winrup Privacy Policy

1 About This Policy

This Privacy Policy ("Policy") sets out how winrup collects, processes, stores, and protects personal data in connection with the operation of the winrup platform at winrup.org. It applies to all registered players, visitors, and any individual whose personal data is processed by winrup in connection with the use of its Services.

This Policy should be read alongside the winrup Terms & Conditions and Responsible Gaming policy, both of which form part of the overall agreement governing your relationship with winrup.

2 Data Controller

For the purposes of applicable data protection law, winrup is the data controller in respect of personal data collected through the winrup platform at winrup.org. As data controller, winrup determines the purposes and means of processing personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

If you have any questions or concerns regarding the processing of your personal data, or wish to exercise any of your data rights as described in Section 10 of this Policy, you may contact the winrup Data Protection team via the support channels set out in Section 15.

3 Data We Collect

winrup collects the following categories of personal data in connection with the registration, operation, and ongoing management of player accounts and the delivery of its Services:

winrup does not intentionally collect sensitive personal data beyond what is strictly required for KYC and regulatory compliance purposes. Where such data is collected (for example, identification documents containing information about national identity), it is handled with enhanced security controls.

4 How We Collect Your Data

winrup collects personal data through the following channels and mechanisms:

• Direct Registration: When you create a winrup Account, you provide identity, contact, and account preference information directly through the registration form.
• KYC Verification Submissions: When winrup requests identity verification, you upload documentary evidence (such as a copy of your CNIC or passport) directly through the platform's secure document upload facility.
• Deposit and Withdrawal Transactions: Payment data is collected when you initiate deposits or withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or any other supported payment method.
• Platform Interaction: Technical and usage data is collected automatically as you navigate the winrup platform, place bets, play casino games, or interact with slot titles. This includes server logs, session data, and cookies as described in Section 9.
• Customer Support Interactions: When you contact the winrup support team via live chat or email, the content of those communications is collected and retained for support resolution and compliance purposes.
• Third-Party Verification Providers: Where winrup uses approved third-party KYC or fraud-screening services, additional data may be received from those providers as part of the verification process.

5 How We Use Your Data

winrup uses personal data collected from players for the following purposes:

• Account Management: To create, maintain, and administer your winrup Account, including processing deposits, withdrawals, and bet settlements.
• Identity and Age Verification: To verify that you meet the minimum age requirement of 21 years and to confirm your identity as part of KYC compliance obligations.
• Regulatory and AML Compliance: To meet anti-money laundering, counter-terrorism financing, and other regulatory obligations applicable under winrup's international gaming licence framework.
• Fraud Detection and Security: To monitor account activity for suspicious behaviour, protect the integrity of the platform, and prevent unauthorised access to player accounts.
• Responsible Gaming: To monitor player activity for indicators of problematic gambling behaviour and to apply responsible gaming tools such as deposit limits, session restrictions, or self-exclusion where appropriate.
• Customer Support: To respond to support enquiries, resolve disputes, and improve service quality based on interaction data.
• Platform Improvement: To analyse aggregated usage data and improve the performance, features, and content of the winrup platform.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have provided explicit consent to receive such communications. You may withdraw this consent at any time.

6 Legal Basis for Processing

winrup processes personal data only where a valid legal basis exists. The following legal bases apply to the main categories of processing carried out by winrup:

• Contractual Necessity: Processing required to enter into and perform the contract with you as a registered winrup player — including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC verification, AML reporting, age verification, and licensing requirements under winrup's international gaming licence.
• Legitimate Interests: Processing carried out for winrup's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your data protection rights.
• Consent: Processing for marketing and promotional communications is carried out only where you have provided explicit, informed consent. This consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Third Parties

winrup does not sell personal data to third parties. Data is shared only in the following limited circumstances and with appropriate safeguards in place:

• Payment Processors: Financial data is shared with payment service providers including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank solely for the purpose of processing player transactions. These providers process data under their own privacy policies and applicable financial regulations.
• KYC & Identity Verification Partners: Identity documents and personal data may be shared with approved third-party KYC verification service providers for the sole purpose of completing regulatory identity checks.
• Fraud Prevention Services: Technical and behavioural data may be shared with fraud screening providers to protect the platform and its players from fraudulent activity.
• Regulatory and Licensing Authorities: winrup may be required to disclose player data to its licensing authority, law enforcement agencies, or other regulatory bodies where required by law or where disclosure is necessary to protect the integrity of the platform.
• IT and Infrastructure Providers: Data may be processed by winrup's hosting, cloud, and IT infrastructure providers who operate under strict data processing agreements and do not use player data for any independent purpose.

8 Data Retention

winrup retains personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. The following general retention periods apply:

• Account Data: Retained for the duration of the active account relationship and for a minimum period of five (5) years following account closure, in accordance with AML regulatory requirements.
• KYC and Identity Documents: Retained for a minimum of five (5) years following the conclusion of the business relationship, as required under applicable anti-money laundering obligations.
• Transaction Records: Deposit, withdrawal, and betting transaction records are retained for a minimum of five (5) years for regulatory compliance and dispute resolution purposes.
• Support Communications: Live chat transcripts and email correspondence are retained for up to three (3) years for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Records of marketing consent and withdrawal of consent are retained for the duration of the account relationship and for a minimum of two (2) years thereafter.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with winrup's internal data lifecycle management procedures.

9 Cookies & Tracking Technologies

winrup uses cookies and similar tracking technologies on the winrup.org platform. Cookies are small text files placed on your device that help the platform function correctly and allow winrup to understand how players use the site.

The following categories of cookies are used on the winrup platform:

• Strictly Necessary Cookies: Essential for the operation of the platform, including maintaining your logged-in session, security tokens, and language preferences. These cannot be disabled without impairing platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised data about how players navigate the platform, which pages are visited most frequently, and how the platform performs across different devices. This data is used solely to improve the winrup experience.
• Functional Cookies: Used to remember your preferences such as preferred game categories, display settings, and responsible gaming tool configurations between sessions.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may affect the functionality of the winrup platform. Further information about managing cookies is available through your browser's help documentation.

10 Your Data Rights

Subject to applicable data protection law and the requirements of winrup's regulatory obligations, you have the following rights in respect of your personal data:

• Right of Access: You may request a copy of the personal data winrup holds about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data held in your winrup Account.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to winrup's legal retention obligations. Note that data subject to mandatory AML retention periods cannot be deleted on request during that period.
• Right to Restriction: You may request that winrup restricts the processing of your data in certain circumstances, such as where you contest the accuracy of the data or object to its processing.
• Right to Data Portability: You may request a copy of the personal data you have provided to winrup in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your data for marketing purposes at any time, and winrup will cease such processing upon receipt of a valid objection.
• Right to Withdraw Consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, contact the winrup support team via live chat on the platform or by emailing [email protected]. winrup will respond to verified requests within thirty (30) days.

11 Data Security

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

• 256-bit SSL Encryption: All data in transit between your device and the winrup platform is protected by industry-standard SSL encryption.
• Encrypted Data Storage: Sensitive personal and financial data at rest is stored using strong encryption protocols on access-controlled servers.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. winrup staff with access to player data are subject to confidentiality obligations and regular security training.
• Intrusion Detection: The winrup platform employs automated intrusion detection and anomaly monitoring systems that flag and respond to suspicious access attempts in real time.
• Regular Security Audits: winrup conducts periodic security reviews and vulnerability assessments to ensure that data protection measures remain effective and up to date.

Despite these measures, no data transmission over the internet can be guaranteed to be completely secure. winrup will notify affected players and relevant regulatory authorities in the event of a data breach that poses a risk to player rights, in accordance with applicable legal requirements.

12 Children's Privacy

The winrup platform is strictly intended for adults aged 21 years and over. winrup does not knowingly collect, process, or retain personal data from individuals under the age of 21.

Where winrup identifies or receives a credible report that an account has been registered by an individual under the age of 21, that account will be suspended immediately and all associated personal data will be reviewed and deleted in accordance with applicable regulatory requirements.

If you have reason to believe that a minor has registered an account on the winrup platform, please contact the support team immediately via live chat so that appropriate action can be taken without delay.

13 Third-Party Links

The winrup platform may contain references or links to affiliated pages and services within the winrup ecosystem. This Privacy Policy applies exclusively to personal data collected and processed by winrup through the winrup.org platform.

winrup is not responsible for the privacy practices of any third-party services, payment platforms, or external resources. Players who use third-party payment providers such as JazzCash or EasyPaisa should review the privacy policies of those providers independently, as their data handling practices are governed by their own policies and not by this document.

14 Amendments to This Policy

winrup reserves the right to update or amend this Privacy Policy at any time in response to changes in applicable data protection law, regulatory requirements, or the operational practices of the winrup platform. The date of the most recent revision is displayed at the top of this page.

Where amendments are material, winrup will notify registered players via the email address associated with their Account or through a prominent notice on the Platform prior to the changes taking effect. Continued use of the winrup platform following notification of an amendment constitutes acceptance of the revised Policy.

We recommend reviewing this Privacy Policy periodically to stay informed about how winrup handles your personal data.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by winrup, please get in touch with our support team using the contact details below:

• Live Chat: Available 24/7 directly on the winrup platform — average response time 3–5 minutes. Select "Privacy & Data" from the support topic menu.
• Email: [email protected] — please note this address is displayed as plain text and is not a clickable link.
• Response Time: winrup aims to acknowledge all privacy-related requests within 24 hours and to provide a substantive response within 30 days of identity verification.