Privacy Policy — betwiner

betwiner collects personal information from you in the following ways: directly from you when you register an account or interact with the platform; automatically through your use of the site; and, in limited circumstances, from third-party identity verification or payment processing services. The categories of data we collect are described below.

1.1 Account Registration Data

When you create a betwiner account, we collect:

• Full legal name (as it appears on your National Identity Card or passport)
• Date of birth (to verify you are 18 years of age or older)
• Residential address in Bangladesh (city, district, full postal address)
• Email address
• Mobile phone number (linked to your bKash, Nagad, Rocket, or Upay account)
• Username and encrypted password

1.2 Identity Verification Data

To comply with our age verification and anti-money laundering obligations, we may request copies of identity documents including your National Identity Card (NID), passport, or birth certificate. These documents are processed securely and stored only for as long as required by applicable law and our internal compliance policies.

1.3 Financial Data

We collect transaction records associated with your account, including deposit amounts, withdrawal requests, payment method references (e.g., your bKash wallet number in truncated form), and account balance history. We do not store full card numbers — card transactions are handled by our PCI-DSS compliant payment processing partners who transmit only tokenised references to betwiner.

1.4 Technical & Usage Data

When you access betwiner, our servers automatically record certain technical data:

• IP address and approximate geolocation (country and city level)
• Device type, operating system, and browser version
• Pages visited, time spent on each page, and click-path data
• Session start and end timestamps (all times stored in BST, UTC+6)
• Referring URL (the site or link you came from before arriving at betwiner)

1.5 Communications Data

If you contact our support team by email or live chat, we retain records of those communications — including the content of your messages and our responses — for quality assurance and dispute resolution purposes.

betwiner uses the personal data we collect for the following purposes. We will only use your data in ways that are consistent with the purpose for which it was originally collected, or in ways that are clearly related and reasonably expected by you.

We do not use your personal data to make automated decisions that produce legal or similarly significant effects on you without human review. Automated fraud-detection systems may flag an account for review, but all resulting account actions (suspension, closure, withdrawal holds) are reviewed by a human compliance team member before being enacted.

betwiner processes your personal data on the following legal bases:

• Contractual necessity: The majority of our data processing is necessary to perform the contract between you and betwiner — namely, to operate your account, process your bets, and handle your BDT deposits and withdrawals. Without this processing, we cannot provide our services.
• Legal obligation: Certain processing activities — particularly identity verification, age checks, and the retention of financial transaction records — are required by applicable anti-money laundering and age-verification obligations. We are legally required to carry out this processing regardless of your preferences.
• Legitimate interests: We process technical and usage data (IP addresses, session logs, device data) based on our legitimate interest in maintaining platform security, preventing fraud, and improving the quality of our services. We have balanced this interest against your privacy rights and determined it is appropriate.
• Consent: Where we send you marketing communications (promotional emails, SMS bonus notifications), we do so on the basis of your consent, which you provide during registration. You may withdraw this consent at any time by updating your communication preferences in your account settings or by emailing support@betwiner.

betwiner uses cookies and similar technologies (including local storage and session storage) to deliver and improve our service. Cookies are small text files stored on your device when you visit the platform.

4.1 Types of Cookies We Use

4.2 What We Do Not Use

betwiner does not use third-party advertising cookies, retargeting pixels, or any tracking technology that follows you across websites unrelated to betwiner. We do not serve interest-based advertising, nor do we share your browsing behaviour with ad networks.

4.3 Managing Cookies

Essential cookies are required for the platform to function and cannot be disabled. You may disable performance and functional cookies through your browser settings. Please note that disabling functional cookies may cause some personalisation features (such as saved preferences) to stop working. Instructions for managing cookies are available in the help documentation for all major browsers including Chrome, Firefox, Safari, and Samsung Internet.

betwiner does not sell your personal data. We share personal data with third parties only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

5.1 Service Providers

We share data with carefully selected third-party service providers who process data on our behalf under strict data processing agreements. These include:

• Payment processors: bKash, Nagad, Rocket (Dutch-Bangla Bank), Upay, and our card payment gateway partners receive the transaction data necessary to process your deposits and withdrawals. They do not receive data beyond what is required for the specific transaction.
• Identity verification providers: Third-party KYC (Know Your Customer) service providers who assist in verifying the authenticity of identity documents submitted during account registration or verification requests.
• Game studios: When you play a game powered by Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, or another studio, limited technical data (player session ID, stake amount, game result) is transmitted to the studio's servers to render the game and calculate outcomes. Studios do not receive your full name, address, or financial account details.
• Analytics providers: Anonymised usage data is processed by our analytics platform to help us understand site performance. This data does not contain personally identifiable information.

5.2 Legal Disclosures

betwiner may disclose personal data to law enforcement agencies, regulatory bodies, or courts if we are required to do so by applicable law, court order, or other legal process. We will notify you of any such disclosure to the extent we are legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of betwiner's business, your personal data may be transferred to the successor entity as part of the transaction. We will notify you via email or an in-platform notice prior to any such transfer, and the successor entity will be bound by this Privacy Policy.

betwiner retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by law. The following retention periods apply:

Once a retention period has elapsed, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with an identifiable individual. Anonymised, aggregated data (such as site-wide traffic statistics) may be retained indefinitely as it no longer constitutes personal data.

betwiner implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• SSL/TLS Encryption in Transit: All data transmitted between your browser or mobile device and the betwiner platform is encrypted using TLS 1.2 or higher. The padlock icon visible in your browser address bar confirms this protection is active.
• AES-256 Encryption at Rest: Personal data stored in our databases is encrypted at rest using AES-256 encryption, the same standard used by financial institutions worldwide.
• Password Hashing: Account passwords are never stored in plain text. They are processed using a one-way cryptographic hash function with a unique salt, meaning even internal staff cannot retrieve your password.
• Access Controls: Access to systems holding personal data is restricted on a strict need-to-know basis. Staff access is logged, regularly reviewed, and revoked immediately upon termination of employment or contract.
• Two-Factor Authentication (2FA): We encourage all players to enable 2FA on their betwiner account. 2FA adds a second layer of protection against unauthorised access even if your password is compromised.
• Penetration Testing: Our platform undergoes regular third-party security audits and penetration tests to identify and remediate vulnerabilities before they can be exploited.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, betwiner will notify affected users without undue delay and take all reasonable steps to mitigate the impact.

As a user of betwiner, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact us at support@betwiner with the subject line "Privacy Rights Request — [Your Username]".

• Right of Access: You may request a copy of the personal data betwiner holds about you. We will provide this within 30 days of receiving your verified request, free of charge for the first request in any 12-month period.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You may also update basic account information (such as your email address or phone number) directly through your account settings dashboard.
• Right to Erasure: You may request that we delete your personal data. We will comply with valid deletion requests within 30 days, subject to our legal obligations to retain certain data (see Section 6 — Data Retention). Where deletion is not possible due to a legal obligation, we will restrict processing instead and inform you accordingly.
• Right to Restriction of Processing: In certain circumstances (for example, while a dispute about the accuracy of your data is being resolved), you may request that we temporarily restrict processing of your personal data rather than delete it.
• Right to Data Portability: You may request a copy of the personal data you provided to us in a commonly used, machine-readable format (such as CSV or JSON), where technically feasible.
• Right to Object to Marketing: You may opt out of receiving marketing communications from betwiner at any time by updating your notification preferences in your account settings, or by replying "UNSUBSCRIBE" to any marketing email. Transactional emails (security alerts, withdrawal confirmations) are not affected by this opt-out.

We aim to respond to all privacy rights requests within 30 calendar days. In complex cases we may extend this to 60 days, in which case we will notify you of the extension and the reason for it.

betwiner is strictly an adults-only platform. Our services are intended exclusively for individuals who are 18 years of age or older. We do not knowingly collect personal data from anyone under the age of 18.

All account registrations require a confirmed date of birth, and we reserve the right to request documentary evidence of age at any point. Any account found to belong to a person under 18 will be closed immediately. Any deposits made by an underage user will be returned to the payment method used for deposit, and any winnings generated will be forfeited.

If you are a parent or guardian and believe your child has registered an account on betwiner, please contact us immediately at support@betwiner. We take underage gambling very seriously and will act promptly to close the account and return any funds.

betwiner reserves the right to update or amend this Privacy Policy at any time. When we make material changes — meaning changes that significantly affect how we collect, use, or share your personal data — we will notify you by email to your registered address or via a prominent in-platform notification at your next login.

Non-material changes (such as correcting typographical errors, updating our contact email, or clarifying existing language without changing its substance) may be made without advance notice. All changes take effect from the date of publication on this page.

The effective date at the top of this Privacy Policy indicates when it was last reviewed and updated. We recommend that you revisit this page periodically to stay informed about how we are protecting your information. The current version of this policy is always available at /privacy-policy.

Your continued use of the betwiner platform after any update to this Privacy Policy constitutes your acknowledgement of the revised policy. If you do not agree with the updated policy, you may request account closure in accordance with our Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way betwiner handles your personal data, please contact our support team using the details below. We take all privacy enquiries seriously and will respond within 5 business days.

• Email: support@betwiner — please use the subject line "Privacy Enquiry" for fastest routing.
• Support Hours: 24/7, all times in Bangladesh Standard Time (BST, UTC+6).
• Response Time: We aim to acknowledge all privacy-related enquiries within 24 hours and provide a full response within 5 business days.
• Postal Correspondence: For formal written requests (such as subject access requests requiring identity verification), please email us first so we can confirm the correct process and address.

If you are not satisfied with our response to a privacy complaint, you may have the right to escalate the matter to the relevant data protection authority in your jurisdiction. betwiner is committed to resolving privacy concerns fairly and transparently, and we encourage you to contact us directly in the first instance so we have the opportunity to address your concern before any formal escalation.