Privacy Policy – Milwin Pakistan Data Protection Statement

1. Who We Are

This Privacy Policy applies to the milwin platform operated at milwin.ws. Milwin is the data controller for all personal information collected from players through the platform. This means milwin is the entity that determines why and how your personal data is processed.

When this document refers to "milwin", "we", "us" or "our", it means the milwin platform and the company operating it. When it refers to "you" or "your", it means any individual who visits, registers on or uses any part of the milwin platform — including sports betting, live casino, Aviator, jackpot slots and fishing games.

This Privacy Policy should be read alongside the milwin Terms and Conditions. By registering a milwin account, you acknowledge that you have read and understood this Privacy Policy and you consent to milwin processing your personal data as described herein.

2. Data We Collect

Milwin collects different categories of personal data depending on how you use the platform. The following table summarises the main categories:

3. How We Collect Your Data

Milwin collects personal data through the following channels:

• Direct collection: Information you provide when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or opt into a promotion.
• Automated technical collection: When you visit milwin.ws, our servers automatically record technical information including your IP address, browser type, device identifiers and session data. This happens whether or not you are logged in.
• Cookies and similar technologies: Milwin uses cookies to maintain your login session, remember your preferences, track site performance and deliver relevant promotional content. See Section 8 for details.
• Payment processors: When you make a deposit or withdrawal via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT or card, the payment provider may share transaction confirmation data with milwin to reconcile your account balance.
• Identity verification services: Where milwin engages a third-party KYC (Know Your Customer) provider to verify your identity documents, that provider may share the results of the verification check with milwin.
• Fraud prevention databases: Milwin may check your details against industry fraud prevention and responsible gaming databases as part of its compliance obligations.

4. Why We Use Your Data

Milwin uses personal data for the following purposes:

Account Management

To register and maintain your milwin account, verify your identity, process your PKR deposits and withdrawals, settle your bets, apply bonuses and communicate with you about your account. This is the core purpose for which almost all personal data collected by milwin is used.

Legal and Regulatory Compliance

Milwin operates under a gaming licence that requires us to verify player identities, conduct anti-money laundering (AML) checks, maintain transaction records, and report certain activities to regulatory authorities. This is a legal obligation we cannot opt out of, and it applies to all players regardless of deposit amount or play level.

Responsible Gaming

Milwin analyses gaming activity data to identify patterns that may indicate problem gaming behaviour. Where such patterns are identified, milwin may proactively contact the player to offer responsible gaming tools or impose protective limits. This is done in the genuine interest of player welfare, not for commercial purposes.

Platform Security and Fraud Prevention

Technical data including IP addresses, device identifiers and session information is analysed to detect account takeover attempts, fraudulent deposits, bonus abuse and other security threats. Milwin's security systems run continuously in the background of every session on the platform.

Marketing and Promotions

If you have opted in to marketing communications at registration or via your account settings, milwin will use your contact details and gaming activity data to send you relevant promotional offers by email or SMS. You can opt out of marketing at any time through your account settings or by contacting support — opting out of marketing will never affect your ability to use any part of the milwin platform.

Platform Improvement

Aggregated, anonymised usage data is used to understand how Pakistani players use the milwin platform and to improve the design, performance and game selection of the platform over time.

5. Legal Basis for Processing

Milwin processes personal data under the following legal bases:

• Contract performance: Processing necessary to deliver the milwin service to you — account management, bet settlement, PKR payments. Without this data we simply cannot operate your account.
• Legal obligation: Processing required by our gaming licence, AML regulations, KYC requirements and tax obligations. We have no choice in this; it is a condition of operating a licensed gaming platform.
• Legitimate interests: Processing for fraud prevention, security monitoring, responsible gaming assessment and platform improvement — where our legitimate interest in operating a safe and compliant platform does not override your privacy rights.
• Consent: Marketing communications sent by email or SMS are based on your explicit consent, which can be withdrawn at any time.

6. Who We Share Data With

Milwin does not sell personal data to third parties under any circumstances. We may share data with the following categories of recipient strictly for the purposes described in this Privacy Policy:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, banking institutions and card networks receive the minimum data necessary to process your PKR transactions securely.
• KYC and identity verification providers: Third-party services that help milwin verify identity documents and run AML checks. These providers act under data processing agreements with milwin and may only use your data for verification purposes.
• Game software providers: The studios and developers who supply milwin's casino games may receive anonymised session data to maintain game integrity. They do not receive your identity or payment data.
• Responsible gaming organisations: Where a player has opted into self-exclusion, milwin may share necessary data with recognised self-exclusion database operators to honour the exclusion request across participating platforms.
• Regulatory and law enforcement authorities: Where required by our gaming licence or applicable law, milwin will disclose player data to licensing bodies, financial intelligence units or law enforcement agencies. Milwin will only do this where legally required and will not volunteer information beyond what is specifically requested.
• Professional advisors: Lawyers, auditors and accountants engaged by milwin may access limited personal data in the course of providing professional services, always subject to strict confidentiality obligations.

7. Payments and PKR Transaction Data

Because milwin operates entirely in Pakistani Rupees, all financial data processed by milwin relates specifically to PKR transactions. This section explains in more detail how payment data is handled.

Deposit Data

When you deposit via Easypaisa or JazzCash, your mobile wallet number is retained by milwin solely to match your deposit to your account and, where you have not completed identity verification, to serve as a supporting verification reference. Milwin does not have access to your Easypaisa or JazzCash account PIN, password or full account history — only the transaction confirmation data passed by the payment provider.

Withdrawal Data

To process a PKR withdrawal, milwin must hold your destination account details — mobile wallet number, bank account number and IBAN for IBFT, or partial card details for Visa/Mastercard. These details are encrypted in milwin's systems and used only to execute authorised withdrawal requests from your account.

Transaction Records

Milwin is required by its licensing conditions to maintain a complete record of all financial transactions on the platform for a minimum of five years. This includes every deposit, withdrawal, bet, win and bonus credit processed on your account. These records are held securely and are accessed only for account queries, dispute resolution, audits and regulatory reporting.

8. Cookies and Tracking Technologies

Milwin uses cookies and similar tracking technologies on the platform. A cookie is a small text file placed on your device by your browser when you visit milwin.ws. Cookies do not contain your personal data directly — they contain identifiers that allow milwin's systems to recognise your browser across sessions.

Categories of Cookies Used by Milwin

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in while you navigate between pages. You cannot opt out of these cookies without losing access to the platform.
• Performance cookies: Collect anonymised data about how players use milwin — which pages are visited most, where errors occur, how fast pages load. Used to improve platform performance.
• Functional cookies: Remember your preferences such as language settings, last game played or display options.
• Marketing cookies: Used only with your consent to track which promotional content you have engaged with and to avoid showing you the same offer repeatedly.

You can manage cookie preferences through your browser settings at any time. Note that blocking strictly necessary cookies will prevent the milwin platform from functioning correctly. Milwin does not use any third-party advertising cookies or allow external advertisers to place tracking cookies on the platform.

9. Data Retention

Milwin retains personal data for as long as is necessary for the purpose for which it was collected, or as required by our regulatory and legal obligations. The following retention periods apply:

• Account and identity data: Retained for the duration of your active milwin account plus a minimum of five years following account closure, as required by anti-money laundering regulations.
• Financial transaction records: Retained for a minimum of five years from the date of each transaction, in line with financial record-keeping requirements applicable to licensed gaming operators.
• Gaming activity logs: Retained for five years from the date of the activity. Used for dispute resolution, regulatory audits and responsible gaming assessments.
• Support communications: Live chat transcripts, emails and support tickets are retained for three years. After this period they are permanently deleted from milwin's systems.
• Marketing consent records: Retained for as long as you remain subscribed to marketing, plus one year following unsubscription, as evidence of consent.
• Technical and cookie data: Session data is deleted when your browser session ends. Analytics data is aggregated and anonymised within 90 days.

10. Security Measures

Milwin takes the security of your personal data seriously. The following technical and organisational measures are in place to protect your data on the platform:

• 256-bit SSL/TLS encryption: All data transmitted between your browser or app and milwin's servers is encrypted using industry-standard TLS protocols. This protects your login credentials, payment data and personal information in transit.
• Encrypted database storage: Sensitive data fields including financial account details, CNIC numbers and verification documents are stored in encrypted form at rest. Database access is restricted to authorised personnel only.
• Two-factor authentication (2FA): Available for all milwin player accounts. We strongly recommend enabling 2FA in your account security settings to add a second layer of protection against unauthorised login.
• Access controls: Milwin staff access to player data is role-based and strictly limited to what is necessary for each role. Support agents cannot access financial account credentials. Audit logs record every staff access to player data.
• Regular security audits: Independent penetration testing and security assessments are conducted on the milwin platform on a regular schedule. Critical vulnerabilities identified are remediated within 24 hours.
• Incident response: Milwin has a documented data breach response procedure. In the event of a breach that affects player data, affected players and relevant authorities will be notified within the timeframe required by applicable regulations.

11. Your Rights as a Milwin Player

As a player whose data is processed by milwin, you have the following rights. To exercise any of these rights, contact us at support@milwin.ws from your registered email address:

12. Children and Minors

The milwin platform is strictly for users aged 18 years and above. Milwin does not knowingly collect personal data from individuals under the age of 18. If you are a parent or guardian and believe that a minor has registered a milwin account using false age information, please contact us immediately at support@milwin.ws. We will investigate and close any account found to belong to a minor, deleting all associated data beyond what is required by law to retain for investigation purposes.

13. Changes to This Privacy Policy

Milwin may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations or platform features. When material changes are made, we will notify registered players by email with a minimum of 14 days' notice before the changes take effect. The revised policy will also be published on this page with an updated "Last Updated" date.

Continued use of the milwin platform after the effective date of any Privacy Policy change constitutes your acceptance of the updated policy. If you disagree with any change, you have the right to close your account by contacting support@milwin.ws — any balance will be returned to you subject to our standard withdrawal verification process.

We recommend reviewing this Privacy Policy periodically, particularly if you are a regular milwin player, to stay informed about how your data is handled.

14. Contact and Complaints

If you have any questions about this Privacy Policy or wish to exercise any of your data rights, please contact milwin through the following channels:

• Email (preferred for data rights requests): support@milwin.ws — include "Privacy Request" in the subject line and send from your registered email address so we can verify your identity.
• Live chat: Available 24/7 in your milwin account dashboard. For data rights requests, email is recommended as it creates a written record of your request.

Milwin will acknowledge all data rights requests within 5 business days and will provide a full response within 30 calendar days. If your request is complex or you have made multiple requests simultaneously, we may extend this period by a further 30 days and will notify you accordingly.