data collected by WinWin is used only for lawful purposes and in a manner that remains transparent for the user.

Main purposes of use

WinWin may use personal information to:

• Register and maintain user accounts.
• Process deposits, withdrawals, bonuses, and other transactions.
• Operate casino games and sportsbook services and record betting history.
• Provide support by phone, email, or chat and handle complaints or disputes.
• Communicate service updates, account notices, technical notifications, and policy changes.

Service improvement and analytics

Data related to usage of the website and mobile access may be used to:

• Analyse performance and improve technical stability.
• Understand general user behaviour in aggregated or anonymised form.
• Develop new features and adjust content for local preferences in Bangladesh.

Marketing and communication

Where permitted by law and based on consent or legitimate interest, WinWin may:

• Send promotional messages by SMS, email, app notifications, or on-site messages.
• Offer personalised content or settings based on user activity.

Users may opt out of marketing communications at any time by using the unsubscribe links or updating account preferences. Transactional messages and important service notices may still be sent.

Compliance and risk management

Information may also be processed for:

• Compliance with anti-money laundering and counter-terrorist financing obligations.
• Prevention, detection, and investigation of fraud, misuse, or security incidents.
• Compliance with tax, accounting, and reporting duties.
• Responding to lawful requests from courts, law enforcement, or regulatory bodies.

WinWin does not sell personal information to third parties. Data is shared only as described in this Policy and only when there is a legal basis for doing so.

WinWin recognises the right of each user to access and manage personal data held about them.

How users can access and update data

Users can usually review and edit core account information by logging into their account settings. This may include:

• Contact details such as email, mobile number, and address.
• Account preferences and communication settings.

For additional data access, users can submit a written request to customer support or to the dedicated privacy contact. WinWin may provide a copy of the main categories of personal data, subject to legal limitations and protection of other individuals.

Correction and deletion procedures

If any personal information is inaccurate or incomplete, users may request correction. WinWin may ask for supporting documents, for example updated identification or proof of address, before changing records.

Users may request deletion of personal data where:

• The information is no longer necessary for the stated purposes.
• Consent has been withdrawn and there is no other legal basis for processing.
• Processing was believed to be unlawful.

WinWin may retain certain records despite a deletion request where it is required to:

• Comply with financial, anti-money laundering, tax, or gaming record-keeping obligations.
• Establish, exercise, or defend legal claims.

Consent to security checks and payment processing

By creating an account and using the services, each user:

• Agrees that WinWin may conduct security and verification checks, including identity, age, location, and source-of-funds reviews, using internal tools or external service providers.
• Acknowledges that payment and withdrawal information will be processed by authorised payment providers, banks, and mobile financial service operators according to their own security standards.

These checks are carried out to protect users, prevent fraud, and satisfy legal obligations. Service may be limited or suspended if required data is not provided or verified.

The services provided by WinWin are intended only for adults aged 18 years and above.

• Registration and use of the website for gaming or betting is not permitted for anyone under 18.
• During registration and later checks, users are asked to confirm that they are at least 18 years old and legally allowed to use such services under the laws of Bangladesh.
• WinWin cannot always verify age without identification documents, but it may request proof of age at any time.

If WinWin becomes aware that personal data belongs to a minor:

• The account will be blocked or closed where appropriate.
• Personal information of the minor will be removed or anonymised, unless law requires retention for evidence.

Parents or legal guardians who believe that their child has provided data to WinWin may contact customer support and request review and deletion of such information. Reasonable proof of guardianship may be requested before action is taken.

To operate online services for Bangladesh users, WinWin may need to transfer or store personal data in other countries.

Where data may be processed

Personal information may be processed in:

• Countries where WinWin has servers or technical infrastructure.
• Countries where group companies, partners, payment processors, or service providers are located.

Some of these countries may have data protection laws that differ from those in Bangladesh. In such cases, WinWin takes steps to protect confidentiality and integrity of personal data.

Safeguards for international transfers

When information is transferred abroad, WinWin aims to:

• Share data only with trusted partners under written agreements.
• Impose confidentiality, data protection, and security obligations on recipients.
• Use appropriate technical measures such as encryption and access controls.

User consent to cross-border processing

By using the website, creating an account, or providing personal information, the user:

• Consents to the transfer, storage, and processing of their personal data outside Bangladesh for the purposes described in this Policy.
• Acknowledges that partner entities and service providers are required to handle the information confidentially and use it only for authorised purposes.

This Privacy Policy describes general rules on collection, use, and protection of personal data for the online services of WinWin. Certain legal disclaimers may limit or clarify how these rules apply in specific situations.

• If local law or a binding order from a court or authority requires processing that differs from this Policy, WinWin will follow the applicable legal requirement.
• Nothing in this document creates rights or obligations that go beyond what is required by applicable law or necessary for providing the services.
• In case of conflict between translated versions of this Policy, the version designated as official by WinWin will prevail.

The legal disclaimer takes effect when a user accepts the Privacy Policy. Acceptance may occur through:

• Creating an account or using the website or related applications.
• Checking a box or taking another affirmative step during registration or verification.
• Signing or otherwise acceding to any agreement that refers to this Policy.

By such acceptance, the user acknowledges that they have read, understood, and agreed to the limitations and conditions stated in this document.

Cookies are small text files stored on a device when a user visits a website. WinWin uses cookies and similar technologies to support and improve online services.

Types and purposes of cookies

The following categories of cookies may be used:

• Essential cookies: required for basic functions such as login, security, and navigation.
• Preference cookies: remember language, region, or other settings selected by the user.
• Statistics cookies: collect aggregated data on how users interact with the website so that performance can be measured and improved.
• Behaviour and analytics cookies: help understand general patterns of use and may support responsible gaming measures.
• Personalisation cookies: adjust content and layout based on previous visits and general interests.

These files may collect information such as IP address, device type, browser, pages visited, time spent, and reference links.

Cookie retention period

Cookie data is generally retained for up to 1 year, after which it is deleted or anonymised, unless a shorter or longer period is required for technical, security, or legal reasons.

Cookie control by users

Users can manage cookie settings through:

• Browser settings, where cookies can be blocked, limited, or deleted.
• On-site cookie tools, where available, to adjust preferences.

Blocking some cookies may affect access to certain functions or reduce site performance, but core services will be provided as far as technically possible.

By browsing the website, creating an account, or using any online services provided by WinWin, the user confirms full acceptance of this Privacy Policy.

• Continued use of the platform after any update to this document means that the user agrees to the revised terms.
• If a user does not agree with any part of the Policy, the only option is to stop using the services and, where applicable, request account closure.

WinWin may modify this Policy from time to time to reflect legal changes, technical updates, or service improvements. The version published on the website at the time of use is considered the valid and current version and will prevail over any previous versions.

WinWin may share personal information with selected third parties when this is necessary for lawful and responsible operation of the online platform.

Situations where data may be shared

Personal data may be disclosed to:

• Payment providers, banks, and mobile financial services to process deposits and withdrawals.
• Identity verification, risk, and anti-fraud service providers.
• Technical partners that host servers, provide support, or maintain security.
• Professional advisers such as auditors, legal consultants, and accountants.
• Courts, regulators, or law enforcement agencies when required by law or in relation to legal disputes.

The main categories or names of such partners may be listed on the website or provided on request. Where a third party is not explicitly listed, WinWin will ensure that any sharing is for a specific, lawful purpose and within a limited scope.

Responsibility of third parties

Once personal data is shared, third parties must:

• Use the information only for the agreed purposes.
• Apply appropriate security and confidentiality measures.
• Comply with any legal obligations that apply in their jurisdiction.

By providing personal information and using the services, the user consents to such sharing and understands that third parties handle data under their own privacy rules, in addition to this Policy.

The website of WinWin may contain links or references to third-party websites, applications, or services.

• These external websites operate under their own privacy policies and terms of use.
• WinWin does not control and is not responsible for how such third parties collect, use, or protect personal information.
• Including a link does not mean that WinWin endorses or supervises the content or practices of the external site.

Users are advised to:

• Read the privacy policy and terms of each external website they visit.
• Consider security and reliability before sharing any personal data outside the WinWin environment.

Use of external sites is at the user’s own risk, and any issues related to such sites should be addressed directly to their operators.