Privacy Policy
How jjwln Handles Your Data

Introduction

This Privacy Policy ("Policy") describes how jjwln ("we", "us", "our", the "Operator") collects, uses, stores, discloses and protects the personal data of individuals ("you", "User", "Player") who access the jjwln platform at https://jjwln.cam or who interact with jjwln through any associated interface, customer support channel or communication method.

jjwln is committed to handling personal data responsibly, transparently and in accordance with applicable data protection legislation. This Policy forms part of the overall legal framework governing your use of the Platform and should be read alongside the Terms and Conditions and the Responsible Gambling Policy.

By registering an Account, using the Platform or communicating with jjwln support, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein, where such processing is based on consent. Processing that is based on other legal grounds (such as contract performance or legal obligation) does not require your separate consent but is carried out in compliance with applicable law.

Definitions

The following terms carry the meanings set out below throughout this Policy:

• "Personal Data" Any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers, payment details and usage behaviour.
• "Processing" Any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" The Operator entity responsible for determining the purposes and means of processing Personal Data, as identified in the licensing disclosure published on the Platform.
• "Data Processor" Any third party that processes Personal Data on behalf of jjwln pursuant to a written data processing agreement.
• "Account" A registered user account on the jjwln Platform.
• "KYC Data" Identity and address verification documentation collected as part of Know Your Customer procedures, including government-issued identification and proof of address.
• "Special Category Data" Sensitive categories of Personal Data afforded enhanced protection under applicable data protection law, including health-related information (such as self-exclusion or problem gambling records).
• "Cookie" A small text file stored on a User's device by the Platform for the purposes described in Section 10 of this Policy.

Personal Data We Collect

jjwln collects personal data in the following categories, depending on how you interact with the Platform:

3.1 Registration & Account Data

• Full name and date of birth
• Email address and chosen username
• Residential address and country of residence
• Account password (stored in hashed form — never in plain text)
• Preferred currency (PKR for Pakistani users)
• Contact language preference (English)

3.2 KYC & Identity Verification Data

• Scanned copies of government-issued photo identification (e.g., Pakistan CNIC, passport, driving licence)
• Proof of residential address documents
• Source of funds documentation where required by anti-money-laundering obligations
• Facial image data where required for liveness verification

3.3 Financial & Transaction Data

• Deposit amounts, dates and payment method identifiers
• Withdrawal requests, amounts and processing status
• Transaction history including bets placed, winnings and bonus credits
• Payment method reference data (e.g., partial account numbers or masked card numbers)

3.4 Technical & Usage Data

• IP address and approximate geolocation derived from it
• Device type, operating system and browser version
• Session duration, pages visited and features used
• Login timestamps and account activity logs
• Crash reports and performance diagnostics

3.5 Communications Data

• Records of live chat conversations and support tickets
• Email correspondence with the support team
• Feedback and survey responses where voluntarily submitted

3.6 Responsible Gambling Data

Where you make use of responsible gambling tools — including deposit limits, self-exclusion requests, cool-off activations or problem gambling disclosures — this information is treated as Special Category Data and is processed with enhanced safeguards. It is used solely to enforce your chosen restrictions, to comply with regulatory obligations and to support your wellbeing. It is not used for marketing or commercial profiling.

How We Use Your Personal Data

jjwln uses the personal data it collects for the following purposes:

jjwln does not use your personal data for automated decision-making that produces legal or similarly significant effects without human oversight, except where expressly permitted by applicable law and disclosed to you.

Legal Basis for Processing

Processing of your personal data is carried out on one or more of the following legal bases:

• Contract performance: Processing necessary to deliver the services you have contracted for, including account management, transaction processing and customer support.
• Legal obligation: Processing required to comply with applicable law, including KYC/AML requirements, regulatory reporting and age verification.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gambling enforcement and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have provided explicit consent that can be withdrawn at any time.
• Vital interests: Processing of Special Category Data (including responsible gambling records) where necessary to protect your vital interests or those of another person.

Data Sharing & Disclosure

6.1 Service Providers (Data Processors)

jjwln shares personal data with vetted third-party service providers acting as Data Processors under written agreements that impose equivalent data protection obligations. These include: payment processing providers, identity verification and KYC service providers, game content delivery networks, customer support platform operators, fraud detection service providers, and cloud infrastructure providers.

6.2 Regulatory Authorities

jjwln may be required to disclose personal data to regulatory bodies, law enforcement agencies, financial intelligence units or other governmental authorities where required by applicable law or a binding legal order. Such disclosures are made only to the extent required and will be carried out in accordance with applicable legal procedures.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of the Operator's business (in whole or in part), personal data held about you may be transferred to the acquiring entity as part of the transaction. You will be notified of any material change in data controller identity via the Platform or by email.

6.4 What We Do Not Do

jjwln does not:

• Sell personal data to third-party data brokers or advertisers
• Share personal data with other gambling platforms or their affiliates for cross-platform profiling without your consent
• Disclose personal data to Pakistani financial institutions (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) beyond the transactional data necessary to process your specific payment instructions
• Transfer personal data to any party that has not agreed to process it in compliance with applicable data protection standards

Data Retention

jjwln retains personal data for as long as is necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory and contractual obligations. The following general retention principles apply:

• Account and KYC data: Retained for a minimum of five (5) years from Account closure, or longer where required by anti-money-laundering legislation applicable to the licensing jurisdiction.
• Transaction data: Retained for a minimum of five (5) years from the date of each transaction, or as required by applicable financial record-keeping regulations.
• Communications data: Support communications retained for up to three (3) years for dispute resolution purposes.
• Technical and usage data: Log data retained for up to twelve (12) months unless required for longer by a specific investigation or legal process.
• Responsible gambling records: Self-exclusion records retained for the full duration of any exclusion period plus five (5) years to prevent circumvention by re-registration.

When personal data is no longer required, it is securely deleted or anonymised so that it can no longer be attributed to an individual. Anonymised aggregate data may be retained indefinitely for statistical and service improvement purposes.

Data Security

jjwln implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data it holds. These measures include:

• TLS encryption: All data in transit between your device and jjwln's servers is encrypted using Transport Layer Security (TLS 1.2 or higher).
• Encryption at rest: Sensitive stored data, including KYC documents and financial records, is encrypted using industry-standard algorithms.
• Access controls: Access to personal data is restricted to authorised personnel on a need-to-know basis. Administrative access is protected by multi-factor authentication.
• Password security: Account passwords are stored as salted hashes — never in plain text. jjwln will never ask you for your password via any communication channel.
• Monitoring & logging: System access is logged and monitored for anomalous activity. Suspected security incidents are investigated promptly.
• Vendor security assessments: Third-party data processors are assessed for security standards prior to engagement.

Your Data Protection Rights

Subject to the legal basis on which your data is processed and applicable jurisdictional requirements, you have the following rights with respect to your personal data held by jjwln. To exercise any of these rights, contact us using the details in Section 15.

jjwln will respond to rights requests within one (1) month of receipt. Complex requests may require an extension of up to two (2) further months; in such cases, you will be notified of the extension and the reason. Requests may be refused where they conflict with overriding legal obligations, such as anti-money-laundering retention requirements.

Cookies & Similar Technologies

jjwln uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences and analyse usage patterns. The following categories of cookies are used:

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality. Disabling analytics or marketing cookies will not affect your ability to use the Platform's core features.

Minors & Underage Access

The jjwln Platform is strictly for adults aged 18 years or above (or the higher minimum age required by the applicable licensing jurisdiction). jjwln does not knowingly collect personal data from individuals below the minimum age. If we become aware that personal data has been collected from a minor, we will promptly delete that data and close the associated Account.

If you are a parent or guardian and believe that a minor in your household has registered on jjwln or accessed the Platform, please contact us immediately using the details in Section 15. We take underage access extremely seriously and will act promptly on all such reports.

Third-Party Services & Links

The Platform integrates third-party services including game content providers, sports data feeds and payment processing gateways. These third parties operate under their own privacy policies and data handling practices. jjwln is not responsible for the privacy practices of third-party services accessed through the Platform.

Where third-party services process personal data on jjwln's behalf, they do so under written Data Processing Agreements requiring equivalent data protection standards. Where they process data for their own purposes as independent controllers (for example, licensed game studios collecting gameplay data under their own terms), their respective privacy policies apply.

jjwln does not host external links to third-party websites. All Platform content is served from jjwln's own infrastructure or from contracted service providers.

International Data Transfers

As an internationally operating platform, jjwln may transfer personal data to countries outside your country of residence for the purposes described in this Policy. Where such transfers take place, jjwln ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required in the jurisdiction of the Data Controller.

Safeguards used for international data transfers may include: adequacy decisions by competent authorities, standard contractual clauses approved by relevant data protection bodies, binding corporate rules, or other legally recognised transfer mechanisms.

If you would like more information about the specific safeguards applied to any particular transfer of your personal data, please contact us using the details in Section 15.

Changes to This Privacy Policy

jjwln reserves the right to update or revise this Privacy Policy at any time to reflect changes in the Platform's data processing activities, applicable law or regulatory requirements. The most current version of the Policy is always available on this page, with the effective date displayed at the top.

Material changes to this Policy — particularly those that affect your rights or the legal basis for processing — will be communicated to registered users via a Platform notification and/or email to the address on your Account, with no less than fourteen (14) days' advance notice where operationally feasible.

Your continued use of the Platform following the effective date of a revised Policy constitutes your acknowledgement of the changes. If you disagree with any revision, you should cease using the Platform and may request Account closure in accordance with the Terms and Conditions.

Contact Us

For all data protection enquiries, rights requests and privacy complaints, please contact the jjwln data team using the details below. All enquiries should be submitted in English and should include your Account username and a clear description of your request.