Privacy Policy – winjj Platform

1. Introduction

winjj ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the winjj website at https://winjj.cam ("the Services"). This Privacy Policy ("Policy") sets out in formal, structured terms how we collect, use, store, protect and, where applicable, transfer personal data relating to you ("User", "Player", "Data Subject", "you").

This Policy applies to all personal data processed by winjj in connection with the operation of its online gaming platform, including data collected during account registration, KYC verification, payment processing, customer support interactions, marketing communications and general platform usage.

By registering an account or using the Services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. Where consent is the legal basis for processing, you may withdraw that consent at any time, subject to the conditions described in Section 11 (User Rights). Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which form part of the overall framework governing your use of winjj.

2. Definitions

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

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, date of birth, device identifiers and financial data.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, disclosure and erasure.
• "Data Controller" — winjj, as the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" — any third party that processes Personal Data on behalf of winjj under a contractual arrangement.
• "KYC Data" — documents and information collected for Know Your Customer verification, including identity documents and proof of address.
• "Cookies" — small text files placed on a User's device by the Platform for the purposes of session management, analytics and personalisation.
• "Sensitive Data" — a subset of Personal Data attracting heightened protection, including data concerning health, financial vulnerability indicators and self-exclusion status.
• "Third Country" — any country outside the jurisdiction in which winjj's operating licence is issued and which may not offer equivalent data-protection standards.

3. Data We Collect

3.1 Registration Data

When you create an Account on winjj, we collect the following categories of Personal Data:

• Full legal name;
• Date of birth;
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar);
• Email address;
• Mobile telephone number;
• Username and encrypted password.

3.2 KYC and Identity Verification Data

To comply with anti-money-laundering (AML) and fraud-prevention obligations, and to verify player eligibility, we collect:

• Copies of government-issued identity documents (e.g., Pakistani CNIC, passport, driving licence);
• Proof of residential address (e.g., utility bill, bank statement);
• Proof of payment method ownership where applicable;
• Selfie or liveness-check imagery where required by our verification procedures.

3.3 Financial and Transaction Data

We collect data relating to your financial activity on the Platform, including:

• Deposit and withdrawal amounts and timestamps;
• Payment method details (partial card or account references — full card numbers are not stored by winjj);
• Wagering history, game participation and winnings data;
• Bonus claim and wagering-requirement completion records.

References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah appear in our payment interface as contextual familiarity markers. Financial data transacted through any payment provider is subject to that provider's own privacy and data-retention policies. winjj does not store full payment credentials for these services.

3.4 Technical and Usage Data

When you access the Platform, we automatically collect the following technical data:

• IP address and approximate geolocation;
• Device type, operating system and browser version;
• Pages visited, session duration and click-path data;
• Referring URL and exit page;
• Error logs and performance diagnostics.

3.5 Communications Data

If you contact our support team via email or live chat, we retain records of that communication, including the content of your enquiry and our response, for quality assurance, dispute resolution and regulatory compliance purposes.

3.6 Responsible Gambling Data

Where you activate responsible gambling tools (deposit limits, self-exclusion, cooling-off periods), we record and process that election as Sensitive Data. This information is used exclusively to give effect to your responsible gambling preferences and is not used for marketing purposes.

4. Data Processing & Legal Basis

winjj processes Personal Data on one or more of the following legal bases:

5. How We Use Your Personal Data

winjj uses the Personal Data we collect for the following purposes:

• Account management: creating, maintaining and securing your Account;
• Service delivery: processing deposits, withdrawals, wagers and bonus activations;
• Identity verification: conducting KYC checks to confirm age, identity and address;
• Fraud and AML prevention: detecting, investigating and preventing fraudulent activity and money laundering;
• Responsible gambling: implementing and monitoring the responsible gambling controls you activate, including self-exclusion and deposit limits;
• Customer support: responding to your queries and resolving disputes;
• Platform improvement: analysing usage patterns to improve functionality, user experience and content;
• Security: detecting unauthorised access, protecting account integrity and maintaining platform security;
• Marketing (where consented): sending promotional communications about winjj offers — you may opt out at any time;
• Legal compliance: meeting obligations under applicable laws and responding to lawful requests from regulatory or law-enforcement authorities.

6. Data Sharing & Disclosure

6.1 We Do Not Sell Your Data

winjj does not sell, rent or trade your Personal Data to third parties for commercial purposes. Your data is not a revenue product.

6.2 Data Processors

We engage carefully selected third-party service providers who process Personal Data strictly on our behalf and under binding contractual obligations. Categories of processors include:

• KYC and identity-verification technology providers;
• Payment-processing infrastructure providers;
• Cloud-hosting and data-storage providers;
• Customer-support platform providers;
• Analytics and fraud-detection services.

6.3 Legal and Regulatory Disclosure

We may disclose Personal Data to competent regulatory bodies, law-enforcement agencies or courts where we are under a legal obligation to do so, or where disclosure is necessary to prevent or detect fraud, money laundering or other serious unlawful activity.

6.4 Corporate Transfers

In the event of a merger, acquisition or sale of all or part of the Platform's business, Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections. Users will be notified of any material change in data controller prior to such a transfer taking effect.

7. Cookies & Tracking Technologies

The winjj Platform uses cookies and similar tracking technologies to enable core functionality, analyse usage and support platform security. The categories of cookies we use are as follows:

• Essential Cookies: Required for login sessions, security tokens and core navigation. These cannot be disabled without impairing Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how Users interact with the Platform — page views, session lengths, click paths. This data helps us improve the Platform experience.
• Preference Cookies: Store your language, display or other personalisation preferences across sessions.
• Security Cookies: Help detect and prevent fraudulent activity, unauthorised access and bot traffic.

You may manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use core Platform features. Note that certain essential cookies cannot be refused without materially impairing your access to the Services.

8. Data Retention

winjj retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and registration data: Retained for the duration of the Account relationship and for a minimum of five (5) years after Account closure, to satisfy AML and regulatory record-keeping requirements;
• KYC documentation: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by applicable law;
• Transaction records: Retained for a minimum of five (5) years in compliance with financial record-keeping obligations;
• Support communications: Retained for up to three (3) years for quality assurance and dispute resolution;
• Marketing data: Retained until consent is withdrawn or for a maximum of two (2) years of inactivity, whichever is earlier;
• Technical and usage data: Typically retained in aggregated form for up to thirteen (13) months.

Upon expiry of applicable retention periods, data is securely deleted or anonymised in accordance with our data-disposal procedures.

9. Data Security

winjj implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• Encryption of data in transit using TLS (Transport Layer Security);
• Encryption of stored sensitive data at rest;
• Role-based access controls limiting internal data access to authorised personnel only;
• Regular security audits and vulnerability assessments;
• Multi-factor authentication for administrative platform access.

No data transmission over the internet is entirely without risk. While we implement industry-standard protections, we cannot guarantee the absolute security of data transmitted to or from the Platform. You are responsible for maintaining the security of your own account credentials.

10. International Data Transfers

As an internationally operated platform, winjj may transfer your Personal Data to Data Processors located in countries outside the jurisdiction in which you reside, including Third Countries that may not provide the same level of data protection as your home jurisdiction.

Where such transfers occur, winjj ensures they are conducted under appropriate safeguards, which may include:

• Standard contractual clauses approved by competent data-protection authorities;
• Binding corporate rules applicable to intra-group transfers;
• Adequacy decisions confirming equivalent protection in the destination country.

By using the Services, you acknowledge that your Personal Data may be transferred and processed outside your country of residence in accordance with this Section and the safeguards described herein.

11. User Rights

Subject to applicable law and certain exceptions, you hold the following rights with respect to your Personal Data held by winjj:

To exercise any of these rights, contact our Data Protection team at [email protected] with the subject line "Data Rights Request". We will respond within the timeframe required by applicable law — typically within thirty (30) days. We may need to verify your identity before processing your request.

Please note that certain rights are subject to exceptions. For example, we are unable to erase data we are legally required to retain under AML or financial record-keeping regulations. Where an exception applies, we will inform you of the reason for our decision.

12. Minors & Age Verification

The winjj Platform is strictly intended for adults. You must be at least 18 years of age — or such higher minimum age as required by the operator's licence jurisdiction — to register an Account. We do not knowingly collect Personal Data from persons below the applicable minimum age.

Age verification is conducted as part of the standard KYC process. If we become aware that Personal Data has been collected from a minor without appropriate consent, we will take steps to delete that data and close the associated Account without delay.

If you have reason to believe that a minor has accessed the Platform or created an Account, please contact us immediately at [email protected].

13. Third-Party Services

The Platform may contain references to or integration with third-party services — including payment processors, game software providers and analytics platforms. These third parties operate under their own privacy policies, which are separate from and independent of this Policy.

winjj is not responsible for the privacy practices of third-party providers. We recommend that you review the privacy policy of any third-party service with which you interact in connection with your use of the Platform.

References to payment brands such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are contextual only. Any data you share directly with these providers in the course of a transaction is governed by those providers' own privacy and data-processing policies. winjj is not a party to those interactions.

14. Policy Amendments

winjj reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, our data-processing activities or Platform features. When material changes are made, we will notify registered Users by email or via a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy will be revised each time an amendment is published. We encourage you to review this Policy periodically. Continued use of the Services following notification of an amendment constitutes acceptance of the revised Policy.

15. Contact Us

For all privacy-related enquiries, data-rights requests or concerns regarding the handling of your Personal Data, please contact the winjj Data Protection team:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Rights Requests: "Data Rights Request"
• Support Hours: 24 hours a day, 7 days a week
• Response Time: We aim to acknowledge all privacy requests within 5 business days and provide a full response within 30 calendar days.

Our customer support team serves players from across Pakistan — including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — and handles privacy queries in both English and Urdu.