jiwn Privacy Policy

1. Introduction

This Privacy Policy (hereinafter "Policy" or "this Policy") is published by jiwn (the "Platform", "we", "us" or "our"), accessible at https://jiwn.cam. It describes how jiwn collects, uses, stores, shares and protects personal data relating to individuals (each a "User", "you" or "your") who access or use the Platform, including its sports betting markets, casino games, live dealer tables, instant games and associated services.

This Policy applies to all Users of jiwn regardless of their location. Pakistani users in particular should note that data protection laws in Pakistan, including any applicable provisions under evolving personal data legislation, may govern certain aspects of how their personal information is handled. This Policy is consistent with generally recognised international data protection standards, including principles drawn from applicable frameworks in the jurisdiction in which jiwn operates.

By registering an account on jiwn or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein.

2. Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information that identifies or can reasonably be used to identify a natural person, directly or indirectly, including name, contact details, identification document numbers, IP address and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, restriction, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, jiwn.
• "Data Processor" means any third party that processes Personal Data on behalf of jiwn in accordance with documented instructions.
• "KYC" means Know Your Customer — the identity and address verification process required to comply with anti-money laundering and fraud prevention obligations.
• "Cookies" means small text files placed on a User's device by the Platform for the purposes of session management, analytics and functionality.
• "Special Category Data" means particularly sensitive Personal Data — such as health information — whose processing requires heightened justification under applicable data protection law.

3. Data Controller

jiwn, operating the Platform at https://jiwn.cam, acts as the Data Controller in respect of Personal Data collected through the Platform. As Data Controller, jiwn is responsible for determining the purposes for which your Personal Data is collected and the manner in which it is processed.

jiwn engages third-party Data Processors — including payment service providers, identity verification services and cloud hosting infrastructure — to assist in delivering the Platform's services. These processors act on jiwn's instructions and are bound by contractual data protection obligations. jiwn remains accountable for the processing carried out by those processors on its behalf.

If you have questions or concerns about how jiwn processes your Personal Data, or wish to exercise any of the rights described in Section 12 of this Policy, you may contact us using the details provided in Section 16.

4. Data We Collect

jiwn collects Personal Data in a variety of ways — directly from you when you register and use the Platform, automatically through your interaction with the Platform, and from third-party sources such as identity verification services. The categories of data collected are described below.

jiwn does not knowingly collect Special Category Data (such as health, religious, ethnic or biometric data) except where KYC requirements necessitate document-based identity checks that may incidentally contain such information. In such cases, the data is used solely for verification and not retained beyond what is required.

5. Legal Basis for Processing

jiwn processes your Personal Data on the following legal bases, each of which corresponds to a category of processing activity:

• Contractual Necessity: Processing that is necessary to perform the contract between jiwn and you — specifically, to operate your Account, process bets, execute deposits and withdrawals, and deliver customer support.
• Legal Obligation: Processing required to comply with legal obligations applicable to jiwn, including KYC/AML verification, transaction monitoring, record-keeping obligations and responses to lawful regulatory or law-enforcement requests.
• Legitimate Interests: Processing carried out in jiwn's legitimate interests in maintaining platform security, preventing fraud, improving user experience and enforcing the Terms and Conditions — provided that these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where jiwn processes data for marketing communications (including promotional emails or notifications about bonuses and upcoming events), such processing is based on your opt-in consent. You may withdraw your consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Data

Personal Data collected through the Platform is used for the following purposes:

• Account Operation: To create, manage and authenticate your Account; to process your deposits and withdrawals in PKR; to record your betting and gaming activity; and to communicate Platform-related updates.
• KYC & AML Compliance: To verify your identity and age, to screen against relevant sanctions and watchlists, and to comply with financial crime prevention obligations applicable to the Platform's operating jurisdiction.
• Fraud Prevention & Security: To detect and investigate suspicious activity, unauthorised account access, bonus abuse and other conduct that breaches the Terms and Conditions or constitutes financial crime.
• Customer Support: To manage and respond to support requests, complaints and enquiries submitted via live chat or email at [email protected].
• Responsible Gambling: To administer self-exclusion requests, deposit and loss limits, session time reminders and other responsible gambling tools requested by or applied to your Account.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve Platform performance, identify technical issues and develop new features.
• Marketing Communications: Where you have provided consent, to send you information about jiwn promotions, bonus offers, cricket and PSL-related betting events, and other Platform updates. You may opt out of marketing communications at any time.

7. Data Sharing & Disclosure

jiwn does not sell, rent or otherwise transfer your Personal Data to third parties for commercial purposes. We share data only in the following circumstances:

• Service Providers & Data Processors: We share Personal Data with vetted third-party service providers who assist in delivering the Platform's services, including identity verification vendors, payment processing partners, hosting and cloud infrastructure providers, fraud detection services, and customer support tools. All such processors are contractually bound to process data only in accordance with jiwn's instructions and to maintain appropriate security standards.
• Legal & Regulatory Compliance: We may disclose Personal Data to competent legal, regulatory or law enforcement authorities where we are required to do so by applicable law, court order, or where we believe in good faith that disclosure is necessary to protect the rights, property or safety of jiwn, its users, or the public.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets involving jiwn, Personal Data held on the Platform may be transferred to the relevant acquirer as part of that transaction, subject to continued data protection obligations equivalent to those described in this Policy.
• Aggregate Analytics: jiwn may share aggregated, fully anonymised statistical information about Platform usage — such as total bet volumes or game category popularity — with partners. This information cannot be used to identify any individual user.

8. Cookies & Tracking Technologies

jiwn uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used are described below:

• Strictly Necessary Cookies: Essential to the operation of the Platform. These cookies maintain your session state, handle authentication, and enable core Platform functions. They cannot be disabled without impairing your ability to use the Platform.
• Analytical Cookies: Used to collect anonymised data about how users interact with the Platform — such as pages visited, session duration and navigation paths — to help jiwn understand usage patterns and improve the user experience.
• Functional Cookies: Used to remember your preferences such as language settings, display options and responsible gambling limit configurations.
• Security Cookies: Used as part of fraud detection and session integrity mechanisms to protect your Account from unauthorised access.

You may manage cookie preferences through your browser settings. Disabling certain cookie categories may affect Platform functionality. jiwn does not use cookies to serve third-party advertising.

9. Data Security

jiwn takes the security of your Personal Data seriously and implements appropriate technical and organisational measures to protect it against unauthorised access, loss, alteration or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your browser or device and jiwn's servers.
• Encrypted storage of sensitive Personal Data, including KYC documents and financial records, at rest.
• Role-based access controls ensuring that only authorised personnel can access specific categories of Personal Data.
• Regular internal security reviews and monitoring of access logs for anomalous activity.
• Incident response procedures, including notification protocols, in the event of a confirmed data breach that affects your Personal Data.

While jiwn takes all reasonable steps to secure your Personal Data, no online platform can guarantee absolute security. You play a role in protecting your own data — use a strong, unique password for your jiwn Account, do not share your login credentials, and contact support immediately if you suspect unauthorised access to your Account.

10. Data Retention

jiwn retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, as described in this Policy, and to comply with applicable legal and regulatory obligations. The following general retention principles apply:

• Active Account Data: Personal Data associated with an active Account is retained for the duration of the Account's active status and for a defined period following voluntary Account closure.
• KYC & Transaction Records: Identity verification documents, transaction records and AML-related data are retained for a minimum period in accordance with the financial crime prevention obligations applicable to the Platform's operating jurisdiction. This period may extend to five (5) years or longer where required by law.
• Responsible Gambling Records: Self-exclusion and responsible gambling tool records are retained for a period that ensures continuity of those restrictions, even if a User requests Account re-opening. This is a deliberate safeguard, not an oversight.
• Communication Records: Support correspondence and complaint records are retained for a reasonable period to enable follow-up, dispute resolution and quality monitoring.

When Personal Data is no longer required for the purposes for which it was collected and no legal obligation requires its continued retention, jiwn will securely delete or anonymise that data in accordance with its internal data lifecycle procedures.

11. International Data Transfers

jiwn operates from a jurisdiction outside Pakistan. Your Personal Data may be processed on servers or by Data Processors located in countries other than your country of residence. Where Personal Data is transferred internationally, jiwn applies safeguards appropriate to the transfer, which may include:

• Contractual clauses that impose data protection obligations equivalent to those described in this Policy on all Data Processors receiving Personal Data.
• Transfers only to jurisdictions that maintain an adequate standard of data protection as assessed by applicable international frameworks.
• Internal data transfer agreements where Personal Data moves within affiliated entities of jiwn's corporate group.

If you have questions about the specific safeguards applied to international transfers of your Personal Data, please contact us using the details in Section 16.

12. Your Rights in Relation to Your Data

Subject to applicable data protection law, you have the following rights in relation to your Personal Data held by jiwn:

• Right of Access: You have the right to request confirmation of whether jiwn holds Personal Data about you and, if so, to receive a copy of that data together with information about how it is being used.
• Right to Rectification: You have the right to request that inaccurate or incomplete Personal Data held about you is corrected or completed without undue delay.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you have the right to request the deletion of your Personal Data. This right is not absolute — jiwn may be required to retain data for legal or regulatory compliance reasons even after your Account is closed.
• Right to Restriction of Processing: You have the right, in certain circumstances, to request that jiwn restricts the processing of your Personal Data — for example, while the accuracy of data is contested.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format.
• Right to Object: You have the right to object to the processing of your Personal Data where that processing is based on jiwn's legitimate interests, including in relation to direct marketing communications.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact jiwn's support team at [email protected]. jiwn will respond to all valid requests within a reasonable timeframe consistent with applicable law. Verification of your identity may be required before your request is actioned.

13. Children & Minors

The jiwn Platform is strictly for adults. Access is limited to individuals who are at least 18 years of age, or the higher minimum age required by the applicable operator/license jurisdiction. jiwn does not knowingly collect Personal Data from individuals below the minimum eligible age.

If jiwn becomes aware that Personal Data has been collected from a minor, that Account will be immediately closed, all data associated with the minor will be deleted as swiftly as technically possible (subject to any mandatory legal retention obligations), and any funds held in the Account will be handled in accordance with jiwn's underage account procedures.

If you are a parent or guardian and believe that a minor under your care has created an Account on jiwn, please contact us immediately at [email protected].

14. Third-Party References & Payment Provider Names

The jiwn Platform references payment method names familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — as contextual references only. These references do not constitute:

• An affiliation, partnership, endorsement or approval relationship between jiwn and those institutions.
• A confirmation that those payment methods are currently available or functional for use on the Platform.
• A data-sharing relationship between jiwn and those institutions in respect of your Personal Data in connection with gambling activity.

Users should verify independently which payment methods are available for their Account at the time of use. jiwn accepts no liability for losses arising from reliance on payment method references that are contextual in nature.

15. Changes to This Privacy Policy

jiwn reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, jiwn's data processing practices, or Platform functionality. Material changes will be communicated to active Users via in-platform notification or by email to the registered address on their Account.

The "Last updated" date at the top of this Policy reflects the date on which the most recent revision took effect. We encourage you to review this Policy periodically. Continued use of the Platform after any change takes effect constitutes acceptance of the revised Policy.

Where a proposed amendment would materially reduce your rights in relation to your Personal Data, jiwn will provide notice in advance and, where required by applicable law, seek your renewed consent before the change takes effect.

16. Contact Us

If you have any questions, concerns or complaints regarding this Privacy Policy, the way in which jiwn processes your Personal Data, or if you wish to exercise any of your data subject rights as described in Section 12, please contact us:

jiwn takes all privacy-related enquiries seriously. We are committed to resolving data subject requests and concerns in a fair, timely and transparent manner.