jjwan Privacy Policy — Your Data, Your Rights

1.1  Welcome to jjwan. This Privacy Policy ("Policy") describes how jjwan ("jjwan", "we", "us", or "our") collects, processes, stores, and protects personal data relating to individuals ("you", "your", "Player") who visit, register on, or otherwise interact with the jjwan platform available at jjwan.club and any associated mobile applications (collectively, the "Platform").

1.2  jjwan is committed to handling your personal data with the highest standards of transparency, integrity, and security. We align our data protection practices with internationally recognised privacy frameworks, including principles derived from the General Data Protection Regulation (GDPR), to ensure that Pakistani players and all other users of the Platform are afforded meaningful protections.

1.3  This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which form part of the agreement between you and jjwan. By accessing or using the Platform, you acknowledge that you have read, understood, and accepted the practices described in this Policy.

1.4  If you do not agree with any part of this Policy, please discontinue use of the Platform and contact our support team at [email protected] to request Account closure.

2.1  For the purposes of applicable data protection law, jjwan acts as the Data Controller in respect of personal data collected through the Platform. As Data Controller, jjwan determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

2.2  All data protection queries, subject access requests, and privacy-related communications should be directed to the jjwan Data Protection team using the contact details set out in Section 15 of this Policy.

3.1  jjwan collects the following categories of personal data in the course of providing gaming and related services to Pakistani players and other users of the Platform:

3.2  jjwan does not collect any sensitive special-category data (such as racial or ethnic origin, health data, or political opinions) unless explicitly required for compliance with a legal obligation and with your prior consent.

3.3  jjwan does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step during the Account registration process and is strictly enforced at all times.

4.1  jjwan collects personal data through the following methods:

• Direct Collection: Data you provide directly when registering an Account on jjwan, completing KYC verification, making a deposit or withdrawal via JazzCash, EasyPaisa, or bank transfer, submitting a support request, or communicating with our team.
• Automated Collection: Technical and gaming data collected automatically as you interact with the jjwan platform, including through cookies, session tracking, and server logs. See Section 8 for full details on cookies.
• Third-Party Sources: Identity and fraud verification data obtained from KYC and anti-money laundering (AML) service providers; payment confirmation data from payment processors including JazzCash and EasyPaisa; fraud and risk signals from third-party security partners.

4.2  jjwan does not purchase personal data from data brokers, advertising networks, or any third-party list providers for the purpose of unsolicited marketing or profiling.

5.1  jjwan processes your personal data for the following purposes:

• Account Management: To create, verify, maintain, and administer your jjwan Account, including processing your jjwan Login credentials and enabling access to the Platform.
• Service Delivery: To provide sports betting (including PSL and international cricket), live casino, slot, and all other gaming services offered through the jjwan Platform.
• Payments Processing: To process PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20, and to maintain accurate financial records.
• KYC & AML Compliance: To verify your identity and age (21+), comply with anti-money laundering obligations, and conduct ongoing transaction monitoring as required under international gaming regulations.
• Responsible Gaming: To administer deposit limits, session time reminders, cool-off periods, and self-exclusion requests; to identify players who may be exhibiting problematic gambling behaviour and to intervene proactively.
• Customer Support: To respond to your queries, complaints, and requests in a timely and effective manner, including through our 24/7 support channels.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates by email or SMS where you have given your consent or where we have a legitimate interest to do so. You may opt out of marketing communications at any time.
• Security & Fraud Prevention: To detect and prevent fraud, collusion, bonus abuse, unauthorised Account access, and other prohibited activities on the Platform.
• Legal Compliance: To comply with applicable laws, regulations, court orders, and requests from regulatory or law enforcement authorities.
• Platform Improvement: To analyse aggregated and anonymised usage data to improve the performance, functionality, and user experience of the jjwan platform for Pakistani players.

5.2  jjwan will not use your personal data for any purpose that is incompatible with the purposes stated above without first obtaining your explicit consent or establishing a new lawful basis for processing.

6.1  jjwan processes your personal data on the following legal bases, as applicable:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you have accepted — including Account registration, payments, and game delivery.
• Legal Obligation: Processing required to comply with KYC, AML, and other applicable regulatory obligations under international gaming licensing requirements.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing for direct marketing communications and certain optional cookies, where you have provided your informed and freely given consent. You may withdraw consent at any time.

7.1  jjwan does not sell your personal data to any third party. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT/crypto payment processors — to facilitate PKR deposits and withdrawals.
• KYC & AML Providers: Identity verification and anti-money laundering screening service providers who verify the authenticity of identity documents submitted by players.
• Game Technology Providers: Third-party gaming software suppliers whose games are integrated into the jjwan platform. These providers may receive session identifiers for the purpose of game delivery and RNG certification — they do not receive full player identity data.
• Fraud Prevention & Security Partners: Specialised security firms engaged to detect, investigate, and prevent fraud, collusion, and other prohibited conduct on the Platform.
• Regulatory & Law Enforcement Authorities: Government bodies, regulators, and law enforcement agencies as required by applicable law, court order, or regulatory obligation.
• Professional Advisors: Legal counsel, auditors, and accountants bound by professional confidentiality obligations who assist jjwan with legal, compliance, and financial matters.
• Group Companies: Affiliated entities within the jjwan corporate group, where such sharing is necessary for operational, compliance, or risk management purposes.

7.2  All third-party service providers engaged by jjwan are contractually required to process personal data only on jjwan's documented instructions, to implement appropriate technical and organisational security measures, and to not use player data for their own independent purposes.

7.3  Where personal data is transferred outside of Pakistan or the jurisdiction in which jjwan is licensed, jjwan ensures that appropriate safeguards are in place — including standard contractual clauses or adequacy determinations — to protect the data to an equivalent standard.

8.1  jjwan uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage) on the Platform. Cookies are small text files placed on your device when you visit jjwan.club. They serve the following functions:

• Strictly Necessary Cookies: Essential for the Platform to function correctly — for example, maintaining your jjwan Login session, storing your language preferences, and enabling secure payments. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences and personalisation settings to provide a more convenient experience on return visits.
• Analytics Cookies: Collect anonymised information about how players use the Platform (page views, session duration, navigation paths) to help jjwan improve performance and user experience. No personally identifiable data is collected through analytics cookies.
• Responsible Gaming Cookies: Track session duration for the purpose of displaying reality-check notifications and enforcing player-set session time limits.

8.2  You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no opt-out mechanism is available as they are essential to the secure operation of jjwan.

8.3  jjwan does not use third-party advertising cookies or permit advertising networks to place tracking cookies on the jjwan Platform without your explicit consent.

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

• Account & Identity Data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, as required for AML and regulatory compliance obligations.
• Financial & Transaction Data: Retained for a minimum of seven (7) years from the date of each transaction, in compliance with applicable financial record-keeping requirements.
• Gaming History: Retained for a minimum of three (3) years from the date of each game session for dispute resolution and regulatory audit purposes.
• Support & Communications Data: Retained for two (2) years from the date of the last communication, or longer where a complaint or legal dispute remains unresolved.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of compliance.
• Technical & Log Data: Retained for up to twelve (12) months from collection for security and fraud prevention purposes.

9.2  Following the expiry of the applicable retention period, jjwan will securely delete or anonymise your personal data in a manner that renders it irreversibly unidentifiable.

10.1  jjwan implements the following technical security measures to protect player data on the Platform:

• TLS/SSL Encryption: All data transmitted between your device and the jjwan Platform is encrypted using Transport Layer Security (TLS 1.3) to prevent interception.
• At-Rest Encryption: Sensitive personal and financial data stored in jjwan's databases is encrypted at rest using AES-256 encryption.
• Two-Factor Authentication (2FA): Available and strongly recommended for all jjwan Accounts to prevent unauthorised access via jjwan Login.
• Access Controls: Strict role-based access controls ensure that jjwan staff can only access player data to the extent necessary for their specific job function.
• Regular Security Audits: jjwan's infrastructure undergoes regular third-party penetration testing and security audits.
• Intrusion Detection: Real-time network monitoring and intrusion detection systems are in place to identify and respond to potential security threats.

10.2  In the event of a personal data breach that poses a risk to your rights and freedoms, jjwan will notify affected players without undue delay and will take all reasonable steps to mitigate the impact of the breach.

10.3  While jjwan implements robust security measures, no system can guarantee absolute security. You remain responsible for maintaining the confidentiality of your jjwan Login credentials and for enabling 2FA on your Account.

11.1  As a player on jjwan, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected] with the subject line "Privacy Rights Request." jjwan will respond to all valid requests within thirty (30) days.

• Right of Access: You have the right to request a copy of the personal data jjwan holds about you and to receive information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to jjwan's legal retention obligations under AML and gaming regulations.
• Right to Restriction: You may request that jjwan restricts processing of your data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
• Right to Object: You have the right to object to processing of your personal data based on jjwan's legitimate interests, and to opt out of direct marketing communications at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

11.2  Please note that certain rights — in particular the right to erasure — may be limited where jjwan is required to retain data under applicable AML, KYC, or gaming regulatory obligations. In such cases, jjwan will inform you of the specific legal basis for retaining your data.

12.1  The jjwan Platform may contain links to third-party websites or services that are not operated by jjwan. These links are provided for convenience and informational purposes only. jjwan does not control those third-party websites and is not responsible for their privacy practices or content.

12.2  This Privacy Policy applies solely to the jjwan Platform at jjwan.club and any associated mobile applications. jjwan encourages you to review the privacy policies of any third-party websites you visit via links from the Platform.

13.1  If jjwan becomes aware that personal data has been collected from a person under the age of 21 without verifiable parental or guardian consent, jjwan will immediately close the Account, delete all associated personal data, and reverse all financial transactions associated with that Account.

13.2  If you are a parent or guardian and believe that your child may have registered on jjwan or provided personal data to jjwan, please contact us immediately at [email protected] with the subject line "Underage Account Report." We will investigate and take appropriate action within 24 hours of receiving your report.

13.3  jjwan's responsible gaming tools — including deposit limits and self-exclusion — are available to all adult players. For further guidance on protecting minors from gambling harm, please visit our Responsible Gaming page.

14.1  jjwan reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The most current version of the Policy will always be published on this page at jjwan.club/privacy-policy, with an updated "Last Updated" date at the top of the document.

14.2  Where changes to this Policy are material — that is, where they significantly affect your rights or the way jjwan processes your data — jjwan will notify registered players via email or on-Platform notification prior to the changes taking effect, where reasonably practicable.

14.3  Your continued use of the jjwan Platform following the publication of a revised Privacy Policy constitutes your acknowledgement of the updated Policy. If you do not accept the revised Policy, please discontinue use of the Platform and contact [email protected] to request Account closure.

15.1  If you have any questions, concerns, or requests relating to this Privacy Policy or to jjwan's processing of your personal data, please contact our Data Protection team using the details below. All privacy-related communications must be submitted in writing to ensure a proper record is maintained.

15.2  For responsible gaming-related data requests — including self-exclusion records, deposit limit history, or cool-off period data — please visit our Responsible Gaming page or email [email protected] with the subject line "Responsible Gaming Data Request."