jjwen Privacy Policy

This Privacy Policy ("Policy") is issued by jjwen ("we", "us", "our"), the operator of the online casino and sports betting platform accessible at https://jjwen.net ("Platform"). It applies to all individuals who visit, register on, or otherwise interact with the jjwen Platform, including Pakistani players accessing the site from any device or location.

jjwen is committed to protecting the personal data of every player on our platform. We handle your data in accordance with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, and the requirement for a lawful basis for every processing activity we undertake.

This Policy should be read alongside jjwen's Terms & Conditions and our Responsible Gaming policy, both of which form part of the binding agreement between you and jjwen.

jjwen collects personal data through a variety of channels — directly from you during registration and account management, automatically through your use of the Platform, and occasionally from trusted third-party sources such as payment processors and KYC verification providers. Below is a comprehensive overview of the categories of personal data we collect:

2.1 Identity & Registration Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (used to verify the mandatory 21+ age requirement)
• CNIC number, passport number, or driver's licence number
• Nationality and country of residence
• Gender (optional, collected for responsible gaming profiling purposes)

2.2 Contact Data

• Email address (primary communication and account security channel)
• Mobile phone number (used for OTP verification and JazzCash / EasyPaisa payment processing)
• Residential address including city (e.g., Karachi, Lahore, Islamabad, Faisalabad) and postal code

2.3 Financial & Payment Data

• JazzCash or EasyPaisa mobile account number
• Bank account details (HBL, UBL, Meezan Bank, or other Pakistani bank) where used for deposits or withdrawals
• Raast ID where applicable
• Transaction history including deposit amounts, withdrawal requests, wagering activity, and bonus claims — all denominated in PKR

2.4 Technical & Usage Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Session duration, pages visited, and navigation patterns on the Platform
• Game rounds played, bet amounts, and win/loss records
• Login timestamps and authentication logs

2.5 KYC Verification Documents

• Scanned or photographed copies of government-issued photo ID (CNIC front and back, passport bio page, or driver's licence)
• Proof of address documents (utility bill, bank statement dated within 90 days)
• Selfie photographs taken during liveness verification, where required

jjwen processes your personal data only where a valid legal basis exists. The following table outlines the primary legal bases we rely upon for each category of processing activity:

jjwen uses the personal data we collect for the following specific purposes. We do not use your data in any manner inconsistent with the purpose for which it was originally collected, and we do not engage in automated decision-making that produces legal or similarly significant effects without human oversight.

• Account Administration: Maintaining your player account, processing login requests, enabling secure access, and updating account settings as requested by you.
• Payment Processing: Facilitating PKR deposits via JazzCash, EasyPaisa, Raast, HBL, UBL, and Meezan Bank, and processing withdrawal requests to your registered payment method.
• Identity & Age Verification: Confirming that all players on the jjwen platform meet the mandatory minimum age of 21 years and that their identity matches the details provided at registration.
• Regulatory Compliance: Meeting anti-money laundering (AML) obligations, counter-terrorism financing (CTF) requirements, and any other applicable legal and regulatory obligations.
• Responsible Gaming: Monitoring wagering behaviour to identify potential signs of problem gambling, applying self-imposed limits, and proactively reaching out to players whose activity patterns suggest they may benefit from responsible gaming support.
• Customer Support: Responding to enquiries, resolving disputes, processing complaints, and providing 24/7 assistance across all support channels.
• Security & Fraud Prevention: Detecting and preventing unauthorised account access, fraudulent transactions, bonus abuse, and multi-accounting activity that violates jjwen's Terms & Conditions.
• Marketing Communications: Where you have provided consent, sending personalised promotions, bonus offers, PSL season campaigns, and platform updates via email or SMS. You may opt out at any time via your account dashboard or by contacting support.
• Platform Improvement: Analysing aggregated usage data to improve game selection, payment flow, site performance, and the overall player experience for users across Pakistan.

jjwen does not sell, rent, or trade your personal data to any third party for commercial purposes. Period. We share personal data only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose.

5.1 Payment Processors

To process deposits and withdrawals, jjwen shares relevant payment data with JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and other integrated payment partners. These processors receive only the data required to execute your specific transaction and are prohibited from using it for any other purpose.

5.2 KYC & Identity Verification Providers

jjwen partners with specialist KYC technology providers to verify the identity and age of players. Your identity documents and verification selfies are processed by these providers under strict data processing agreements that require them to maintain confidentiality, limit data use to verification purposes only, and comply with applicable data protection law.

5.3 Fraud Prevention & AML Screening

We share data with fraud detection and AML screening services to identify suspicious activity and comply with our anti-money laundering obligations. This may include sharing data with financial intelligence databases operated by regulated entities.

5.4 Regulatory & Legal Authorities

jjwen will disclose personal data to competent authorities — including regulators, law enforcement agencies, and courts — where required to do so by applicable law, court order, or legitimate regulatory request. In all such cases, we will seek to notify you of the disclosure unless we are legally prohibited from doing so.

5.5 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving the jjwen platform, your personal data may be transferred to the acquiring entity, subject to that entity honouring the commitments made in this Privacy Policy or providing you with notice and the opportunity to object.

The jjwen Platform uses cookies and similar tracking technologies to provide core functionality, remember your preferences, and analyse how the Platform is used. By continuing to use the jjwen Platform, you consent to the use of cookies as described in this section.

You may manage or disable non-essential cookies at any time through your browser settings or via the cookie preference centre accessible from the Platform footer. Note that disabling strictly necessary cookies will affect your ability to log in and use core Platform features.

jjwen retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law or regulatory obligation. The following retention periods apply as a general guide:

• Active Account Data: Retained for the lifetime of your jjwen Account plus a minimum of five years following Account closure, in compliance with standard AML and financial record-keeping requirements.
• KYC Identity Documents: Retained for a minimum of five years from the date of verification or Account closure (whichever is later), as required under applicable anti-money laundering regulations.
• Transaction & Wagering Records: Retained for a minimum of five years following the date of the transaction, to support regulatory audit requirements and dispute resolution.
• Customer Support Records: Retained for three years following the resolution of the relevant support case, to support quality assurance and dispute handling.
• Marketing Consent Records: Retained for as long as you remain an active player plus three years, to evidence the basis on which marketing communications were sent.
• Technical Logs & Access Records: Retained for a maximum of twelve months, after which they are deleted or anonymised unless required for an ongoing investigation.

Upon expiry of the applicable retention period, jjwen will securely delete or anonymise your personal data in a manner that ensures it cannot be reconstructed or attributed back to you.

jjwen implements a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security programme includes the following measures:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the jjwen Platform is encrypted in transit using industry-standard TLS protocols. This applies to all pages of the Platform, not just payment pages.
• Encryption at Rest: All sensitive personal data stored on jjwen's servers — including identity documents, payment information, and account credentials — is encrypted at rest using AES-256 encryption.
• Password Hashing: Account passwords are never stored in plaintext. They are hashed using a modern, computationally expensive hashing algorithm (bcrypt) with per-user salting, ensuring that even in the event of a data breach, raw passwords cannot be recovered.
• Two-Factor Authentication (2FA): jjwen strongly recommends enabling 2FA on your account. When enabled, access requires both your password and a time-sensitive one-time code sent to your registered mobile number.
• Access Controls: Access to player personal data within jjwen's internal systems is strictly role-based. Only staff members with a demonstrable operational need are granted access, and all access is logged and audited.
• Regular Security Audits: jjwen conducts periodic internal and third-party security assessments, including penetration testing, to identify and remediate vulnerabilities before they can be exploited.

As a jjwen player, you hold meaningful rights over your personal data. jjwen is committed to honouring these rights promptly and without unnecessary obstruction. The following rights are available to you:

• Right of Access: You may request a copy of all personal data jjwen holds about you at any time. We will provide this in a structured, commonly used, machine-readable format within 30 days of receiving a verified request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct or update it. Simple corrections (e.g., updating your contact number) can be made directly within your account dashboard.
• Right to Erasure: You may request the deletion of your personal data where: (a) the data is no longer necessary for the purpose it was collected; (b) you withdraw consent and no other legal basis applies; or (c) the data has been processed unlawfully. Note that erasure requests may be subject to overriding legal retention obligations — for example, AML regulations require us to retain certain financial records for a minimum of five years.
• Right to Restrict Processing: You may request that jjwen restrict the processing of your data while a rectification or objection request is being assessed.
• Right to Data Portability: You may request that jjwen provide your personal data in a portable format suitable for transfer to another service provider.
• Right to Object: You may object to the processing of your personal data where jjwen relies on legitimate interests as its legal basis. You may also object at any time to the processing of your data for direct marketing purposes.
• Right to Withdraw Consent: Where jjwen processes your data on the basis of consent (e.g., for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact jjwen's support team at [email protected]. We may ask you to verify your identity before processing a data rights request, to ensure that personal data is not disclosed to or modified by an unauthorised party.

Age verification is enforced at the point of registration and prior to first withdrawal. Should jjwen become aware that personal data has been collected from an individual under the age of 21 — whether through a failed age verification check or other means — we will immediately suspend the relevant Account, delete all associated personal data, and return any real-money balance to the source payment method where technically possible.

If you are a parent or guardian and you believe your child may have accessed the jjwen Platform, please contact our support team immediately at [email protected]. We will investigate and take appropriate action within one business day.

jjwen's primary infrastructure is hosted in data centres that maintain high standards of physical and digital security. Some of our third-party service providers — including KYC verification partners and cloud infrastructure providers — may process your personal data in jurisdictions outside Pakistan.

Where personal data is transferred internationally, jjwen ensures that appropriate safeguards are in place to provide a level of protection equivalent to that afforded under internationally recognised data protection standards. These safeguards may include:

• Standard contractual clauses approved by a recognised data protection authority, incorporated into our data processing agreements with third-party providers.
• Transfers to jurisdictions that have been assessed to provide an adequate level of data protection by the relevant regulatory framework.
• Binding corporate rules where data is transferred between entities within the same corporate group.

You may request further information about the specific safeguards in place for any given international transfer by contacting jjwen's support team.

jjwen reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page.
• Display a prominent notice on the jjwen Platform informing active players of the update.
• Where the changes are significant and affect how we process data you have already provided, send a notification to your registered email address with a summary of the key changes.

Your continued use of the jjwen Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the updated Policy, you should cease using the Platform and request Account closure. The most current version of this Privacy Policy is always available at https://jjwen.net/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or jjwen's data processing practices, our dedicated privacy support team is available 24 hours a day, seven days a week.

• Email: [email protected]
• Live Chat: Available within the Platform after logging in to your Account.
• Response Time: Privacy-related requests are acknowledged within 24 hours and resolved within 30 calendar days.

For data rights requests (access, erasure, portability, etc.), please include your registered email address, the nature of your request, and sufficient information for us to verify your identity. All requests are handled confidentially by jjwen's compliance team.