Privacy Policy

This Privacy Policy ("Policy") is published by jjwn ("jjwn", "we", "us", "our"), the operator of the online betting and casino platform accessible at https://jjwn.cam (the "Platform"). This Policy explains how we collect, use, process, store, share and protect personal data relating to users ("you", "your") of the Platform.

jjwn is an English-language online betting and casino information platform targeting the Pakistan market, serving adult users across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and beyond. We take your privacy seriously and have designed our data practices to be transparent, proportionate and respectful of your rights.

By accessing or using the Platform — including registering an account, making a deposit or placing a bet — you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the Platform.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information that identifies or could reasonably be used to identify a living natural person, directly or indirectly.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure or deletion.
• "Data Controller" means jjwn, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of jjwn under a data processing agreement.
• "KYC Data" means identity verification documents and associated personal information submitted as part of the Know Your Customer process.
• "Cookies" means small text files placed on your device by the Platform to enable functionality and analytics as described in Section 10.
• "Account" means the registered user account you hold on the Platform.
• "Platform" means the jjwn website at https://jjwn.cam and all associated services.

jjwn acts as the Data Controller for Personal Data collected and processed through the Platform. As Data Controller, jjwn is responsible for determining the purposes for which your data is used and ensuring that appropriate safeguards are in place.

Where jjwn engages third-party service providers (Data Processors) to assist with platform operations, such parties are bound by data processing agreements requiring them to handle your data only on jjwn's instructions and in accordance with applicable data protection obligations.

jjwn collects and processes the following categories of Personal Data, depending on the nature of your interaction with the Platform:

We do not intentionally collect sensitive special-category data (such as racial or ethnic origin, religious beliefs, health data or biometric data) through the Platform. Where such data is incidentally provided — for example, in the context of a responsible gambling assessment — it is handled with additional care and used only for the stated purpose.

jjwn collects Personal Data through the following channels:

• Direct submission: Information you provide when completing account registration, KYC verification, support requests or any other forms on the Platform;
• Automated collection: Technical and usage data collected automatically through cookies, server logs and analytics tools when you access the Platform;
• Third-party sources: Identity verification data from third-party KYC/AML service providers; fraud screening data from risk management partners; payment transaction confirmation data from payment processors;
• Public sources: Publicly available information used to supplement identity verification where applicable under AML obligations.

jjwn processes your Personal Data only where a lawful basis exists for doing so. The following table sets out the primary purposes of data processing and the corresponding legal basis:

jjwn does not sell, rent or trade your Personal Data to any third party for their own commercial purposes. We may share your Personal Data with third parties only in the following circumstances:

• Service Providers (Data Processors): Third-party vendors who assist in operating the Platform, including KYC/AML verification providers, payment processors, IT infrastructure and hosting providers, fraud screening services, and customer support technology providers. All such parties process data on jjwn's behalf under binding data processing agreements;
• Regulatory and Legal Authorities: Where required by applicable law, court order, licensing authority requirement, or where we have a good-faith belief that disclosure is necessary to protect our legal rights, prevent fraud or respond to an emergency involving safety;
• Responsible Gambling Partners: Where you enrol in a self-exclusion scheme or request referral to a responsible gambling support resource, we may share relevant account data with the relevant programme operators as necessary to enforce your exclusion;
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets, your Personal Data may be transferred to the successor entity, subject to equivalent data protection obligations;
• With Your Consent: In any other circumstances where you have provided explicit prior consent to the specific sharing arrangement.

jjwn retains your Personal Data for no longer than is necessary for the purposes for which it was collected, or as required by applicable law or licensing obligations. The following general retention guidelines apply:

• Account and Identity Data: Retained for the duration of your active Account relationship with jjwn, plus a minimum period of five (5) years following account closure, in accordance with standard AML/KYC record-keeping requirements. This period may be extended where required by applicable licensing authority rules or ongoing legal proceedings;
• Financial Transaction Data: Retained for a minimum of five (5) years following the transaction date, in compliance with anti-money-laundering obligations;
• Communications and Support Data: Retained for a period of three (3) years from the date of the communication, unless the matter relates to an ongoing dispute, legal proceeding or compliance investigation;
• Technical and Usage Data: Typically retained in anonymised or aggregated form for platform analytics purposes. Non-anonymised technical data is retained for a maximum of twelve (12) months in most cases;
• Marketing Preferences: Retained until you withdraw consent or request deletion, subject to any minimum retention periods imposed by applicable law.

Following the expiry of the applicable retention period, Personal Data will be securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

Subject to applicable law and any overriding legal obligations on jjwn, you have the following rights in respect of your Personal Data:

jjwn uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, maintain session security and gather anonymised analytics data to improve the user experience.

The categories of cookies we use include:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, security tokens and load-balancing cookies. These cannot be disabled without breaking core Platform functionality;
• Functional Cookies: Remember your preferences such as language, display settings and region to personalise your experience on return visits;
• Analytics Cookies: Collect aggregated, anonymised data about how users navigate the Platform, which pages are most visited and where users encounter issues. This data helps us improve the Platform;
• Marketing Cookies: Used only where you have consented to receive promotional communications. These may track whether you have opened or interacted with marketing messages from jjwn.

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. However, disabling strictly necessary cookies will impair your ability to use the Platform. Disabling analytics cookies does not affect your ability to bet or play.

jjwn operates internationally, and your Personal Data may be transferred to, stored in or processed in countries outside Pakistan. Where such transfers occur, jjwn takes steps to ensure that appropriate safeguards are in place to protect your data to a standard consistent with this Policy and applicable data protection law.

Such safeguards may include contractual clauses binding recipient parties to equivalent data protection standards, or transfers to jurisdictions where the licensing authority's data protection requirements provide an adequate level of protection for personal data.

The Platform is strictly intended for adults aged 18 years and above, or the higher minimum age required by the operator's licensing jurisdiction. jjwn does not knowingly collect Personal Data from individuals under the age of 18.

If jjwn becomes aware that Personal Data has been collected from a person under the minimum age, that Account will be immediately suspended and the data will be deleted in accordance with applicable requirements. Any funds deposited by a minor will be handled in accordance with the applicable regulatory and legal requirements.

Parents and guardians are strongly encouraged to install parental control software on devices that may be accessed by minors, to prevent access to gambling platforms including jjwn. If you believe a minor in your household has accessed the Platform, please contact jjwn Support immediately.

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

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encrypted storage of sensitive personal and financial data at rest;
• Role-based access controls limiting staff access to Personal Data on a strict need-to-know basis;
• Regular security assessments and vulnerability scanning of Platform infrastructure;
• Two-factor authentication options for user accounts;
• Secure, audited processes for handling KYC documents and source-of-funds submissions;
• Incident response procedures for detecting, assessing and notifying affected users of data breaches where required by applicable law.

While jjwn takes all reasonable steps to protect your data, no internet-based system is completely secure. You are responsible for maintaining the security of your Account credentials and should notify us immediately if you suspect any unauthorised access.

The Platform may contain references to third-party services or payment providers — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — mentioned only as contextual information about Pakistani payment infrastructure. These providers operate under their own privacy policies and data practices, which are entirely independent of jjwn.

jjwn is not responsible for the privacy practices or content of any third-party service providers or platforms referenced on or accessible through the Platform. We encourage you to review the privacy policies of any third-party service you interact with.

jjwn reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or Platform functionality. Material changes will be communicated to registered users via their registered email address or through a prominent notice on the Platform prior to the changes taking effect.

The "Effective Date" shown at the top of this Policy indicates the date of the most recent revision. We recommend reviewing this Policy periodically. Your continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Policy.

If you do not accept a revised Privacy Policy, you must discontinue use of the Platform and contact jjwn Support to request account closure and deletion of your data to the extent legally permissible.

For any questions, concerns or requests relating to this Privacy Policy or the handling of your Personal Data, please contact jjwn's support team. All contact details are provided as plain text only and are not clickable links.

If you are not satisfied with our response to a privacy concern, you may have the right to lodge a complaint with a relevant data protection authority in your jurisdiction. jjwn will cooperate with any such regulatory process.