WinWin Privacy Policy

WinWin collects personal information that is necessary to provide lawful online gaming and betting services for users in Bangladesh.

Types of personal data collected

WinWin may collect the following categories of personal data:

• Identification data: full name, date of birth, nationality, identity document details (such as NID, passport, driving licence), gender.
• Contact data: residential address, email address, mobile number, communication preferences.
• Account data: username, encrypted password, security questions, account settings.
• Transaction data: payment method details (for example, masked card data, mobile financial service account, bank details), deposits, withdrawals, betting history, game activity.
• Technical data: IP address, device type, browser data, operating system, access time, language, approximate location from IP.
• Compliance and security data: verification records (KYC), copies of documents provided for age, identity, and address confirmation, records relating to responsible gambling, fraud checks, and dispute records.

Purposes of collection and processing

Personal data is collected and processed to:

• Create and manage user accounts and provide access to online services.
• Confirm identity and age, and comply with legal and regulatory requirements.
• Process payments, manage balances, and handle withdrawals and deposits.
• Maintain security of the platform, detect and prevent fraud, abuse, money laundering, and other prohibited activities.
• Meet responsible gaming obligations, including monitoring patterns that may show problematic behaviour.
• Provide customer support and respond to complaints or queries.
• Improve website performance, user experience, and service quality using technical and analytical data.

The legal bases for processing include user consent, performance of a contract for services, compliance with legal obligations, and legitimate interests such as prevention of fraud and safeguarding of the platform.

Technical and organisational protection measures

To protect user data from unauthorised access, alteration, disclosure, or loss, WinWin applies:

• Encryption of data in transit using industry-standard protocols (for example, TLS/SSL).
• Secure storage of sensitive data, including hashing and salting of passwords.
• Access controls based on roles, so only authorised personnel can access necessary information.
• Regular security monitoring, logging, and risk assessment of systems.
• Procedures for responding to suspected data breaches and security incidents.
• Staff training on confidentiality, data protection, and responsible handling of user information.

No method of electronic storage or transmission over the internet is fully risk free, but WinWin aims to apply reasonable and proportionate safeguards in line with current technical standards.

User rights regarding personal data

Under applicable data protection principles, users have the right to:

• Request confirmation whether personal data about them is held.
• Access their personal information and receive a copy in a commonly used format, subject to identity verification.
• Request correction of inaccurate or incomplete data.
• Request deletion of personal data, where allowed by law and where data is not required for legal or contractual reasons.
• Object to certain types of processing, including some forms of profiling, when justified by their situation.
• Request restriction of processing in specific circumstances.

Requests for these rights may be made through the contact details provided in the support section of the website. WinWin may need to request additional information to verify identity before responding.

Compliance with Bangladesh laws

WinWin aims to handle personal data in line with:

• Applicable laws and regulations of Bangladesh related to information technology, telecommunications, anti-money laundering, and electronic transactions.
• General data protection principles based on international standards such as transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

Where international standards such as the GDPR are used as guidance, WinWin adapts them to the context of services offered to users in Bangladesh.

Personal data collected from users is used only for specified, legitimate purposes and is not sold or misused.

Main uses of personal data

WinWin may use personal and account information to:

• Register, verify, and manage user profiles for online casino and sportsbook services.
• Process financial transactions, including deposits, withdrawals, bonuses, and refunds.
• Maintain betting records, game history, and account balances.
• Provide technical support and respond to questions or complaints.
• Communicate important service messages, such as changes to terms, policy updates, security alerts, or service interruptions.

Service improvement and analytics

Technical and behavioural data may be used to:

• Analyse website performance and usage trends.
• Detect bugs, usability issues, and technical problems.
• Improve layout, navigation, and design of online services.
• Evaluate the effectiveness and fairness of games and betting markets.

Where possible, this analysis is done on aggregated or pseudonymised information to reduce direct identification of users.

Responsible gaming, risk, and compliance

WinWin may process personal and transactional data to:

• Monitor gameplay and betting behaviour to identify risky patterns.
• Apply limits, temporary blocks, or other responsible gaming tools chosen or requested by users.
• Conduct security checks, identity verification, and anti-fraud controls.
• Comply with anti-money laundering, counter-terrorism financing, and other legal obligations.
• Respond to regulatory enquiries, lawful orders, and dispute resolution processes.

Marketing and communication

Subject to consent and applicable law, contact information may be used to:

• Send information about product updates, features, or relevant services.
• Provide notifications tailored to user preferences.

Users can manage marketing preferences through account settings or by following instructions provided in communications. Operational and legally required messages may still be sent even where marketing preferences are limited, as they relate to account and security.

Lawful and transparent processing

All collection and processing of personal information is:

• Based on a defined legal ground such as consent, contractual necessity, or legal obligation.
• Limited to what is necessary for the stated purposes.
• Conducted in a transparent manner, described in this document and related notices on the website.

WinWin does not carry out automated decision making that produces legal or similarly significant effects for users without providing information about the logic used and the potential consequences, except where required by law for risk and compliance checks.

Users have control over much of their personal data and may manage many details directly through their online account.

How users can access data

Users may access their main account information at any time by logging in to their profile. From the account area, they can usually view:

• Basic registration details.
• Contact information.
• Account settings and preferences.
• Balance, transaction history, and recent activity.

Users who require access to broader information, such as full data records, may submit a written request through the contact channels listed on the website. WinWin may ask for documents to verify identity before sharing any sensitive data.

Updating and correcting personal data

Users are expected to keep their personal information accurate and up to date. In most cases, basic details such as email, phone number, or address can be updated directly in account settings.

Where a change affects verification status (for example, change of name, address, or identity document), WinWin may request supporting documents before updating records. If any stored data is found to be incorrect or incomplete, users can request correction by contacting support.

Deletion and retention of data

Users may request deletion of their personal data, subject to legal and regulatory obligations that may require retention for a defined period. WinWin may retain certain information where necessary to:

• Comply with anti-money laundering and accounting rules.
• Resolve disputes or enforce agreements.
• Prevent fraud or misuse of services.

Once the relevant retention periods expire, data is either securely deleted or anonymised so it can no longer be linked to an identified user.

Security checks and payment data processing

By creating an account and using the services, users consent to:

• Security and risk checks carried out on their account and transactions.
• Verification of identity, age, and payment methods using trusted third parties.
• Processing of payment data by licensed payment providers, banks, and mobile financial service operators.

These providers process card, bank, or wallet information to complete deposits, withdrawals, and related financial operations. Only the minimum payment data necessary for these purposes is shared, and providers are expected to apply appropriate security standards.

The services offered by this website are intended only for individuals who are at least 18 years old and legally allowed to participate in online betting and gaming according to applicable laws.

Age restrictions

• Registration and use of services by persons under 18 are strictly prohibited.
• During account creation and verification, users must confirm that they are at least 18 years old.

Limitations on age verification

The operator cannot always verify the age of every visitor to the website without receiving supporting documents. For this reason, additional checks may be requested where there is any concern about age or identity. If a user does not provide requested proof of age, access to services may be restricted or closed.

Handling of minors’ data

If evidence is received that a registered user is under 18:

• The account will be suspended and reviewed.
• Any personal data collected will be handled in line with legal obligations.

A parent or legal guardian who believes that a minor has provided personal information may contact support and request review. After confirming the relationship and age, WinWin will:

• Close any account held by the minor.
• Arrange deletion or anonymisation of the child’s personal data, except where retention is required to comply with legal or regulatory duties.

To operate online services and provide secure transactions, it may be necessary to transfer and process personal information outside Bangladesh.

Where data may be processed

Personal data may be stored or processed in:

• Countries where hosting servers, data centres, or cloud services used by the operator are located.
• Jurisdictions where payment processors, banks, mobile financial service providers, game suppliers, or technical support partners operate.

These locations may have different data protection rules from those in Bangladesh, but WinWin aims to engage partners that apply appropriate security and confidentiality standards.

Basis for international transfers

By using the website, creating an account, or submitting personal data, users consent to the transfer, storage, and processing of their information in these other countries for the purposes described in this Privacy Policy.

Where possible, contractual protections and recognised safeguards are put in place to help ensure that:

• Personal data is handled only for authorised purposes.
• Confidentiality is maintained by all partners and service providers.
• Reasonable technical and organisational measures are in place to protect information.

Any such partners are required to process personal data in line with instructions and not to use it for their own independent purposes unrelated to the services.

This Privacy Policy aims to describe how personal data is collected, used, and protected, but it does not limit any rights or obligations arising under applicable law.

Scope and effect of this document

• The policy sets out general rules for handling user information in connection with online casino and sportsbook services.
• Where there is any difference between this document and mandatory legal rules, the applicable law will prevail.
• Nothing in this document creates rights that go beyond what is required by law or what is agreed in other binding agreements such as the Terms and Conditions.

Acceptance and application of the policy

This Privacy Policy applies from the moment the user:

• Creates an account, signs up, or otherwise registers on the website.
• Uses the services, accesses content, or submits personal information.
• Indicates acceptance through any technical means provided on the website, such as clicking to agree to the policy or continuing to use the website after being informed of updates.

By accepting this Privacy Policy, users acknowledge that data processing described in this document may be necessary to provide services, manage accounts, ensure security, and comply with legal and regulatory requirements.

Cookies are small text files placed on a device when a user visits online services. They store limited information and help recognise the browser on later visits.

How cookies are used

The website may use cookies and similar technologies to:

• Collect anonymous statistics about visits, such as pages viewed and time spent.
• Analyse user behaviour to understand how services are accessed and navigated.
• Remember user preferences, such as language, region, or display settings.
• Improve website performance, security, and reliability.

Cookies may be set by the website itself (first-party cookies) or by trusted analytics and service providers (third-party cookies).

Duration and retention

• Cookies used for analytics and functional purposes are generally stored for up to 1 year, after which they expire or are removed.
• Some session cookies are deleted when the browser is closed.

Managing cookies

Users can manage or delete cookies through their browser settings. It is possible to:

• Block cookies entirely.
• Delete existing cookies from the device.

If cookies are disabled, some parts of the website may not function as intended, and certain preferences may not be saved.

By accessing or using the website or services, users confirm that they have read and agreed to the terms of this Privacy Policy.

• Use of the platform, creation of an account, or submission of any personal information is considered full acceptance of this document.
• Users who do not agree with the Privacy Policy should not register, submit personal data, or continue using the services.

WinWin may update this Privacy Policy from time to time. In case of changes, a revised version will be made available on the website, with an updated date. The current published version of the Privacy Policy always prevails over any earlier version for ongoing and future processing of personal data.

In certain situations, personal data may be shared with external parties that assist in providing and supporting services, or where lawfully required.

Situations where data may be shared

Personal information may be disclosed to:

• Payment service providers, banks, and mobile financial service operators for processing deposits, withdrawals, and related financial operations.
• Game and betting providers, technology partners, and hosting providers that support the operation of the online platform.
• Verification, fraud prevention, and risk management partners for identity checks, anti-money laundering controls, and security monitoring.
• Professional advisers such as lawyers, auditors, and consultants where necessary to protect legal interests.
• Public authorities, courts, law enforcement agencies, or regulators where required by applicable law or to respond to lawful requests and disputes.

Where practicable, the categories or names of such parties are listed on the website or provided during the relevant process. If they are not listed, users may request additional information about the nature of the third party and the purpose of processing, subject to legal limitations.

User consent and third-party responsibilities

By providing personal data and using the services, users consent to:

• Sharing of information with such third parties for the purposes described in this Privacy Policy.
• Processing of personal data by these parties acting as independent controllers or processors, depending on the specific role.

These third parties are expected to protect the confidentiality and security of personal data and to use it only for the agreed purposes. Their own privacy policies and legal obligations may also apply, and users are encouraged to review them where relevant.

The website may contain links or references to external websites or services operated by third parties.

• These external websites have their own privacy policies, terms, and data protection practices.
• WinWin does not control how third parties collect, use, or protect personal information on their own platforms.

When a user follows a link to another website, any data provided there is subject to that website’s policy, not this Privacy Policy. Users are advised to:

• Read the privacy and cookie policies of any external website before providing personal information.
• Exercise caution when sharing sensitive data, such as financial or identity details, on third-party platforms.

WinWin is not responsible for any loss, misuse of data, or other consequences arising from the use of third-party websites that are accessed through links on this website.