Milwin Privacy Policy

This Privacy Policy applies to the Milwin platform, accessible at milwin.click and all associated subdomains and services. Milwin is the data controller in respect of the personal data collected and processed through the platform.

As data controller, Milwin determines the purposes and means of processing your personal data. This policy describes those purposes and means in full. Milwin is responsible for ensuring that personal data is processed in a manner consistent with this policy and applicable data protection principles.

By creating an account and using the Milwin platform, you acknowledge that you have read this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this policy, you should not register an account or continue using the Milwin platform.

Milwin collects personal data in three ways: information you provide directly, information generated automatically through your use of the platform, and in limited cases, information obtained from third parties involved in operating the service.

Information You Provide Directly

• Registration data: Your full name, date of birth, Pakistani mobile number, and email address (if provided).
• Identity verification documents: Government-issued ID (such as CNIC or passport), proof of address, or proof of payment method ownership — requested when account verification is required.
• Payment information: Identifiers associated with your chosen payment method such as your registered mobile number for Easypaisa or JazzCash transactions. Milwin does not receive or store PINs or full card numbers.
• Support communications: The content of messages you send to Milwin's support team via live chat, WhatsApp, or email.
• Responsible gaming requests: Any self-exclusion, deposit limit, or cooling-off period requests you submit.

Information Collected Automatically

• Device information: Device type, operating system, browser type and version, screen resolution, and device identifiers.
• Connection data: IP address, approximate geographic location derived from IP address, mobile network operator, and connection type (WiFi or mobile data).
• Usage data: Pages visited, games played, bets placed, session duration, navigation patterns, and feature interactions within the Milwin platform.
• Transaction data: Records of deposits, withdrawals, bets, game outcomes, and bonus activity associated with your account.
• Cookie and tracking data: As described in Section 8 of this policy.

Information From Third Parties

• Payment processors: Transaction confirmation and status data from Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT systems, and card processing networks.
• Fraud prevention services: Risk signals and fraud indicators from third-party fraud detection services that help Milwin identify suspicious account activity.
• Game providers: Game session data and outcome records from licensed third-party live casino and game providers operating tables on the Milwin platform.

Milwin uses the personal data it collects for the following specific purposes:

Account Management and Service Delivery

Creating and maintaining your Milwin account, verifying your identity, processing deposits and withdrawals in PKR, delivering the games and betting markets you access, and responding to your support requests. This is the core use of your data — without it, Milwin cannot provide the service.

Security and Fraud Prevention

Detecting and preventing fraudulent activity, money laundering, bonus abuse, multi-accounting, and other prohibited conduct. Milwin's fraud detection systems analyse transaction patterns, device fingerprints, and IP data to identify suspicious activity and protect both the platform and its honest players.

Responsible Gaming

Monitoring betting patterns to identify indicators of problem gambling behaviour, enforcing deposit limits and self-exclusion requests, and providing appropriate support and interventions. This use of data is a core part of Milwin's responsible gaming commitment and is always in the player's interest.

Legal and Regulatory Compliance

Maintaining transaction records as required by applicable financial regulations, responding to lawful requests from regulatory authorities and law enforcement, and complying with anti-money-laundering (AML) and counter-terrorism financing (CTF) obligations where applicable.

Platform Improvement

Analysing aggregated usage data to understand how players use the platform, which features are most valued, where technical issues arise, and how the user experience can be improved. This analysis uses aggregated or anonymised data wherever possible.

Marketing Communications (With Your Consent)

Sending promotional offers, bonus notifications, and game updates to players who have opted in to receive marketing communications. Milwin only uses your contact details for marketing where you have provided explicit consent, and you can withdraw that consent at any time.

Milwin processes personal data on the following legal bases, depending on the specific purpose of the processing activity:

• Contractual necessity: Processing required to fulfil the contract between Milwin and you as a registered player — account creation, payment processing, game delivery, and support. Without this processing, Milwin cannot deliver the service.
• Legitimate interests: Processing that serves Milwin's legitimate business interests, such as fraud prevention, security monitoring, and platform improvement, where those interests are not overridden by your privacy rights.
• Legal obligation: Processing required to comply with applicable laws and regulations, including financial record-keeping requirements and responses to lawful authority requests.
• Consent: Processing for purposes where you have given specific, informed consent — primarily marketing communications and optional personalisation features. Consent can be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

Milwin does not sell or rent personal data to third parties. Data is shared only in the specific circumstances described below, and only to the extent necessary for the stated purpose:

Service Providers and Platform Partners

Milwin shares data with third-party service providers that help operate the platform. These include licensed game providers (Ezugi, Evolution Gaming, and others) who receive game session data to deliver live casino tables; payment processors (Easypaisa, JazzCash, NayaPay, SadaPay, bank systems, and card networks) who receive transaction data to process payments; fraud detection services; and cloud infrastructure providers who host platform data. All service providers are bound by contractual data-sharing agreements that restrict their use of data to the specific purpose for which it is shared.

Legal and Regulatory Disclosure

Milwin may disclose personal data to regulatory authorities, financial intelligence units, law enforcement agencies, or courts where required by applicable law, by a lawful court order, or where disclosure is necessary to protect the safety of players or the public. Milwin will notify affected players of such disclosures where legally permitted to do so.

Business Transfers

In the event of a merger, acquisition, or sale of all or part of Milwin's business, player data may be transferred as part of that transaction. Any acquirer would be bound by this Privacy Policy in respect of the personal data transferred, and Milwin would notify affected players of any such transfer and any material changes to the policy that result.

Data security is taken seriously at Milwin. The following technical and organisational measures are in place to protect your personal data against unauthorised access, loss, disclosure, or destruction:

• Transport encryption: All data in transit between your device and Milwin's servers is protected with 256-bit TLS/SSL encryption. Connections using outdated, insecure protocols are refused.
• Data at rest: Personal data stored in Milwin's systems is encrypted at rest using industry-standard encryption methods. Database access is restricted to authorised personnel only.
• Access controls: Access to systems containing personal data is restricted on a need-to-know basis. Multi-factor authentication is required for all staff accessing sensitive data systems.
• Payment credential isolation: Financial credentials (PINs, passwords, full card numbers) are never received or stored by Milwin. Payment processing is fully delegated to PCI-DSS compliant payment processors.
• Security monitoring: Milwin's systems are continuously monitored for unusual access patterns, intrusion attempts, and data exfiltration indicators.
• Staff training: All Milwin staff with access to personal data undergo data privacy and security training as part of their onboarding and on an ongoing basis.
• Incident response: Milwin maintains documented incident response procedures. In the event of a data breach that poses a risk to players, affected individuals will be notified promptly.

Milwin retains personal data for as long as it is necessary for the purposes for which it was collected, and for as long as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Active account data: Retained for the lifetime of your Milwin account, plus a period of up to five years following account closure to meet financial record-keeping and regulatory obligations.
• Transaction records: Deposit, withdrawal, and betting records are retained for a minimum of five years following the transaction date in accordance with standard financial record-keeping obligations.
• Identity verification documents: Retained for the period required by applicable anti-money-laundering regulations, typically five years from the end of the business relationship.
• Support communications: Retained for up to three years from the date of the last communication to allow resolution of any disputes that may arise.
• Marketing consent records: Retained as long as necessary to demonstrate compliance with consent requirements — typically for the duration of the relationship and up to three years following withdrawal of consent.
• Anonymised or aggregated analytics data: May be retained indefinitely as it no longer constitutes personal data once properly anonymised.

When personal data is no longer required and no legal obligation to retain it remains, Milwin deletes or destroys it in a secure manner that prevents recovery or reconstruction.

The Milwin platform uses cookies and similar tracking technologies to deliver and improve the service. A cookie is a small text file stored on your device by your browser when you visit the platform. Milwin uses the following categories of cookies:

Most browsers allow you to control cookie settings — you can choose to block or delete cookies through your browser settings. Blocking essential cookies will affect your ability to use the Milwin platform. Blocking optional cookies will not affect your ability to play games or manage your account.

As a player on the Milwin platform, you have the following rights in relation to your personal data. To exercise any of these rights, contact Milwin at support@milwin.click with the subject line "Data Rights Request."

The Milwin platform is strictly intended for individuals aged 18 years and above. Milwin does not knowingly collect personal data from individuals under the age of 18.

If Milwin becomes aware that personal data has been collected from a person under 18 — whether through registration, deposit activity, or any other means — that account will be immediately suspended, all data associated with the account will be handled in accordance with applicable laws, and access to any funds will be managed in accordance with Milwin's underage account procedures.

If you are a parent or guardian and believe that a minor in your care has registered on Milwin, please contact support@milwin.click immediately so the account can be reviewed and closed. Milwin takes underage access extremely seriously and will act without delay on credible reports.

Parents and guardians who wish to prevent minors from accessing online gaming services are encouraged to use parental control software that restricts access to gambling-related websites on shared devices.

Milwin reviews and updates this Privacy Policy periodically to reflect changes in the platform, applicable laws, or data protection best practices. When material changes are made, Milwin will notify active players through a prominent notice displayed upon login or through direct communication to registered contact details.

• The date at the top of this page reflects the most recent update.
• Continued use of the Milwin platform after an updated Privacy Policy is published constitutes acceptance of the updated policy.
• If any update involves a material change in how Milwin uses data that was previously collected under a different basis, Milwin will seek fresh consent before implementing the change in respect of that previously collected data where required.
• Previous versions of this Privacy Policy are available on request by contacting support@milwin.click.

If you have any question, concern, or request related to this Privacy Policy or to how Milwin handles your personal data, please get in touch using any of the following channels:

• Email: support@milwin.click — please use the subject line "Privacy Query" or "Data Rights Request" as appropriate.
• Live Chat: Available 24/7 on the Milwin platform — fastest response for general privacy questions.
• WhatsApp: Contact Milwin's bilingual support team for privacy concerns in either English or Urdu.

Milwin commits to responding to all privacy-related communications within 48 hours during normal operating conditions. Data rights requests will be actioned within 30 days of receipt of a verified request.