winbbb Privacy Policy — How We Protect Your Personal Data

This Privacy Policy applies to all personal data collected and processed by winbbb ("we", "us", "our") in connection with the operation of the winbbb online gaming platform accessible at winbbb.app and all associated services, mobile interfaces, and promotional communications directed at Members ("you", "your").

winbbb acts as the Data Controller in respect of all personal data processed under this Policy. As Data Controller, winbbb determines the purposes for which, and the means by which, your personal data is processed. winbbb is committed to processing personal data responsibly and in accordance with applicable data protection principles, including those recognised under international data protection frameworks relevant to our licensed jurisdiction.

This Policy applies to all current Members, former Members, and individuals who have interacted with winbbb communications or visited the winbbb Platform without completing registration. By accessing or using any winbbb service, you confirm that you have read and understood this Privacy Policy in full.

winbbb collects personal data through several channels: directly from you when you register or use the Platform, automatically through your device and browser as you interact with the Platform, and in limited circumstances from third-party verification providers. The categories of data collected are set out below.

winbbb does not intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, or health information unless it is directly relevant to a responsible gaming assessment and you have provided it voluntarily.

winbbb uses personal data only for specific, documented purposes. The principal purposes for which your data is processed are as follows:

• Account Creation & Management: To register, verify, and maintain your winbbb account, including identity verification (KYC) in compliance with our licensing obligations.
• Service Delivery: To provide you with access to sports betting, casino games, live dealer tables, slot games, and all other winbbb platform features.
• Payment Processing: To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other approved payment methods in PKR.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, and other prohibited conduct.
• Regulatory Compliance: To satisfy our obligations under applicable gaming regulations, anti-money laundering laws, and know-your-customer requirements.
• Responsible Gaming: To monitor wagering patterns and intervene appropriately where behaviour indicates potential gambling harm, and to enforce self-exclusions, deposit limits, and cooling-off periods.
• Customer Support: To respond to queries, resolve disputes, and improve the overall quality of our support interactions.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to Members who have not opted out of marketing communications. You may opt out at any time.
• Product Improvement: To analyse aggregated usage data and improve the winbbb Platform, game selection, interface design, and payment infrastructure.
• Legal Proceedings: To establish, exercise, or defend legal claims where necessary.

winbbb processes your personal data on one or more of the following legal grounds, depending on the nature and purpose of each processing activity:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under the winbbb Terms & Conditions, including account management, payment processing, and service delivery.
• Legal Obligation: Processing necessary to comply with applicable gaming regulations, anti-money laundering obligations, KYC requirements, and any mandatory reporting obligations under our operating licence.
• Legitimate Interests: Processing carried out in pursuit of winbbb's legitimate business interests — including fraud detection, platform security, product improvement, and responsible gaming monitoring — where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on your consent — for example, for optional marketing communications — you retain the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

winbbb shares personal data with third parties only in the following defined circumstances:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment providers receive the minimum financial data required to process your deposits and withdrawals.
• Game Providers: Casino game studios (such as Pragmatic Play, NetEnt, and others) receive a technical session identifier to deliver gameplay. They do not receive your full identity or financial details.
• Identity Verification Services: Third-party KYC providers may receive identity documents submitted during account verification. These providers are bound by strict data handling agreements.
• Responsible Gaming Partners: In cases of self-exclusion, winbbb may share limited data with inter-operator self-exclusion registries as required by our licensing obligations.
• Regulatory Authorities: winbbb may disclose personal data to gaming regulators, financial intelligence units, or law enforcement agencies when legally required or compelled by a valid legal process.
• Legal & Professional Advisors: Lawyers, auditors, and compliance consultants who process data under strict confidentiality obligations in connection with winbbb's business operations.
• Business Transfers: In the event of a merger, acquisition, or asset sale involving winbbb, personal data may be transferred to the successor entity, subject to continuation of equivalent privacy protections.

All third parties with whom winbbb shares personal data are required to implement and maintain appropriate technical and organisational security measures and are prohibited from using your data for any purpose beyond what winbbb has contracted them to perform.

The winbbb Platform uses cookies and similar tracking technologies to ensure the Platform functions correctly, to improve your experience, and to support our security and analytics operations. A cookie is a small data file stored on your device by your browser.

winbbb uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to operate. These include session authentication cookies that keep you logged in to your winbbb account. These cannot be disabled without preventing Platform access.
• Functional Cookies: Remember your preferences — such as language settings, your preferred game lobby view, and deposit method — to personalise your experience across sessions.
• Analytics Cookies: Help winbbb understand how Members interact with the Platform, which pages are visited most frequently, and where technical issues occur. This data is aggregated and not linked to individual identities.
• Security Cookies: Support our fraud detection systems by identifying unusual session patterns that may indicate account compromise or prohibited automated activity.

You may configure your browser to refuse or delete cookies at any time. Note that disabling strictly necessary cookies will prevent you from accessing your winbbb account. Disabling functional cookies will result in your preferences not being saved between sessions.

winbbb implements a layered approach to data security designed to protect your personal information against unauthorised access, disclosure, alteration, and destruction. Our security infrastructure includes the following measures:

• 256-bit SSL/TLS encryption on all data transmission between your device and winbbb servers.
• Encrypted storage of all sensitive personal and financial data at rest.
• Role-based access controls ensuring that only authorised winbbb personnel with a specific operational need can access Member personal data.
• Multi-factor authentication for all internal administrative systems handling Member data.
• Regular penetration testing and security audits conducted by independent third parties.
• Comprehensive logging of all data access events for audit and intrusion detection purposes.
• Secure disposal procedures for data that has reached the end of its retention period.

winbbb retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable laws and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained for the full duration of your membership and for a period of up to five (5) years after account closure, to meet regulatory obligations and to facilitate the resolution of any disputes or regulatory enquiries.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction in accordance with anti-money laundering regulations applicable to our licensed jurisdiction.
• KYC & Identity Documents: Retained for the period required by applicable gaming and financial regulations, typically five (5) to seven (7) years from account closure.
• Marketing Preferences & Opt-Out Records: Retained indefinitely to ensure that opt-out preferences continue to be honoured even if you re-register on the Platform.
• Support Correspondence: Retained for a minimum of two (2) years from the date of the last interaction for quality assurance and dispute resolution purposes.
• Self-Exclusion Records: Retained for the full duration of the self-exclusion period and for a further period of up to five (5) years, to prevent circumvention of exclusion decisions.

At the end of the applicable retention period, personal data is either securely deleted or irreversibly anonymised so that it can no longer be associated with any individual.

As a winbbb Member, you hold meaningful rights over the personal data we hold about you. These rights are summarised below. To exercise any of these rights, please contact us at [email protected] with your full name, registered mobile number or email address, and a description of your request. winbbb will acknowledge receipt within 48 hours and respond substantively within thirty (30) days.

winbbb does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted at registration using declared date of birth, and may be supplemented by documentary identity verification at any point during the account lifecycle. If winbbb becomes aware that personal data has been collected from a person under 21, the account will be immediately suspended, all funds returned through the original deposit method, and the personal data deleted without delay.

If you have reason to believe that a person under the age of 21 has accessed winbbb services using false information, please notify us immediately at [email protected]. winbbb takes its age verification obligations seriously and will respond promptly to any such notification.

winbbb operates a global technical infrastructure. Personal data collected from Pakistani Members may be transferred to and processed in countries outside Pakistan, including the jurisdiction in which winbbb holds its operating licence and the locations of our technology infrastructure and third-party service providers.

Where such international transfers occur, winbbb implements appropriate safeguards to ensure that your personal data continues to be protected to a standard equivalent to the protections afforded in this Privacy Policy. These safeguards may include data processing agreements with our service providers incorporating internationally recognised data protection clauses.

By using the winbbb Platform and providing personal data to winbbb, you acknowledge and consent to the transfer of your personal data to locations outside Pakistan as described in this section, subject to the protections outlined above.

winbbb reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or the services we offer. Material changes — those that significantly affect how we collect, use, or share your personal data — will be communicated to registered Members via the registered email address at least seven (7) days prior to the effective date of the change.

Non-material updates — such as corrections to language, clarifications of existing practices, or formatting changes — will take effect immediately upon publication on this page. The date shown at the top of this Policy will be updated accordingly.

We recommend that all winbbb Members review this page periodically. Your continued use of the winbbb Platform following any change to this Privacy Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, please discontinue use of the Platform and contact [email protected] to close your account.

All privacy-related enquiries, data subject access requests, consent withdrawals, and data deletion requests should be directed to the winbbb support team. Please include your full registered name, your winbbb-registered mobile number or email address, and a clear description of your request or concern to allow us to respond efficiently.

This Privacy Policy was last reviewed and updated in January 2026 and supersedes all previous versions. winbbb is committed to transparent, responsible handling of every Pakistani player's personal data — and this Policy reflects that commitment in full.