TrueWin Privacy Policy — How We Protect Your Data in Pakistan

This Privacy Policy applies to TrueWin, the online real-money gaming platform operated at truewin.ws (referred to throughout this policy as "TrueWin", "we", "us" or "our"). TrueWin is the data controller for personal information collected from players and visitors who use the platform.

TrueWin is a gaming platform built specifically for the Pakistani market, serving players across Pakistan. Our platform offers a range of real-money gaming products including sports betting, casino games, card games, jackpot slots, fishing games and esports betting — all operated in Pakistani Rupees and designed around the preferences and payment methods of Pakistani players.

This Privacy Policy applies to all personal data collected through your use of truewin.ws, including registration, account management, gameplay, financial transactions and any communications with TrueWin's customer support team. By using TrueWin, you acknowledge that you have read and understood this policy.

TrueWin collects personal data in three ways: information you provide directly to us, information generated by your use of the platform and information provided by third-party services we use to operate TrueWin. Here is a breakdown of what we collect and why:

TrueWin uses the personal data we collect for specific, clearly defined purposes. We do not use your data for purposes beyond those listed here without first obtaining your consent or updating this Privacy Policy to notify you:

• Account creation and management: To create and maintain your TrueWin account, verify your identity, manage your preferences and provide access to the platform's features.
• Payment processing: To process deposits from your chosen payment method and to process withdrawal requests back to your registered payment account. TrueWin does not store full card numbers — payment card data is handled by our PCI-compliant payment processors.
• Gameplay and transaction records: To maintain accurate records of all bets, game sessions and financial transactions as required for account management, dispute resolution and regulatory compliance.
• Identity verification and fraud prevention: To verify that you meet TrueWin's eligibility requirements, to detect and prevent fraud, money laundering and other prohibited activities and to comply with anti-money laundering obligations.
• Responsible gaming: To monitor gameplay patterns for indicators of problem gambling and to administer the responsible gaming tools and limits you set on your account. TrueWin may apply responsible gaming measures based on data analysis where patterns of concern are identified.
• Customer support: To respond to your queries, complaints and requests and to maintain records of communications for quality and compliance purposes.
• Platform improvement: To analyse usage patterns, identify technical issues, test new features and improve the overall performance and user experience of the TrueWin platform.
• Legal compliance: To comply with applicable laws and regulations, including financial record-keeping requirements, anti-money laundering regulations and any lawful orders from regulatory authorities.
• Marketing communications: To send promotional offers, bonus notifications and platform updates — but only where you have opted in to receive such communications. See Section 11 for details.

TrueWin processes your personal data under the following legal bases:

• Contractual necessity: Processing required to fulfil our contractual obligations to you as a registered TrueWin player — including account management, payment processing and gameplay records.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering regulations, financial record-keeping requirements and any lawful regulatory requests.
• Legitimate interests: Processing necessary for TrueWin's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring and platform performance improvement — provided these interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes — primarily marketing communications — where you have given explicit, informed consent. Consent can be withdrawn at any time without affecting the processing already carried out.

TrueWin does not sell your personal data to third parties. We share data only where it is necessary to operate the platform or to comply with legal obligations, and only with parties who are contractually required to protect it:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, bank partners and card processing networks receive the payment details necessary to process your deposit or withdrawal transaction. These parties are PCI-DSS compliant and operate under strict data processing agreements.
• Identity verification services: Where identity verification is required, we work with regulated identity verification providers who process your verification documents under strict data processing agreements. Document data is used solely for verification and is not retained beyond the period required.
• Technology and infrastructure partners: TrueWin uses third-party cloud infrastructure, analytics tools and platform technology providers. These partners process data on TrueWin's behalf under contractual obligations that prohibit independent use of your data.
• Regulatory and law enforcement authorities: Where required by applicable law, court order or regulatory instruction, TrueWin will disclose personal data to competent authorities. TrueWin will notify you of any such disclosure unless legally prohibited from doing so.

TrueWin uses cookies and similar tracking technologies on the platform. Cookies are small text files stored on your device that help us provide a better, more personalised experience. Here is how TrueWin uses cookies:

• Essential cookies: Required for the platform to function — these manage your login session, keep you logged in securely and ensure the platform operates correctly. These cannot be disabled without preventing your use of TrueWin.
• Functional cookies: Remember your preferences — such as language settings and display preferences — so you don't have to reconfigure them every visit.
• Analytics cookies: Collect anonymised data about how visitors use the platform — which pages are visited most, where users navigate from and any technical errors encountered. This data is used solely to improve TrueWin's performance and never to identify individual users.
• Security cookies: Help us detect and prevent fraudulent activity, including identifying suspicious login patterns and potential unauthorised account access attempts.

You can manage cookie preferences through your browser settings. Disabling essential cookies will prevent you from logging in or using TrueWin's core features. Disabling analytics cookies will not affect your ability to use the platform but will reduce our ability to identify and fix technical issues.

TrueWin implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration or disclosure. These measures include:

• TLS encryption in transit: All data transmitted between your device and TrueWin's servers is encrypted using Transport Layer Security (TLS). This protects your data from interception during transmission.
• Encryption at rest: Sensitive personal data — including identity documents and financial information — is stored in encrypted form on TrueWin's servers.
• Access controls: Access to personal data within TrueWin's organisation is strictly limited to staff who require it to perform their job functions. Access rights are reviewed regularly.
• Security monitoring: TrueWin monitors its systems continuously for suspicious activity, including attempted unauthorised access, unusual transaction patterns and potential data breaches.
• Incident response: TrueWin maintains a documented incident response procedure. In the event of a data breach that poses a risk to your rights, TrueWin will notify affected players promptly and take immediate steps to contain the incident.

While TrueWin takes every reasonable precaution to protect your data, no internet transmission or electronic storage system is completely secure. You use TrueWin's platform acknowledging this inherent limitation. If you believe your account security has been compromised, contact TrueWin support immediately at support@truewin.ws.

TrueWin retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following retention principles apply:

• Active account data: Personal data associated with an active TrueWin account is retained for the duration of the account's active status plus any legally required period following account closure.
• Financial transaction records: Records of deposits, withdrawals and gameplay transactions are retained for a minimum of five years from the date of the transaction, as required by financial record-keeping regulations.
• Identity verification records: Identity verification documents are retained for as long as required to comply with anti-money laundering regulations — typically five years from the end of the customer relationship.
• Customer support communications: Records of support interactions are retained for three years from the date of the interaction, or longer if the interaction is connected to a complaint or dispute that remains open.
• Marketing consent records: Records of your marketing consent or opt-out decisions are retained indefinitely to demonstrate compliance with your stated preferences.

When data reaches the end of its retention period and there is no legal basis for continued retention, TrueWin deletes or anonymises it securely. You can request early deletion of your data by contacting support — see Section 9 for your rights in this regard.

As a TrueWin player, you have the following rights in relation to your personal data. To exercise any of these rights, contact TrueWin at support@truewin.ws — we will respond within 30 days:

TrueWin is strictly an adult platform — registration and play are permitted only for individuals aged 18 years and above. TrueWin does not knowingly collect personal data from anyone under the age of 18.

If TrueWin becomes aware that personal data has been collected from a person under the age of 18, that account will be immediately suspended, the personal data will be deleted and any deposited funds will be returned to the payment source. TrueWin takes its responsibility to prevent underage access to its platform extremely seriously.

If you believe a minor has registered on TrueWin, please contact us immediately at support@truewin.ws so that we can take immediate action.

TrueWin sends marketing communications — including promotional bonus offers, new game announcements and seasonal campaign notifications — only to players who have explicitly opted in to receive them.

• Marketing opt-in is offered at registration and can be changed at any time from within your account settings.
• You can opt out of marketing communications at any time by updating your preferences in your account settings, by clicking the unsubscribe link in any marketing email, or by contacting TrueWin support at support@truewin.ws.
• Opting out of marketing communications takes effect immediately. You will no longer receive promotional messages but will continue to receive essential account communications — such as deposit confirmations, withdrawal notifications and security alerts — which are not marketing communications and are required for account management.
• TrueWin does not share your contact details with any third party for marketing purposes. All TrueWin marketing is sent directly by TrueWin — you will never receive marketing from third parties as a result of your TrueWin registration.

TrueWin may update this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements or improvements to how we communicate our privacy practices. The date of the most recent update is always shown at the top of this page.

When material changes are made to this Privacy Policy — changes that affect your rights or the way your data is used in a significant way — TrueWin will notify registered players via email or in-platform notification before the changes take effect, giving you the opportunity to review the updated policy and, if necessary, close your account before the new policy applies.

Your continued use of TrueWin following any update to this Privacy Policy constitutes your acceptance of the revised policy. TrueWin recommends that you review this page periodically to stay informed of any updates.

For any questions, concerns or requests relating to this Privacy Policy or TrueWin's handling of your personal data, please contact us using the details below. TrueWin is committed to addressing all privacy-related communications promptly and transparently.

• Email: support@truewin.ws
• Subject line for data requests: "Privacy Rights Request"
• Website: truewin.ws
• Support availability: 24 hours a day, 7 days a week

TrueWin will acknowledge your privacy-related communication within 2 business days and will provide a substantive response within 30 calendar days. Complex requests may take longer — we will always notify you if we need additional time.