Privacy Policy — How winb Collects, Uses, and Protects Your Data

01 Introduction and Scope

This Privacy Policy ("Policy") describes how winb ("winb", "we", "us", "our") collects, processes, stores, and shares personal information about individuals ("you", "Player", "User") who access or use the winb Platform at winb.ws, including all associated subdomains, mobile-optimised pages, and ancillary services (collectively, the "Platform").

This Policy applies to all personal data processed in connection with your registration, use of betting and casino services, payment processing, customer support interactions, and any other engagement with the winb Platform. It should be read alongside winb's Terms and Conditions and Responsible Gaming Policy, both of which are available on the Platform.

By creating a winb account, making a deposit, placing a bet, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy 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 discontinue use of the Platform immediately.

02 Information We Collect

winb collects the following categories of personal information in the course of providing its services:

2.1 Identity and Registration Data

• Full legal name as it appears on a government-issued identification document.
• Date of birth (used to verify that you meet the 21+ age requirement).
• Residential address, including city, district, and postal code.
• Nationality and country of residence.
• Mobile telephone number.
• Email address used for account correspondence.
• Username and hashed password.

2.2 Identity Verification (KYC) Documents

• Copies of government-issued photo ID (National ID card, passport, or driving licence).
• Proof of address documents (utility bills, bank statements, or similar).
• Proof of payment method (screenshots or confirmations from bKash, Nagad, Rocket, or bank accounts).
• Selfie photographs where required for identity confirmation.

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records including amounts, timestamps, and payment method identifiers.
• Mobile financial service account references (bKash, Nagad, Rocket, Upay mobile numbers).
• Bank account details where applicable (Dutch-Bangla Bank, BRAC Bank, and others).
• Card type and partial card number where Visa or Mastercard is used.
• Account balance history and bonus credit records.

2.4 Betting and Gaming Activity Data

• Bets placed, including sport, market, selection, odds, stake, and settlement outcome.
• Casino game sessions including game title, provider, session duration, wagered amounts, and results.
• Bonus usage records and wagering requirement progress.
• Responsible gaming tool settings including deposit limits, session limits, and self-exclusion status.

2.5 Technical and Device Data

• IP address at time of account creation, login, deposit, and withdrawal.
• Device type, operating system, and browser type and version.
• Unique device identifiers where applicable.
• Session timestamps, page navigation paths, and click interaction data.
• Geolocation data (country and city level, derived from IP address).

2.6 Communications Data

• Content of live chat conversations with the winb support team.
• Email correspondence sent to or received from winb's support address.
• Feedback, complaints, and dispute records.

03 How We Collect Your Information

3.1 Information You Provide Directly

The majority of personal data winb holds about you is information you have provided voluntarily during the account registration process, when completing identity verification, when making deposits or requesting withdrawals, and when contacting the support team. You are not legally obligated to provide this information; however, failure to provide certain mandatory data fields will prevent winb from creating or maintaining your account.

3.2 Information Collected Automatically

When you access the winb Platform, certain technical information is collected automatically by our systems. This includes your IP address, the type of device and browser you are using, pages visited, and session duration. This information is collected using server logs, cookies, and similar tracking mechanisms described in Section 7 of this Policy.

3.3 Information from Third Parties

winb may receive information about you from third-party sources in specific circumstances, including:

• From payment service providers such as bKash, Nagad, and Rocket, in connection with payment verification and fraud screening.
• From identity verification service providers engaged to assist with KYC compliance.
• From fraud prevention and risk management databases used to screen for known fraudulent patterns.
• From sports data providers, in connection with the settlement of sports betting markets.

04 How We Use Your Information

winb uses the personal data it collects for the following purposes:

4.1 Account Management and Service Delivery

To create and maintain your winb account, process your deposits and withdrawals, display your account balance and transaction history, deliver the betting and casino services you have requested, and communicate with you about your account activity.

4.2 Identity Verification and Compliance

To verify your identity and age in accordance with our KYC policy, to prevent underage gambling in compliance with our strict 21+ policy, and to satisfy anti-money laundering obligations applicable to online gaming platforms operating in the Bangladesh market.

4.3 Fraud Prevention and Security

To detect, investigate, and prevent fraudulent transactions, account takeovers, bonus abuse, and other prohibited activities. winb's security systems monitor account activity in real time and may flag unusual patterns for manual review by our compliance team.

4.4 Responsible Gaming

To monitor your gaming activity for indicators of problem gambling behaviour, to enforce deposit limits, session limits, and self-exclusion arrangements that you have put in place, and to fulfil winb's duty of care obligations towards players who may be experiencing difficulty managing their gambling activity.

4.5 Customer Support

To respond to your enquiries, resolve account disputes, investigate complaints, and maintain records of communications for quality assurance and training purposes.

4.6 Platform Improvement and Analytics

To analyse aggregated usage patterns across the Platform in order to improve functionality, identify technical issues, optimise the user experience for players in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, and across Bangladesh, and to develop new features and product offerings.

4.7 Marketing Communications

To send you promotional communications about winb bonuses, new games, seasonal offers (such as BPL and IPL cricket promotions), and other relevant updates — where you have provided consent for such communications. You may withdraw consent for marketing messages at any time by contacting the support team.

05 Legal Bases for Processing

winb processes your personal data on the following legal grounds, consistent with internationally recognised data protection principles:

• Contractual Necessity: Processing required to perform the contract between you and winb — including account creation, payment processing, bet settlement, and customer support.
• Legal Obligation: Processing required to comply with applicable anti-money laundering requirements, age verification obligations, and other legal duties applicable to online gaming platforms.
• Legitimate Interests: Processing carried out for winb's legitimate business interests where those interests are not overridden by your privacy rights — including fraud detection, security monitoring, platform analytics, and business continuity.
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent — primarily in relation to marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

06 Sharing Your Information

6.1 Service Providers

winb shares personal data with carefully selected third-party service providers who assist in operating the Platform. These providers are contractually bound to process data only on winb's instructions, to maintain appropriate security standards, and not to use the data for their own independent purposes. Categories of service providers include:

• Payment processing partners (bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, BRAC Bank).
• Identity verification and KYC service providers.
• Cloud hosting and data storage infrastructure providers.
• Customer support platform providers.
• Fraud detection and security analytics providers.
• Game content providers (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) — limited to session and outcome data required for game delivery and audit.

6.2 Legal and Regulatory Disclosures

winb may disclose personal data to law enforcement agencies, regulatory authorities, or other public bodies where required to do so by applicable law, court order, or other legal process. Such disclosures are made only to the extent necessary to fulfil the applicable legal obligation.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of winb's business, personal data held about Platform users may be transferred to the relevant successor entity. Players will be notified of any such transfer via a Platform notice before their data is subject to a materially different privacy policy.

6.4 No Sale of Personal Data

winb does not sell, rent, or exchange your personal data with unaffiliated third parties for their own marketing or commercial purposes. Any commercial data sharing arrangements are limited to aggregated, anonymised data sets that cannot be used to identify individual players.

07 Cookies and Tracking Technologies

7.1 What Are Cookies

Cookies are small text files that are placed on your device when you visit a website. winb uses cookies and similar technologies (including local storage, session storage, and pixel tags) to operate and improve the Platform.

7.2 Types of Cookies Used

7.3 Managing Cookies

You can control and manage cookies through your browser settings. Most modern browsers allow you to refuse new cookies, delete existing cookies, and browse in private/incognito mode to limit cookie storage. Please note that disabling strictly necessary cookies will prevent core Platform functionality from operating correctly, including the ability to log in and maintain a secure session.

08 Data Retention

winb retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulatory obligation. The following general retention periods apply:

• Active Account Data: Retained for the full duration of your account's active status plus a minimum of five years following account closure, to meet anti-money laundering record-keeping requirements.
• Transaction Records: Retained for a minimum of five years from the date of each transaction, consistent with financial record-keeping best practices.
• KYC Documents: Retained for a minimum of five years from the date of verification or account closure, whichever is later.
• Customer Support Communications: Retained for three years from the date of the most recent interaction, or longer if the communication relates to an unresolved dispute.
• Technical and Device Logs: Retained for up to 24 months from collection, subject to security and fraud investigation requirements.
• Marketing Consent Records: Retained for the duration of the marketing relationship plus three years to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

09 Data Security

winb implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• TLS/SSL Encryption: All data transmitted between your device and the winb Platform is encrypted in transit using Transport Layer Security (TLS) with a minimum of TLS 1.2.
• Password Security: Passwords are stored in hashed and salted form using a strong cryptographic hashing algorithm. winb never stores passwords in plain text and will never ask you to reveal your password via any channel.
• Access Controls: Access to systems holding personal data is restricted on a need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Security Assessments: winb's infrastructure undergoes regular security reviews to identify vulnerabilities and ensure that protective measures remain effective against evolving threats.
• Incident Response: winb maintains an internal data breach response procedure. In the event of a security incident affecting your personal data, winb will take prompt action to contain the breach and will notify affected players where required.

10 Your Privacy Rights

winb recognises the following privacy rights in relation to the personal data we hold about you. To exercise any of these rights, please contact the winb support team using the details in Section 15.

10.1 Right of Access

You have the right to request a copy of the personal data winb holds about you, together with information about how that data is used and shared. winb will respond to verified access requests within a reasonable timeframe.

10.2 Right to Rectification

If any personal data winb holds about you is inaccurate or incomplete, you have the right to request that it be corrected or supplemented. You can update certain account information directly via your account settings, or by contacting the support team.

10.3 Right to Erasure

You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (for consent-based processing), or where you object to processing and there are no overriding legitimate grounds. Please note that winb may be unable to fulfil erasure requests where retention is required by law — for example, anti-money laundering record-keeping obligations may require us to retain certain data for a minimum of five years even after account closure.

10.4 Right to Restrict Processing

You may request that winb temporarily restrict the processing of your personal data in certain circumstances — for example, where you have contested the accuracy of data held about you, pending verification.

10.5 Right to Object

You have the right to object to processing of your personal data carried out on the basis of legitimate interests, and to processing for direct marketing purposes. Where you object to marketing, winb will cease sending promotional communications promptly.

10.6 Right to Data Portability

Where processing is carried out by automated means on the basis of your consent or contractual necessity, you have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.

10.7 Withdrawing Consent

Where winb processes your personal data on the basis of consent, you may withdraw that consent at any time by contacting our support team. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

11 Children and Minors

The winb Platform is strictly intended for adults aged 21 years and above. winb does not knowingly collect personal data from individuals under the age of 21. The registration process includes an explicit age confirmation step, and winb's KYC verification process is designed to detect and reject underage registrations.

If winb becomes aware that personal data has been collected from an individual who is under 21 years of age, that account will be immediately suspended, all associated funds will be withheld pending investigation, and the personal data in question will be deleted as soon as practicably possible in accordance with applicable legal requirements.

If you have reason to believe that a minor may have registered on the winb Platform, please notify our support team immediately at support@winb.ws so that the matter can be investigated without delay.

12 International Data Transfers

winb's Platform serves players across Bangladesh, including Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar. In the course of providing services to these players, personal data may be stored on or transferred to servers or systems located outside of Bangladesh.

Where personal data is transferred internationally, winb takes appropriate steps to ensure that such transfers are subject to adequate safeguards. These may include data processing agreements incorporating internationally recognised standard contractual clauses, or transfers to jurisdictions that provide a comparable level of data protection.

By using the winb Platform and providing your personal data, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Bangladesh as described in this section.

13 Third-Party Links and Services

The winb Platform may contain references to third-party game providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi), payment processors (such as bKash, Nagad, and Rocket), and other external services. While winb exercises care in selecting its partners, this Privacy Policy applies only to personal data processed directly by winb in connection with the Platform.

Third-party services have their own privacy policies and data processing practices, which are independent of winb's. winb is not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the winb Platform.

14 Amendments to This Policy

winb reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, Platform features, or payment partner arrangements. When material changes are made, winb will notify registered players through a prominent notice on the Platform or via the email address or mobile number associated with their account.

The effective date displayed at the top of this document will always reflect the date of the most recent revision. Your continued use of the winb Platform following the posting of any amendment constitutes your acceptance of the updated Policy.

winb recommends that you review this Privacy Policy periodically, particularly before making significant deposits or providing new personal information. Previous versions of this Policy may be requested from the support team for reference purposes.

15 Contact and Data Enquiries

If you have any questions about this Privacy Policy, wish to exercise any of your privacy rights as described in Section 10, or have a concern about how winb handles your personal data, please contact the winb Data Support team through any of the following channels:

• Email: support@winb.ws (plain text — not a clickable link)
• Subject Line: Please include "Privacy Enquiry" or "Data Request" in your subject line to ensure prompt routing to the relevant team.
• Live Chat: Available 24/7 directly on the winb Platform
• Response Time: winb aims to acknowledge all privacy-related enquiries within 48 hours and to provide a substantive response within 30 days of receiving a verifiable request.

To protect your privacy and the security of your account, winb may require you to verify your identity before processing any data access, rectification, or erasure request. This typically involves confirming your registered name, account username, and a recent transaction reference.