jjwin2 Privacy Policy — How We Handle Your Personal Data

1 Introduction

This Privacy Policy ("Policy") describes how jjwin2 ("Platform", "we", "us", "our"), accessible at https://jjwin2.cam, collects, processes, stores, protects and discloses personal data in connection with your access to and use of the jjwin2 website and all associated services.

jjwin2 is an English-language online gaming information and entertainment platform serving Pakistani audiences. We respect the privacy of every user — from Karachi and Lahore to Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — and are committed to handling personal data transparently, securely and in accordance with applicable data protection principles.

By accessing or using the Platform, you acknowledge that you have read this Privacy Policy and agree to the data practices described herein. This Policy forms part of the jjwin2 Terms & Conditions and should be read in conjunction with that document.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, CNIC number, IP address, device identifiers and transaction history.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" — jjwin2, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" — any third party that processes Personal Data on behalf of jjwin2 in accordance with our instructions and this Policy.
• "KYC" — Know Your Customer; identity verification procedures required for compliance purposes.
• "AML" — Anti-Money Laundering; regulatory obligations requiring monitoring and reporting of suspicious financial activity.
• "Cookie" — a small data file placed on your device by the Platform to enable certain features and collect usage data.
• "User" — any individual who accesses the Platform, whether as a registered account holder or unregistered visitor.

3 Data We Collect

jjwin2 collects Personal Data through three primary channels: data you provide directly, data collected automatically through your use of the Platform, and data received from third parties in specific circumstances.

When you access the Platform, the following data may be collected automatically:

• AutoIP address — used for geolocation context, fraud detection and security logging;
• AutoDevice information — browser type, operating system, screen resolution, device model;
• AutoUsage data — pages visited, session duration, click patterns, feature interactions;
• AutoLog files — server-side access logs including timestamps, request paths and HTTP response codes;
• AutoCookie data — session tokens, preference identifiers and analytics identifiers (see Section 9).

In limited circumstances, jjwin2 may receive Personal Data from third parties, including: identity verification service providers conducting KYC checks; payment processing partners confirming transaction status; and fraud-detection services flagging suspicious activity patterns. Data received from third parties is handled in accordance with this Policy and is not used beyond its stated purpose.

4 Lawful Basis for Processing

jjwin2 processes Personal Data on one or more of the following lawful bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions — including account creation, platform access and transaction processing;
• Legal Obligation: Processing required to comply with applicable law, including KYC/AML obligations, data retention requirements and law enforcement disclosures;
• Legitimate Interests: Processing conducted to pursue our legitimate business interests, including fraud prevention, platform security, abuse detection and service improvement — provided such interests are not overridden by your rights;
• Consent: Where you have provided specific, informed and freely given consent, such as for optional marketing communications or certain non-essential cookie categories.

5 How We Use Your Data

jjwin2 uses the Personal Data we collect for the following specific purposes:

To create, verify, maintain and secure your user account. This includes processing registration data, authenticating login sessions, managing account preferences and facilitating account recovery procedures.

To deliver the features and services of jjwin2, including displaying personalised content, processing PKR wallet transactions, providing sports betting market context, managing game access and operating responsible gambling tools such as deposit limits and self-exclusion.

To verify your identity and age in accordance with KYC requirements. To conduct AML screening, monitor transactions for suspicious patterns and comply with applicable regulatory obligations. KYC data may include your CNIC number, date of birth and identity document scans.

To respond to your queries, complaints and support requests through email and live chat channels. Support communications may be retained for quality assurance and training purposes for a period consistent with our retention schedule.

To detect and prevent fraud, account compromise, money laundering and other prohibited activities. This includes IP-based geolocation, device fingerprinting and behavioural pattern analysis.

To analyse aggregated and anonymised usage data to improve Platform features, fix technical issues and optimise the user experience for Pakistani audiences — including mobile performance optimisation for Android and iOS browsers commonly used across Pakistan.

To meet any applicable legal obligations including court orders, regulatory directions and law enforcement requests. jjwin2 will only disclose Personal Data to public authorities when legally required to do so and, where permissible, will notify affected users.

6 Data Sharing & Disclosure

jjwin2 does not sell, rent or trade your Personal Data to third parties for commercial marketing purposes. Personal Data may be shared in the following limited circumstances only:

• Service Providers and Data Processors: Third-party vendors contracted by jjwin2 to provide platform infrastructure, payment processing, identity verification, fraud detection, customer support tooling and analytics. These processors are contractually bound to handle data only as instructed and in accordance with applicable data protection standards.
• Payment Partners: Financial transaction data (not including full card numbers or bank credentials) may be shared with payment processing partners as necessary to facilitate deposits and withdrawals. Familiar Pakistani payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah may process transaction data independently subject to their own privacy policies. Their mention does not imply an endorsement of gambling services.
• Legal and Regulatory Authorities: Data may be disclosed to law enforcement, regulatory authorities or courts where we are legally required to do so, including in response to valid court orders or mandatory regulatory reporting obligations.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of jjwin2 or its assets, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.
• With Your Consent: In any other circumstances where you have provided explicit, informed consent for the specific sharing purpose.

7 Data Retention

jjwin2 retains Personal Data only for as long as is necessary for the purposes set out in this Policy or as required by applicable law. The following general retention principles apply:

• Active Account Data: Retained for the duration of the account relationship plus a reasonable wind-down period following account closure;
• KYC and AML Data: Retained for the period required by applicable anti-money laundering regulations, which may extend several years beyond account closure;
• Transaction Records: Financial transaction records are retained for the period required by applicable financial record-keeping and tax obligations;
• Support Communications: Retained for a period proportionate to the nature of the support issue, typically up to 24 months from resolution;
• Security Logs: Server access logs and security event records may be retained for up to 12 months for incident investigation purposes;
• Cookie and Analytics Data: Anonymised analytics data may be retained indefinitely in aggregated form; individual-level cookie data expires per the cookie's defined lifespan.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised. Where deletion is not immediately technically feasible, data will be placed in quarantine pending scheduled destruction.

8 Security Measures

jjwin2 implements a range of technical and organisational security measures to protect Personal Data against unauthorised access, disclosure, alteration and destruction. These measures include:

• TLS/SSL Encryption: All data transmitted between your device and our servers is encrypted using current-generation TLS protocols;
• Password Hashing: Account passwords are stored using industry-standard one-way cryptographic hashing algorithms — we do not store plaintext passwords;
• Access Controls: Internal access to Personal Data is restricted on a need-to-know basis, with role-based access controls and audit logging;
• Intrusion Detection: Network-level monitoring and intrusion detection systems are in place to identify and respond to anomalous activity;
• Vulnerability Management: Regular security assessments and patching cycles are applied to Platform infrastructure;
• Incident Response: A documented incident response procedure is in place to contain, investigate and notify in the event of a confirmed data breach.

9 Cookies & Tracking Technologies

jjwin2 uses cookies and similar technologies (including local storage and session tokens) to operate the Platform, remember your preferences and analyse usage patterns. Cookies are small text files placed on your device by the Platform.

• Strictly Necessary Cookies: Essential for Platform operation — including session authentication tokens, security cookies and user preference storage. Cannot be disabled without affecting core functionality;
• Performance / Analytics Cookies: Collect anonymised data about how users interact with the Platform — pages visited, errors encountered, session duration. Used to improve Platform performance;
• Functionality Cookies: Remember your preferences and settings — such as language preference, display options and responsible gambling limit configurations;
• Security Cookies: Support fraud prevention measures including session integrity verification and anomalous login detection.

You can manage or disable non-essential cookies through your browser's privacy settings. Please note that disabling strictly necessary cookies may impair core Platform functionality including account login and session management. Instructions for managing cookies vary by browser — consult your browser's help documentation for guidance.

10 Payment Data & PKR Transactions

Financial transaction data processed through jjwin2 is subject to the following specific provisions:

• Scope of Payment Data Collected: jjwin2 collects transaction amounts (denominated in PKR), payment method category, transaction timestamps and reference identifiers. Full bank account numbers, full card numbers and wallet PINs are not stored on jjwin2 systems;
• Payment Processor Handling: Payment processing is handled by authorised third-party payment processors. These processors are contractually bound to applicable payment security standards;
• Pakistani Payment References: Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced on the Platform as familiar Pakistani payment methods. Where transactions are processed via these providers, those providers' own privacy policies and terms apply independently. None of these providers endorses or supports gambling services;
• AML Monitoring: Transaction data is subject to AML monitoring procedures. Unusual transaction patterns may trigger additional verification requests or regulatory reporting as required by applicable law.

11 Your Rights as a Data Subject

As a user of jjwin2, you hold certain rights with respect to your Personal Data. These rights are subject to applicable data protection law and, in certain cases, to legal retention obligations that may limit their scope.

To exercise any of the rights listed above, please contact us at the details provided in Section 14. We will respond to verified data requests within a reasonable timeframe (typically 30 days from receipt). We may require identity verification before processing certain requests to protect against fraudulent access to other users' data.

12 Minors & Age Policy

jjwin2 is strictly an adults-only platform. We do not knowingly collect, process or retain Personal Data from individuals under the age of 18 years — or the higher minimum age required by the applicable operator's licence jurisdiction.

If we discover or have reasonable grounds to believe that Personal Data has been collected from an individual who is underage, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe your child has provided Personal Data to jjwin2 without your consent, please contact us immediately at [email protected] with the account details and we will investigate and act promptly.

Age verification (as part of KYC procedures) may be required at any time during the account lifecycle. Failure to complete age verification will result in account restrictions until verification is confirmed.

13 Changes to This Privacy Policy

jjwin2 reserves the right to update or amend this Privacy Policy at any time to reflect changes in data practices, legal obligations or Platform features. When material changes are made, we will:

• Update the "Last Updated" date at the top of this Policy;
• Where feasible, notify registered users via email or in-Platform notification;
• Publish the updated Policy at https://jjwin2.cam/privacy-policy.

Your continued use of the Platform following the publication of an updated Policy constitutes your acceptance of the revised terms. We recommend reviewing this Policy periodically. If you do not accept the updated Policy, you must cease using the Platform and may close your account in accordance with the procedures set out in our Terms & Conditions.

14 Contact Us

For any questions, concerns or requests related to this Privacy Policy — including data subject rights requests, consent withdrawal or data breach reporting — please contact the jjwin2 data team using the details below. All correspondence is handled in English. We aim to respond to privacy-related enquiries within a reasonable timeframe and no later than 30 calendar days from receipt of a verified request.

For general platform queries unrelated to privacy, please visit our FAQ page or review our Terms & Conditions.