Privacy Policy — How jjiwin Handles Your Personal Data

Introduction

jjiwin ("we", "us", "our", "the Platform") operates the website located at jjiwin.cam. We are an English-language online gaming information and entertainment platform targeting users in Pakistan. jjiwin does not operate a gambling service and does not accept deposits, process wagers or hold player funds.

We are committed to protecting the privacy and personal data of all users who access our Platform. This Privacy Policy ("Policy") sets out how jjiwin collects, uses, stores, shares and protects personal data in connection with your use of the Platform. It also explains your rights in relation to the personal data we hold.

This Policy should be read alongside our Terms & Conditions. By accessing or using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please discontinue use of the Platform immediately.

Definitions

• "Personal Data" — any information that identifies or can be used to identify a natural person, directly or indirectly. This includes names, email addresses, IP addresses, device identifiers and usage patterns.
• "Processing" — any operation performed on personal data, including collection, storage, use, transfer, disclosure or deletion.
• "Data Controller" — the party that determines the purposes and means of processing personal data. For the purposes of this Policy, jjiwin acts as the Data Controller.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller under a binding data processing agreement.
• "User" — any individual who accesses or interacts with the jjiwin Platform.
• "Cookies" — small text files placed on a user's device by a website in order to retain session state, personalise content or support analytics functions.
• "Applicable Law" — the body of law applicable to the processing of personal data in the relevant jurisdiction, which may include the Prevention of Electronic Crimes Act 2016 (PECA) and any applicable data protection legislation.

Data Controller Identity

jjiwin (operating at jjiwin.cam) acts as the Data Controller for personal data collected through this Platform. All data processing activities described in this Policy are carried out by or on behalf of jjiwin, unless otherwise stated.

For any queries relating to data controller responsibilities, users may contact us using the contact details provided in Section 16 of this Policy.

Personal Data We Collect

jjiwin collects personal data through two primary channels:

When you voluntarily interact with the Platform — for example by submitting an enquiry via a contact form — we may collect:

• Name (first and/or last name);
• Email address;
• City or region of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar);
• The content of your message or enquiry;
• Any other information you choose to include in your communication.

When you access the Platform, certain technical data is collected automatically, including:

• IP address and approximate geographic location derived therefrom;
• Browser type, version and language settings;
• Device type and operating system;
• Pages visited, time spent on pages and navigation patterns;
• Referral source (the URL or channel through which you arrived at the Platform);
• Cookie identifiers and session data.

Legal Basis for Processing

jjiwin processes personal data on the following legal bases:

Purpose of Data Processing

jjiwin processes personal data for the following clearly defined purposes:

• Platform Operation: To deliver, maintain and improve the jjiwin website, including page personalisation and session management;
• User Enquiry Management: To receive, assess and respond to enquiries submitted by users via contact channels;
• Analytics and Performance: To understand how users navigate the Platform and to improve content relevance, particularly for Pakistani audiences;
• Security and Fraud Prevention: To detect, investigate and prevent fraudulent use, unauthorised access or abuse of the Platform;
• Responsible Gambling Support: To support session-tracking and responsible gambling tools that help users manage their time on gambling-related content;
• Legal Compliance: To meet our obligations under applicable law, including responding to lawful requests from competent authorities.

jjiwin does not use personal data for automated decision-making or profiling that produces legal or similarly significant effects on users.

Data Sharing and Disclosure

7.1 — jjiwin does not sell, rent or license your personal data to any third party for commercial purposes under any circumstances.

7.2 — We may share personal data with the following categories of recipients, strictly on a need-to-know basis:

• Service Providers and Data Processors: Trusted third-party vendors engaged to provide hosting, analytics, security, content delivery or email services on behalf of jjiwin. These parties are bound by confidentiality obligations and data processing agreements;
• Legal and Regulatory Authorities: We may disclose personal data to law enforcement, courts or regulatory bodies where required by law or where we reasonably believe such disclosure is necessary to protect the rights of jjiwin or any other party;
• Business Successors: In the event of a merger, acquisition or sale of all or part of jjiwin's assets, personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

7.3 — jjiwin does not share personal data with third-party gambling operators. Any such operators referenced on the Platform are entirely independent, and users engage with them at their own risk.

Cookies and Tracking Technologies

8.1 — jjiwin uses cookies and similar tracking technologies to enhance your experience on the Platform. A cookie is a small data file placed on your device when you visit a website.

8.2 — We use the following categories of cookies:

8.3 — You may control and manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality and performance of the Platform. Please refer to your browser's help documentation for guidance on managing cookies.

Data Retention

9.1 — jjiwin retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal obligations.

9.2 — The following retention principles apply:

• Enquiry and contact data is retained for a period sufficient to resolve the enquiry and for a reasonable period thereafter for record-keeping purposes;
• Technical and usage data collected via cookies or analytics tools is typically retained in aggregated or anonymised form for no longer than 24 months;
• Data retained for legal compliance purposes is retained for the duration required by the applicable law or regulatory guidance;
• Upon a valid request for deletion under Section 12, personal data will be erased within a reasonable timeframe, subject to any overriding legal retention obligations.

Data Security

10.1 — jjiwin implements appropriate technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• Encrypted data transmission via HTTPS (TLS);
• Access controls limiting internal data access to authorised personnel on a need-to-know basis;
• Regular security assessments and monitoring of the Platform's infrastructure;
• Data minimisation practices — we collect only data that is necessary for the stated purpose.

10.2 — Notwithstanding these measures, no method of electronic transmission or storage is entirely secure. jjiwin cannot guarantee absolute security of personal data. In the event of a data breach that is likely to result in risk to users, we will take appropriate steps in accordance with applicable law.

International Data Transfers

11.1 — The Platform and its supporting infrastructure may be hosted and operated from jurisdictions outside Pakistan. As a result, personal data may be transferred to and processed in countries other than your country of residence.

11.2 — Where personal data is transferred internationally, jjiwin takes steps to ensure that appropriate safeguards are in place — including contractual protections with receiving parties — to ensure that your data is treated with a standard of protection equivalent to that described in this Policy.

11.3 — By using the Platform, you acknowledge that your personal data may be processed in jurisdictions outside Pakistan.

Your Data Rights

Subject to applicable law, you may have the following rights in relation to personal data that jjiwin holds about you:

• Right of Access: The right to request a copy of the personal data jjiwin holds about you, together with information about how it is processed;
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data in certain circumstances, subject to overriding legal obligations;
• Right to Restriction: The right to request that we restrict the processing of your data in certain circumstances;
• Right to Data Portability: The right to receive a structured, machine-readable copy of your personal data where processing is based on consent or contractual necessity;
• Right to Object: The right to object to processing based on legitimate interests, including for direct marketing purposes;
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact us using the details in Section 16. We will respond to all valid requests within a reasonable timeframe and in compliance with applicable law. We may require verification of identity before processing any data rights request.

Children's Privacy

13.1 — The Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the operator's license jurisdiction. jjiwin does not knowingly collect personal data from individuals under this age.

13.2 — If we become aware that personal data has been collected from a person below the minimum eligible age, we will take prompt steps to delete that data. If you believe a minor has accessed the Platform or submitted personal data, please contact us immediately using the details in Section 16.

Third-Party Services and External References

14.1 — The Platform may contain editorial references to third-party services, including payment methods (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) and online gaming operators. These references are contextual and educational only. jjiwin is not responsible for the privacy practices of any third party.

14.2 — If you choose to engage with any third-party service referenced on or accessed via the Platform, that third party's own privacy policy and terms of use will govern the collection and processing of your data by them. jjiwin strongly encourages you to review the privacy policies of any third-party platform before providing personal information.

14.3 — jjiwin uses third-party analytics and infrastructure tools to operate the Platform. Where such tools involve processing of personal data, jjiwin ensures that appropriate data processing agreements are in place.

Amendments to This Policy

15.1 — jjiwin reserves the right to update or amend this Privacy Policy at any time. The revised Policy will be published on this page with an updated "Last Updated" date. We will not provide individual notification of changes.

15.2 — Your continued use of the Platform following the publication of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically to stay informed of how we protect your data.

15.3 — If any provision of this Policy is found to be invalid or unenforceable under applicable law, the remaining provisions shall continue in full force and effect.

Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the personal data jjiwin holds about you, please contact our support team using the details below. All privacy-related correspondence should be clearly marked as a data rights enquiry.

We will acknowledge receipt of your request promptly and endeavour to respond fully within a reasonable timeframe consistent with applicable law.