Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how Truwin ("we", "us", "our" or "the Platform"), accessible at truwin.cam, collects, processes, stores, shares and protects personal information relating to users ("you", "your" or "User") of the Platform and its services.

Truwin is an English-language online betting and casino information platform primarily serving users in Pakistan. We are committed to handling personal data responsibly, transparently and in accordance with applicable data protection principles. This Policy is designed to give you a clear and complete picture of our data practices so that you can make informed decisions about using our Platform.

By accessing or using the Truwin Platform, creating an account, or otherwise providing personal information to us, you confirm that you have read and understood this Privacy Policy and consent to the data practices described herein, where such consent forms the lawful basis for processing. If you do not agree to this Policy, you should discontinue use of the Platform immediately.

2 Definitions

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, CNIC number, IP address, device identifiers, location data and financial information.
• "Processing" means any operation or set of operations performed on Personal Data, whether by automated or manual means, including collection, recording, storage, adaptation, retrieval, use, disclosure, transfer or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For this Policy, Truwin is the Data Controller in respect of Personal Data collected through the Platform.
• "Data Processor" means any third party that processes Personal Data on behalf of Truwin, under contractual instruction.
• "Cookies" means small text files placed on your device by a website to store preference information, session identifiers and analytics data.
• "KYC Data" means identity verification documents and associated information collected as part of the Know Your Customer compliance process, including CNIC or passport copies, proof of address and selfie or liveness verification data.
• "Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, health or medical data, financial account details beyond standard transactional data, or biometric data used for identification purposes.

3 Data Controller

Truwin, operating through the domain truwin.cam, acts as the Data Controller in respect of all Personal Data collected through the Platform. As Data Controller, Truwin is responsible for determining the purposes for which your Personal Data is processed and for ensuring that such processing is lawful, fair and transparent.

Where Truwin engages third-party service providers — for example, payment processing partners, KYC verification providers or analytics services — those parties act as Data Processors under contractual arrangements that require them to process data only on Truwin's instructions and to maintain appropriate security standards. Truwin retains responsibility for ensuring that all such arrangements comply with applicable data protection principles.

4 Data We Collect

Truwin collects Personal Data in several ways, depending on how you interact with the Platform. The categories of data collected include:

4.1 Registration Data

When you create a Truwin account, we collect the information you provide during the registration process, including:

• Full legal name
• Date of birth (to verify minimum age eligibility)
• Email address
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Username and encrypted password
• Preferred currency (including PKR/Rs where supported)

4.2 KYC Verification Data

As part of our identity verification (KYC) obligations, we may collect:

• CNIC (both sides) or passport copy
• Proof of address documentation
• Selfie or liveness verification image
• Payment method verification documentation (referenced as familiar local payment context for Pakistani users, such as Easypaisa or JazzCash account screenshots — not as an endorsement of those providers)

4.3 Transaction Data

We collect records of financial transactions conducted through your account, including deposit amounts, withdrawal requests, bonus transactions, betting activity and gaming history.

4.4 Technical and Usage Data

We automatically collect certain technical data when you access the Platform, including:

• IP address and approximate geolocation derived from IP
• Device type, operating system and browser version
• Pages visited, time spent on the Platform, navigation paths and click behaviour
• Session duration and frequency of visits
• Referral URL (the page from which you navigated to Truwin)

4.5 Communications Data

When you contact our support team via Live Chat, email or any other channel, we retain records of those communications, including the content of messages, timestamps and any attachments provided, for quality assurance and dispute resolution purposes.

5 Lawful Basis for Processing

Truwin processes your Personal Data only where a lawful basis exists for doing so. The applicable lawful bases are:

• Contractual Necessity: Processing required to fulfil our obligations to you under the Terms & Conditions — including account management, transaction processing and service delivery.
• Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering (AML), counter-terrorism financing (CTF), age verification requirements and court orders or lawful requests from competent authorities.
• Legitimate Interests: Processing carried out in pursuit of Truwin's legitimate business interests, including fraud prevention, security monitoring, responsible gambling compliance, platform analytics and service improvement — provided such interests are not overridden by your rights and freedoms.
• Consent: Processing for purposes such as optional marketing communications, where we have obtained your explicit prior consent. You may withdraw consent at any time without affecting the lawfulness of processing based on consent prior to withdrawal.

6 How We Use Your Data

Truwin uses the Personal Data it collects for the following purposes:

• Account administration: Creating, managing and maintaining your user account, including authentication and account recovery.
• Service delivery: Processing deposits, withdrawals, bets, gaming activity, bonus allocations and loyalty rewards.
• Identity and age verification: Fulfilling KYC obligations to confirm your identity, confirm minimum age compliance and verify payment methods.
• Fraud prevention and AML compliance: Monitoring transactions and account activity for signs of fraud, money laundering, bonus abuse or other prohibited conduct.
• Responsible gambling monitoring: Identifying patterns of account behaviour that may indicate problem gambling, in order to trigger appropriate protective interventions in accordance with our Responsible Gambling Policy.
• Customer support: Responding to enquiries, resolving disputes and providing technical assistance.
• Legal compliance: Fulfilling obligations imposed by applicable laws and regulations, including responding to lawful requests from regulatory authorities or law enforcement bodies.
• Platform improvement: Analysing aggregated usage data to improve the functionality, content, design and performance of the Platform.
• Marketing communications: Sending promotional offers, bonus notifications and platform updates where you have opted in or where a legitimate interest applies — always with an easy opt-out mechanism.

7 Data Sharing & Disclosure

Truwin does not sell your Personal Data. We share data only in the following circumstances:

• Service providers and processors: We share data with carefully selected third-party processors — such as payment processing partners, KYC verification providers, fraud detection services and cloud hosting providers — who are contractually obligated to process data only on our instructions and maintain appropriate security standards. Payment method names (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah) are referenced purely as familiar local context for Pakistani users and do not indicate a data-sharing arrangement with those institutions.
• Legal and regulatory authorities: Where required by applicable law, court order or regulatory directive, we may disclose Personal Data to competent authorities. We will notify you of such disclosure where legally permitted to do so.
• Corporate transactions: In the event of a merger, acquisition, reorganisation or sale of assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.
• Responsible gambling bodies: Where required under applicable licensing conditions or where you have enrolled in an external self-exclusion scheme, we may share limited data with responsible gambling programme administrators.

8 Data Retention

Truwin retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal obligations. The following general retention principles apply:

• Active account data: Retained for the duration of your active relationship with Truwin, plus the period required to resolve any outstanding disputes or comply with post-closure legal obligations.
• KYC and identity documents: Retained for a minimum period as required by applicable AML regulations, typically no fewer than five years from the date of account closure or the end of the business relationship.
• Transaction records: Financial transaction records are retained for the period required by applicable financial regulation and taxation law.
• Support communications: Retained for a period sufficient to resolve disputes and support quality assurance, typically no longer than three years from the date of the last communication.
• Technical and usage data: Anonymised or aggregated analytics data may be retained indefinitely; identifiable technical data is retained only as long as operationally necessary for security and fraud monitoring purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with Truwin's data destruction procedures.

9 Security Measures

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

• SSL/TLS encryption for all data transmitted between your device and our servers
• Encryption at rest for sensitive data categories, including KYC documents and financial records
• Two-factor authentication (2FA) options for user account access
• Role-based access controls limiting staff access to Personal Data on a need-to-know basis
• Regular security audits and penetration testing
• Secure password hashing using industry-standard algorithms
• Automated monitoring for anomalous account or transaction activity

10 Cookies & Tracking Technologies

Truwin uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the Platform effectively and to understand how Users interact with it. The categories of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session management cookies that keep you logged in during a visit. These cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: Used to collect anonymised data about how Users navigate the Platform — including which pages are visited most and where errors occur — to help us improve performance and user experience.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences and previously entered information, to provide a more personalised experience on repeat visits.
• Security Cookies: Used to detect and prevent fraud, identify suspicious login patterns and protect Platform integrity.

Most web browsers are configured to accept cookies by default. You may configure your browser to refuse cookies or to alert you when cookies are being set; however, disabling certain cookies may impair your ability to use the Platform fully. Truwin does not deploy aggressive third-party advertising cookies or cross-site tracking for unrelated commercial purposes.

11 International Data Transfers

As an online platform accessible internationally, Truwin may transfer your Personal Data to servers, service providers or affiliated entities located in countries outside Pakistan. Where such transfers occur, Truwin takes steps to ensure that appropriate safeguards are in place to protect your data, including:

• Contractual data protection clauses binding the recipient to privacy standards equivalent to those described in this Policy
• Transfer only to jurisdictions that maintain recognised data protection standards
• Limiting transferred data to the minimum necessary for the specific processing purpose

By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in countries other than Pakistan, and you consent to such transfers where they are undertaken in accordance with the safeguards described above.

12 Your Rights

Subject to applicable law, you hold the following rights in respect of your Personal Data held by Truwin. To exercise any of these rights, please contact us using the details in Section 16.

13 Minors & Age Restriction

The Truwin Platform is strictly intended for adults aged 18 years or above — or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect, process or store Personal Data relating to individuals below this age threshold.

If we become aware that Personal Data has been submitted by or on behalf of a minor, we will take immediate steps to delete that data and close the associated account without delay. If you believe that a minor has registered on or submitted data through the Platform, please contact our support team immediately at [email protected] (plain text only).

Account holders are responsible for ensuring that devices used to access the Platform are not accessible to minors. We recommend enabling parental control software on shared devices as an additional precaution.

14 Third-Party Services

The Truwin Platform may reference or interact with third-party services, including payment processors and KYC verification providers. These third parties operate under their own privacy policies, which Truwin does not control. The mention of payment references familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — does not imply a data-sharing partnership, endorsement of gambling, or any affiliation between those institutions and Truwin.

Where Truwin links to or facilitates integration with any third-party platform or service, you are encouraged to review the privacy policy of that third party before providing any personal information through their services. Truwin accepts no responsibility or liability for the data practices of independent third parties.

15 Changes to This Policy

Truwin reserves the right to update or modify this Privacy Policy at any time. Where changes are material — for example, changes to the categories of data collected, the purposes for which data is used, or the rights available to you — we will provide advance notice by displaying a prominent notice on the Platform or by communicating directly to your registered email address.

The date of the most recent revision is displayed at the top of this page. Continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you should discontinue use of the Platform and close your account before the revised version takes effect.

16 Contact Us

For any questions, concerns or requests relating to this Privacy Policy or to the handling of your Personal Data, please contact the Truwin data team using the details below: