Privacy Policy

This Privacy Policy explains how 1Win N.V. (registered in Curaçao, company no. 147039), operating under Curaçao eGaming License 8048/JAZ2018-040, collects, uses, stores, and protects your personal data when you access and use our platform at uniquepakistan.com.pk and our associated mobile applications. We are committed to transparency and compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and other relevant privacy frameworks. Please read this policy carefully to understand our practices.

Data Controller and Contact Information

The data controller responsible for your personal information is 1Win N.V., Curaçao. For data protection inquiries, you may contact our Data Protection Officer or our support team available 24/7 in English, Urdu, and Hindi. All requests regarding your data should be directed to our support channels, and we will respond within the timeframes required by applicable law.

What Personal Data We Collect

We collect various categories of personal data to provide our services, comply with legal obligations, and prevent fraud. The data we collect includes:

Identity data: your full name, date of birth, nationality, and gender
Contact information: email address, phone number, and postal address
Financial data: bank account details, payment card information, and transaction history
KYC and AML documents: government-issued identification, proof of address, and source of funds verification
Technical data: IP address, device type, operating system, browser type, and device identifiers
Usage data: pages visited, games played, betting patterns, session duration, and account activity
Marketing preferences: your consent status for promotional communications and communication channels
Communications: records of support tickets, emails, chat logs, and other correspondence with our team

How We Collect Your Data

Your personal data is collected through multiple sources and methods. You directly provide identity, contact, and financial information when you register an account, complete KYC verification, or update your profile. We automatically collect technical and usage data through cookies, pixels, and similar tracking technologies when you use our platform. Third parties, including payment processors, KYC and AML verification providers, credit reference agencies, fraud prevention services, and affiliate partners, may provide us with additional data to verify your identity and prevent illegal activity. For detailed information about cookies and tracking, please refer to our Cookie Policy.

Purposes of Data Processing and Legal Basis

We process your personal data for the following purposes, each supported by a lawful legal basis:

Purpose: Legal Basis
Account creation and management: Performance of contract with you
Processing deposits and withdrawals: Performance of contract and payment processing obligations
KYC and AML compliance verification: Legal obligation under anti-money laundering and counter-terrorism financing regulations
Fraud detection and prevention: Legitimate interest in protecting our platform and users
Responsible gaming enforcement: Legal obligation and legitimate interest in player protection
Marketing communications and promotions: Your explicit consent (which you may withdraw at any time)
Customer support and dispute resolution: Performance of contract and legitimate interest
Regulatory reporting and licensing compliance: Legal obligation to our gaming regulator
Platform improvement and analytics: Legitimate interest in enhancing user experience

We may disclose your personal data to third parties in the following circumstances:

Payment processors and financial institutions: MFI Investments Limited (Cyprus, HE386738) and other payment service providers to process your transactions
KYC and AML partners: third-party verification providers to confirm your identity and assess compliance risk
Regulatory authorities: gaming regulators, tax authorities, and law enforcement agencies when legally required
Group companies: other entities within the 1Win corporate group for operational and compliance purposes
Fraud prevention services: specialized providers to detect and prevent fraudulent activity
Affiliate and marketing partners: to manage referral programs and promotional campaigns (only with your consent)
IT service providers and contractors: cloud hosting providers, software developers, and support vendors who process data on our behalf
Legal advisors: our lawyers and compliance consultants when necessary to defend legal claims or comply with obligations

All third parties are contractually bound to process your data only as instructed and to maintain appropriate security measures.

International Data Transfers

Your personal data may be transferred to, stored in, and processed in countries outside Pakistan, including Curaçao, Cyprus, the European Union, and other jurisdictions where our service providers operate. Where we transfer data outside the European Economic Area, we rely on Standard Contractual Clauses, adequacy decisions, or other safeguards recognized under applicable data protection law. By using our platform, you consent to such transfers. We take appropriate steps to ensure that international transfers are protected by contractual guarantees and technical security measures.

Data Retention Periods

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Typically, we retain data as follows:

Account and transaction data: retained for a minimum of 5 years after account closure to comply with AML and tax obligations
KYC and identity documents: retained for 5+ years after the last transaction or account closure
Marketing data: retained until you withdraw consent or request deletion
Technical and usage logs: typically retained for 12 months unless longer retention is required for security or legal purposes
Support communications: retained for 3 years after the final interaction or as required by applicable law

After the retention period expires, we securely delete or anonymize your data unless we are legally obligated to retain it longer.

Your Data Subject Rights

Under applicable data protection laws, you have the following rights regarding your personal data:

Right of access: you may request a copy of the personal data we hold about you
Right to rectification: you may correct inaccurate or incomplete data
Right to erasure: you may request deletion of your data, subject to legal retention obligations
Right to restrict processing: you may request that we limit how we use your data
Right to data portability: you may request your data in a structured, machine-readable format
Right to object: you may object to processing for marketing, profiling, or legitimate interest purposes
Right to withdraw consent: you may withdraw consent for marketing communications at any time
Right not to be subject to solely automated decision-making: you have the right to human review of automated decisions that significantly affect you

To exercise any of these rights, contact our support team or submit a formal request. We will respond within 30 days or as required by applicable law. Please note that some rights may be limited by legal obligations, such as AML retention requirements.

Cookies and Tracking Technologies

Our platform uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, remember your preferences, analyze usage patterns, and deliver targeted content. These technologies may collect information about your browsing behavior and device. For a detailed explanation of the types of cookies we use, their purposes, and how to manage your cookie preferences, please refer to our separate Cookie Policy.

Data Security

We implement comprehensive organizational and technical security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security safeguards include 256-bit SSL/TLS encryption for data in transit, two-factor authentication for account access, secure data storage with access controls, regular security audits and penetration testing, and staff training on data protection. However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and account information.

Age Restrictions

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from someone under 18, we will take steps to delete such information promptly and may terminate the account. By using our platform, you represent and warrant that you are at least 18 years old and legally permitted to use online gambling services in your jurisdiction.

Complaints and Supervisory Authority

If you believe we have violated your data protection rights or have concerns about how we process your data, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. While we encourage you to contact us first so we may address your concerns, you are not required to do so. Your right to lodge a complaint with a supervisory authority is not affected by any other administrative or judicial remedy available to you.

Policy Updates and Changes

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated policy on our platform and updating the date of last revision. Your continued use of 1win online following the posting of changes constitutes your acceptance of the updated policy. We encourage you to review this policy periodically to stay informed about how we protect your data.

Last updated: January 2025