jjwon Privacy Policy — How We Collect, Use & Protect Your Personal Data

This Privacy Policy ("Policy") is published by jjwon ("we", "us", "our", "jjwon"), the operator of the online casino and sports betting platform accessible at jjwon.app. It governs how jjwon processes the personal data of all individuals who visit jjwon.app, register a player account, make deposits or withdrawals, place wagers, contact our support team, or interact with the platform in any other capacity ("you", "Player", "User").

This Policy forms part of jjwon's broader legal framework, which also includes the Terms & Conditions and the Responsible Gaming Policy. Where any specific promotional or product terms address data handling in a manner that differs from this Policy, this Policy shall prevail unless the specific terms explicitly state otherwise.

By registering a jjwon account, continuing to use jjwon.app, or submitting personal data to jjwon through any channel, you confirm that you have read and understood this Policy and that you consent to the data processing activities described herein to the extent that consent is the applicable legal basis for a given processing activity.

jjwon collects the following categories of personal data, depending on how you interact with the platform:

jjwon does not knowingly collect sensitive personal data beyond what is strictly required for identity verification and anti-money-laundering compliance. We do not collect religious affiliation, biometric data (other than CNIC photograph for KYC), health information, or political opinions.

jjwon collects personal data through the following channels:

• Direct submission: When you register a jjwon account, complete KYC verification, make a deposit or withdrawal request, submit a support ticket, or otherwise input data into the platform directly.
• Automated technical collection: When you visit jjwon.app, our servers automatically log technical data including your IP address, device identifiers, browser fingerprint, and session timestamps. This occurs on every page load and during every active game session.
• Cookies and tracking technologies: jjwon uses first-party cookies and similar technologies to maintain session state, remember your preferences, and collect aggregate usage analytics. See Section 7 for full details on cookie categories and how to manage them.
• Payment processors: When you complete a deposit or withdrawal, our payment processing partners (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank) transmit transaction confirmation data to jjwon's systems to reconcile your PKR wallet balance.
• Third-party game providers: Licensed game studios that supply casino titles and live dealer tables to jjwon's platform transmit game session outcome data and RTP audit logs to jjwon for compliance and dispute resolution purposes.
• KYC and AML screening services: jjwon uses third-party identity verification and sanctions screening services to validate CNIC documents and check player identities against applicable watchlists as required by our international gaming license.

Every personal data processing activity conducted by jjwon rests on one of the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations to you under the jjwon Terms & Conditions — including account creation, identity verification, processing deposits and withdrawals, settling bets, and delivering game outcomes.
• Legal obligation: Processing required to comply with applicable anti-money-laundering (AML) laws, counter-terrorist financing (CTF) regulations, international gaming license requirements, and any lawful instruction from a competent authority or court.
• Legitimate interests: Processing necessary to protect jjwon's platform security, detect and prevent fraud and bonus abuse, maintain audit logs for dispute resolution, and improve platform functionality — provided such processing does not override your fundamental privacy rights.
• Consent: Processing for optional activities, such as the delivery of promotional offers, marketing communications, or personalised game recommendations, where we have obtained your explicit consent and you retain the right to withdraw that consent at any time without penalty.

jjwon uses the personal data we collect for the following specific purposes:

• Account management: To create, maintain, and secure your jjwon player account, including verifying your identity at registration and at the withdrawal stage through CNIC-based KYC procedures.
• Transaction processing: To process PKR deposits and withdrawals through JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank; to reconcile your wallet balance; and to produce accurate transaction histories accessible from your account dashboard.
• Gaming services delivery: To operate casino games, live dealer tables, crash games, and sports betting markets; to record game session outcomes for audit and dispute resolution; and to apply bonus credits and wagering requirement tracking to your account.
• AML and fraud prevention: To screen player identities and transaction patterns against anti-money-laundering obligations, detect multi-accounting and bonus abuse, and fulfil reporting requirements under our international gaming license.
• Customer support: To respond to your support queries, resolve disputes, and maintain records of communications for quality assurance and compliance purposes.
• Responsible gaming: To monitor for behavioural indicators of problem gambling (such as sudden significant increases in deposit frequency or wager sizes), to enforce self-exclusion and limit settings, and to fulfil the responsible gaming obligations imposed by our licensing authority.
• Platform security: To detect and block unauthorised access attempts, prevent bot activity and script-based manipulation, and maintain the integrity of the jjwon platform for all players.
• Service improvement: To analyse aggregate, anonymised usage data to improve platform performance, game selection, payment method offerings, and the overall player experience for users across Pakistan.
• Marketing communications (with consent): To send you promotional offers, bonus notifications, and platform updates via email or mobile notification — only where you have opted in and until such time as you withdraw consent.

jjwon does not sell or rent your personal data to any third party. We share your data only in the following tightly controlled circumstances:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank receive the minimum transactional data required to process your PKR deposits and withdrawals. These providers operate under their own applicable privacy frameworks and are bound by contractual obligations not to use your data for any purpose beyond transaction processing.
• Game content providers: Licensed third-party game studios receive pseudonymised session identifiers and wager data necessary to operate game rounds and return outcomes to jjwon's platform. They do not receive your full identity data or payment information.
• KYC and AML service providers: jjwon engages accredited identity verification and sanctions screening vendors to process CNIC document verification. These vendors are contractually restricted to using your data exclusively for the purpose of the specific verification task.
• Regulatory and law enforcement authorities: jjwon will disclose personal data to competent regulatory authorities, law enforcement agencies, or courts when required to do so by a valid legal obligation, court order, or licensing authority directive. jjwon will notify the affected player of such disclosure where legally permitted to do so.
• Platform infrastructure providers: Cloud hosting and content delivery providers that process data on jjwon's behalf under data processing agreements that prohibit independent use of your data.
• Professional advisers: Legal, audit, and compliance professionals engaged by jjwon who are bound by professional confidentiality obligations.

Every third party that receives personal data from jjwon is subject to a data processing agreement or equivalent contractual instrument requiring them to protect that data to the same standard applied by jjwon, and to process it solely for the specified purpose.

jjwon uses cookies and similar client-side technologies on jjwon.app. The following cookie categories are in use:

You may manage cookie preferences through your browser's built-in settings. Please note that disabling strictly necessary cookies will prevent you from logging into your jjwon account and accessing platform features. Disabling analytics or marketing cookies will not affect your ability to use the platform.

jjwon retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to the following minimum retention obligations imposed by our international gaming license and applicable AML regulations:

• Account and identity data (including KYC documents): Retained for a minimum of five (5) years from the date of account closure. This is a non-negotiable licensing requirement to support post-closure AML investigations if required.
• Financial transaction records (deposits, withdrawals, wallet history): Retained for a minimum of five (5) years from the date of each transaction, in line with standard financial record-keeping obligations.
• Game session and wager logs: Retained for a minimum of three (3) years from the date of each session, to support dispute resolution, RNG audit obligations, and responsible gaming monitoring.
• Support communications: Retained for three (3) years from the date of the interaction, for quality assurance and dispute evidence purposes.
• Marketing data (consent records and communication logs): Retained for the duration of your active marketing consent plus one (1) year from the date of consent withdrawal.
• Technical and usage logs: Retained for up to twelve (12) months from collection for platform security and fraud detection purposes, after which they are anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard data destruction procedures. Anonymised aggregate data may be retained indefinitely for statistical analysis.

jjwon implements a multi-layered security architecture to protect your personal data from unauthorised access, accidental loss, destruction, or alteration. The following technical and organisational measures are in place:

• Encryption in transit: All data exchanged between your browser or device and jjwon.app is encrypted using TLS 1.3. This applies to every page load, login request, deposit initiation, and support chat message.
• Encryption at rest: Personal and financial data stored in jjwon's databases is encrypted at rest using AES-256 encryption. Database access is restricted to authorised internal systems only, not to individual staff members directly.
• Access controls: Access to systems that hold personal data is restricted on a strict need-to-know basis. All internal access is logged and subject to periodic review. Multi-factor authentication is mandatory for all administrative access.
• CNIC document security: Identity documents submitted during KYC verification are stored in an isolated, access-controlled document vault separate from the main player database, with access restricted to the compliance team only.
• Penetration testing: jjwon's platform and infrastructure undergo regular independent security testing as required by our licensing authority.
• Incident response: In the event of a personal data breach that poses a material risk to affected players, jjwon will notify affected individuals and the relevant licensing authority within 72 hours of becoming aware of the breach, and will publish a platform notice within the same timeframe.

As a jjwon player, you hold the following rights in relation to your personal data. These rights can be exercised by contacting jjwon's support team via live chat or by writing to [email protected] with the subject line "Data Rights Request". jjwon will acknowledge your request within five business days and respond substantively within thirty (30) calendar days:

• Right of access: You have the right to receive a copy of all personal data jjwon holds about you, along with information about how that data is processed and on what legal basis.
• Right to rectification: If any personal data jjwon holds about you is inaccurate or incomplete, you have the right to request that it be corrected or completed without undue delay. For KYC identity data, corrections must be supported by updated documentation.
• Right to erasure ("right to be forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and there is no overriding legal basis for continued processing. Note that jjwon cannot erase data that is subject to mandatory minimum retention obligations under gaming license or AML regulations.
• Right to restrict processing: You may request that jjwon pause certain processing activities — for example, while a dispute about data accuracy is being resolved — without requesting full deletion.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format (such as JSON or CSV), and to have that data transmitted to another data controller where technically feasible.
• Right to object: You have the right to object to processing of your data based on legitimate interests, and to withdraw consent for any consent-based processing at any time.
• Rights related to automated decision-making: jjwon does not make decisions with significant legal effect on players using fully automated processes without human review. If automated screening flags your account for a restriction, a human compliance officer will review the case before any suspension is imposed.

jjwon's platform is strictly restricted to individuals aged 21 years and above. We do not knowingly collect or process personal data from individuals under the age of 21. The 21+ age requirement is enforced through mandatory CNIC-based KYC verification at the withdrawal stage, and through automated age-check routines applied at registration.

If jjwon discovers that personal data has been collected from a player who is under the age of 21, the affected account will be immediately suspended, all funds will be returned to the originating payment method after completion of required AML checks, and all personal data associated with the account will be deleted as soon as the regulatory retention minimum — where applicable — permits.

If you believe that a minor may have registered a jjwon account using your payment method or personal details, please contact jjwon support immediately via live chat. We take under-age gambling extremely seriously and will prioritise the investigation of any such report.

jjwon's platform is operated under an international gaming license. As a result, certain personal data may be processed or stored on servers and by service providers located outside Pakistan. This includes data processed by cloud infrastructure providers, game content studios, and KYC verification services that operate in multiple jurisdictions.

Where personal data is transferred outside Pakistan, jjwon ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy. These safeguards include:

• Contractual data processing agreements incorporating standard privacy clauses binding the receiving party to jjwon's data protection standards;
• Transfer to jurisdictions that maintain adequate data protection frameworks recognised by our licensing authority;
• Technical measures including end-to-end encryption ensuring that data is protected during transit regardless of the jurisdictions through which it passes.

You may request further information about the specific safeguards applicable to any international data transfer involving your personal data by contacting our support team.

jjwon reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When we make material changes — meaning changes that meaningfully affect how we collect, use, or share your personal data — we will provide advance notice of no less than seven (7) days via a prominent notice on jjwon.app and, where practicable, by a notification to your registered email address or mobile number.

Non-material amendments, such as typographical corrections or clarifications that do not alter the substance of any provision, may be made without prior notice and will take effect upon publication.

The effective date displayed at the top of this Policy reflects the date on which the most recently published version came into effect. You are encouraged to review this Policy periodically. Your continued use of jjwon.app following the effective date of any updated Policy constitutes acceptance of the revised terms.

For any questions about this Privacy Policy, to exercise any of the data rights described in Section 10, or to report a privacy concern, please contact the jjwon data team through any of the following channels:

• Live chat: Available 24/7 on jjwon.app with an average response time of three to five minutes. This is the fastest channel for routine privacy queries.
• Email: Write to [email protected] with the subject line "Privacy Request" or "Data Rights Request". jjwon aims to acknowledge all formal data rights requests within five business days and provide a substantive response within thirty (30) calendar days.

To help us process your request efficiently, please include your registered account username and a brief description of your request. For data access or portability requests, we may require you to verify your identity before releasing any personal data.