Privacy Policy — jeerwin

1 Information We Collect

jeerwin collects personal information through several channels: directly from you during account registration and KYC verification, automatically through your use of the platform, and occasionally from trusted third-party service providers. The categories of personal information we collect are set out below.

1.1 Information You Provide Directly

• Registration Data: Full legal name, date of birth, gender, email address, mobile phone number (Bangladeshi or international), and a player-chosen username and password.
• Address Information: Residential address including division, district, thana, and postal code within Bangladesh (e.g., Dhaka, Chittagong, Sylhet, Rajshahi, Khulna, Barisal, Rangpur, Mymensingh).
• Identity Documents (KYC): Scanned copies or photographs of your Bangladesh National Identity Card (NID), passport, birth certificate, or driving licence, submitted for age and identity verification purposes.
• Payment Information: Mobile money account numbers (bKash, Nagad, Rocket, Upay), bank account details (Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank), and USDT wallet addresses. jeerwin does not store raw card numbers — payment instrument data is processed via tokenised, encrypted gateways.
• Support Communications: The content of any messages, emails, or live chat transcripts you send to jeerwin's support team, including any attachments.
• Responsible Gaming Submissions: Self-exclusion requests, deposit limit settings, loss limit configurations, and session time limit preferences — stored to enforce your chosen restrictions accurately.

1.2 Information Collected Automatically

• Device and Browser Data: IP address, device type and model, operating system version, browser type and version, screen resolution, and language settings.
• Session and Usage Data: Pages visited, games played, bet amounts, game outcomes, session duration, login timestamps, and clickstream data.
• Geolocation Data: Approximate location derived from your IP address, used to detect access from restricted regions and to tailor locally relevant content (e.g., BPL cricket odds, Eid promotional periods).
• Cookie and Tracking Data: Data collected via cookies, web beacons, and local storage as described in Section 3 of this Policy.

1.3 Information from Third Parties

• Payment Providers: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, and banking partners to verify deposit and withdrawal status.
• Identity Verification Services: Confirmation results from third-party KYC and age verification service providers used to cross-check document authenticity.
• Fraud and AML Screening: Risk-scoring data from anti-fraud and anti-money-laundering screening services used to protect the platform and its players.

2 How We Use Your Data

jeerwin processes personal data only for specific, legitimate purposes. The table below sets out the primary purposes for which your data is used and the lawful basis for each processing activity.

jeerwin does not use your personal data for automated individual decision-making that produces significant legal effects, except in fraud detection and AML screening contexts where automated risk scoring is a necessary component of our compliance obligations. In such cases, you retain the right to request human review of any automated decision that adversely affects your account.

Where jeerwin sends promotional communications (bonus offers, seasonal promotions such as Eid or Pohela Boishakh campaigns, BPL cricket promotions, or reload bonus notifications), these are sent only to players who have opted in to marketing communications during registration or subsequently via their account settings. You may withdraw this consent at any time by contacting support@jeerwin or updating your communication preferences within your account.

3 Cookies & Tracking

jeerwin uses cookies and similar tracking technologies — including web beacons, pixel tags, and browser local storage — to operate the platform effectively, remember your preferences, and analyse platform usage. This section explains the types of cookies we use and the purpose of each.

You may control cookies through your browser settings. Disabling strictly necessary cookies will prevent you from logging into jeerwin and using core platform features. Disabling functional or analytics cookies will not prevent you from using the platform but may reduce the quality of your experience. Because jeerwin does not use advertising cookies, disabling cookies at the browser level has no effect on external advertising networks in relation to jeerwin.

4 Data Sharing & Disclosure

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

• Payment Processing Partners: We share transaction-specific data (payment amount, player account reference, payment instrument identifier) with payment gateway partners including bKash, Nagad, Rocket, Upay, and participating Bangladeshi banks solely to process deposits and withdrawals. These partners process data under their own privacy policies and are contractually bound to handle your data securely.
• KYC and Identity Verification Providers: Identity document images and personal details necessary for age and identity verification are shared with accredited third-party KYC service providers. These providers are contractually prohibited from using your data for any purpose other than the verification service they supply to jeerwin.
• Game Software Providers: Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive pseudonymised player identifiers and gameplay data necessary to deliver and audit game sessions. These providers do not receive your full personal identity or financial details.
• Fraud Prevention and AML Services: Pseudonymised transaction and device data may be shared with fraud detection and anti-money-laundering screening services to protect the platform and comply with financial crime prevention obligations.
• Legal and Regulatory Authorities: jeerwin will disclose personal data to competent legal, regulatory, or law enforcement authorities where required to do so by applicable law, valid court order, or legitimate regulatory request. We will notify affected players of such disclosures where permitted by law.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of jeerwin's business assets, player personal data may be transferred to the acquiring entity, provided that the acquiring entity is bound by privacy obligations no less protective than those set out in this Policy. Affected players will be notified before any such transfer takes effect.

5 Data Retention

jeerwin retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The retention periods set out below represent the standard framework applied by jeerwin:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any individual player. Where anonymised analytics data is retained beyond these periods, it no longer constitutes personal data and is not subject to this Policy's deletion obligations.

If you request deletion of your account and personal data before the standard retention period has expired, jeerwin will delete all data that we are not legally required to retain and will anonymise or suppress the remaining legally required data so it is no longer actively accessible or usable for any operational purpose.

6 Your Data Rights

jeerwin recognises and respects your rights over your personal data. The following rights are available to all registered players and may be exercised by submitting a written request to support@jeerwin. We will respond to all data rights requests within 30 days of receipt.

7 Data Security

jeerwin implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. The security framework applied to jeerwin includes, but is not limited to, the following measures:

• Transport Layer Security (TLS): All data transmitted between your browser or device and jeerwin's servers is encrypted in transit using TLS 1.2 or higher, preventing interception or tampering during transmission.
• Data Encryption at Rest: Personal data and financial records stored on jeerwin's servers are encrypted at rest using AES-256 encryption, ensuring that even in the event of physical server access, data cannot be read without the correct decryption keys.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. jeerwin employees and contractors are granted access only to the data required to perform their specific job functions. All privileged access is logged, monitored, and subject to regular review.
• Two-Factor Authentication (2FA): Internal system access by jeerwin staff requires multi-factor authentication. Players are strongly encouraged to enable 2FA on their own accounts for enhanced personal account security.
• Penetration Testing and Vulnerability Assessments: jeerwin conducts regular security assessments, including external penetration testing and automated vulnerability scanning, to identify and remediate potential weaknesses in our systems before they can be exploited.
• Incident Response: jeerwin maintains a documented data breach response procedure. In the event of a confirmed personal data breach that poses a risk to your rights and freedoms, we will notify affected players without undue delay, providing details of what occurred, what data was affected, and what remediation steps have been taken.
• Certified RNG Providers: All game outcomes on jeerwin are determined by certified Random Number Generator (RNG) systems operated by our licensed game providers. Game integrity data is audited independently to ensure fairness and prevent manipulation.
• Staff Training: All jeerwin personnel who handle personal data receive mandatory privacy and security awareness training upon onboarding and on a recurring annual basis.

8 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or jeerwin's data handling practices, please contact our Data Protection team using the details below. All privacy-related correspondence should be submitted in English and addressed clearly as a "Privacy Enquiry" or "Data Rights Request" in the subject line.

• Email: support@jeerwin — Please mark your message "Privacy Enquiry" in the subject line.
• Response Time: jeerwin will acknowledge all privacy-related enquiries within 5 business days and will provide a full substantive response within 30 calendar days of receipt.
• Language: All formal privacy correspondence must be submitted in English. Communications submitted in other languages may be returned for translation before processing.
• Live Support: For general questions about your data or account privacy settings, our 24/7 live chat support team can provide guidance, though formal data rights requests must be submitted in writing via email.

jeerwin is committed to resolving all privacy complaints fairly and promptly through our internal complaints process. If you submit a formal complaint and are not satisfied with the outcome of our internal review, you may escalate the matter through any competent external dispute resolution mechanism available to you under applicable law in Bangladesh.

jeerwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or business operations. Where a material change is made to this Policy, we will notify registered players via the email address associated with their account at least 14 days before the change takes effect. Continued use of jeerwin following the effective date of any updated Policy constitutes your acceptance of the revised terms. The "Last Updated" date at the top of this document always reflects when the most recent version of this Policy was published.