win399 Privacy Policy

1Introduction

This Privacy Policy ("Policy") is issued by win399 ("we", "us", "our" or "the Operator"), the operator of the online sports betting and casino platform available at https://win399.cam ("the Platform" or "the Website"). This Policy applies to all users who access, browse or register on the Platform, including players based in Pakistan and any other applicable jurisdiction.

win399 is an English-language platform designed for Pakistani users, providing sports betting markets — including cricket, PSL, ICC tournaments, football and UFC — alongside live casino games, slot titles and instant-win products, with account balances displayed in Pakistani Rupees (PKR / Rs) for user convenience.

We are committed to protecting your privacy. This Policy describes the categories of personal data we collect, the purposes for which it is processed, the legal bases that apply, how long data is retained, and the rights available to you. We do not sell, rent or trade personal data to third parties for marketing purposes.

2Definitions

The following terms are used throughout this Policy with the meanings defined below:

3Data We Collect

win399 collects personal data in the following categories, depending on how you interact with the Platform:

3.1 Registration Data

• Full legal name;
• Date of birth (for age verification);
• Email address;
• Mobile phone number (where provided);
• Username and account credentials (password stored in hashed, non-reversible format);
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar).

3.2 Identity Verification (KYC) Data

• Government-issued photo identification: valid Pakistani CNIC or current passport;
• Proof of address documentation where required;
• Selfie or liveness verification images;
• Payment method confirmation documentation where applicable.

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records;
• Account balance history in PKR;
• Payment method references (type and last digits only — full card or account numbers are not stored by win399);
• Bonus claim and wagering activity records.

3.4 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system and browser information;
• Session duration, page interaction data and clickstream information;
• Cookies and similar tracking technologies (see Section 9).

3.5 Communications Data

• Support chat transcripts and email correspondence;
• Feedback, complaints and survey responses;
• Marketing preference records.

4Legal Basis for Processing

win399 processes personal data only where a lawful basis exists. The applicable legal bases are as follows:

5How We Use Your Data

Personal data collected by win399 is used for the following purposes:

• Account Services: Creating and managing your Account, verifying your identity and age, processing deposits and withdrawal requests, and maintaining your transaction history in PKR;
• Platform Delivery: Providing access to sports betting markets (including PSL, ICC, football and UFC), live casino games, slots and promotional offers;
• Compliance: Meeting Know Your Customer (KYC), Anti-Money Laundering (AML), and responsible gambling obligations required under the Operator's applicable licence conditions;
• Security and Fraud Prevention: Detecting, investigating and preventing fraudulent transactions, account takeovers, bonus abuse and other prohibited conduct as defined in the Platform's Terms and Conditions;
• Responsible Gambling: Monitoring player behaviour for indicators of problem gambling and facilitating the use of deposit limits, session controls and self-exclusion tools where needed;
• Customer Support: Responding to queries, complaints and verification requests submitted by Users, including those from players in Karachi, Lahore, Islamabad and other cities across Pakistan;
• Marketing (opt-in only): Sending promotional communications about bonuses, new games or platform updates to Users who have expressly opted in. You may withdraw this consent at any time by updating your Account preferences or contacting support;
• Analytics: Understanding how Users navigate and use the Platform in order to improve user experience, site performance and product offerings.

6Data Sharing & Disclosure

win399 does not sell, rent or trade your personal data to third parties for commercial purposes. We may share personal data in the following limited circumstances:

• Service Providers (Data Processors): We engage third-party service providers to support Platform operations, including KYC verification engines, payment gateway processors, fraud detection systems, cloud hosting providers, customer support platforms and analytics tools. These providers are bound by contractual data processing obligations and may not use your data for their own independent purposes;
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order or regulatory request, win399 may be obligated to disclose personal data to relevant authorities. This includes AML reporting obligations where applicable under the Operator's licence jurisdiction;
• Business Transfers: In the event of a merger, acquisition, asset sale or corporate restructuring involving win399, personal data held by the Operator may be transferred to the successor entity, subject to equivalent privacy protections;
• Fraud Prevention Networks: win399 may share data with industry fraud prevention databases where there is a reasonable basis to suspect fraudulent, abusive or criminal conduct involving a User Account.

7Data Retention

win399 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following indicative retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

8Data Security

win399 implements a range of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and the Platform is protected using 256-bit SSL/TLS encryption. We strongly encourage Users to verify the HTTPS padlock in their browser before entering any credentials;
• Encryption at Rest: Sensitive data fields — including passwords (stored in hashed, non-reversible form) and financial details — are encrypted within our data stores;
• Access Controls: Access to personal data within win399's systems is restricted on a strict need-to-know basis, with role-based permissions and audit logging;
• Third-Party Security Assessments: Key service providers are assessed for security compliance prior to engagement and subject to contractual security standards;
• Incident Response: win399 maintains a data breach response procedure. In the event of a breach likely to result in risk to individuals, we will notify affected Users and, where required, relevant regulatory authorities within applicable timeframes.

9Cookies & Tracking Technologies

win399 uses cookies and similar technologies (such as local storage and session tokens) to operate and improve the Platform. The following categories of cookies are used:

You may manage cookie preferences through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled without impacting core features.

10Your Rights

Subject to applicable data protection law and any overriding legal obligations (such as AML/KYC retention requirements), you have the following rights in relation to your personal data held by win399:

To exercise any of the above rights, please contact win399 using the details in Section 15. We will respond to valid requests within the timeframe required by applicable law — typically within 30 days. Where requests are complex or numerous, we may extend this period by an additional 30 days, with prior notification to you.

11Minors

win399 is strictly an adults-only Platform. We do not knowingly collect personal data from individuals under the age of 18 — or the higher minimum age required by the Operator's licence jurisdiction or applicable local law. Age verification is a mandatory step in the KYC process for all Users.

If win399 becomes aware that personal data has been collected from a minor without verified parental consent, such data will be deleted promptly and the associated Account closed. If you believe a minor has registered on the Platform, please contact support immediately using the details in Section 15.

12International Data Transfers

Given the nature of online platforms, personal data collected by win399 may be processed in, or transferred to, countries outside your country of residence, including countries that may have different data protection standards from those applicable in Pakistan.

Where such transfers occur, win399 ensures that appropriate safeguards are in place to protect your personal data — such as contractual data processing agreements with service providers that impose equivalent data protection standards. By using the Platform, you acknowledge that your data may be processed outside Pakistan in connection with the services described in this Policy.

13Third-Party Services

The Platform may integrate with or reference third-party services — including payment processors, KYC verification providers, live-dealer game studios, sports data feeds and analytics tools. Each third-party provider operates under its own privacy policy and data processing terms.

Payment methods commonly known in Pakistan — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are referenced as contextual examples for Pakistani users only. Their mention does not constitute a data-sharing agreement, partnership arrangement or endorsement by those institutions. Any data transmitted to payment processors in connection with a transaction is governed by the applicable processor's own terms.

win399 is not responsible for the privacy practices of third-party services accessed through or referenced on the Platform. We recommend that Users review the relevant third-party privacy policies independently.

14Policy Amendments

win399 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements or our data processing practices. The effective date shown at the top of this document will be updated whenever a material change is made.

Where a material amendment is made, we will use reasonable efforts to notify registered Users via email or on-Platform notification prior to the change taking effect. Continued use of the Platform following such notification constitutes acceptance of the revised Policy.

The most current version of this Privacy Policy is always available at https://win399.cam/privacy-policy.

15Contact & Data Requests

If you have any questions about this Privacy Policy, wish to exercise any of your data rights described in Section 10, or wish to make a complaint regarding our data handling practices, please contact win399 as follows:

For account-related verification requests, please use the secure KYC portal within your Account dashboard — do not send identity documents by email. Live chat support is available 24/7 (as per operator availability) with Urdu assistance available on request.