milwan Privacy Policy – How We Handle Your Personal Data

1. Introduction

milwan ("we", "us", "our", or the "Company") operates the online gaming platform accessible at milwan.bet. This Privacy Policy explains how milwan collects, uses, stores, and protects personal data provided by users ("you", "your", or the "Player") in connection with account registration, gameplay, deposits, withdrawals, customer support interactions, and all other platform services.

milwan takes the privacy of its players seriously. We have designed our data practices to be proportionate, transparent, and compliant with applicable data protection standards under our international gaming licence. This document has been written in plain, accessible English so that players across Pakistan can understand exactly how their personal information is being handled.

This Privacy Policy should be read alongside milwan's Terms and Conditions, which govern the overall relationship between you and milwan. Together, these two documents form the foundation of your player agreement with milwan.

2. Data Controller Identity

For the purposes of applicable data protection law, milwan is the data controller in respect of the personal data collected from and processed about its registered players. As data controller, milwan is responsible for determining the purposes and means by which your personal data is processed.

milwan operates under an international gaming licence. Our data processing activities are conducted in accordance with the data protection requirements stipulated by our licensing authority. Any queries regarding data controller identity or our licensing jurisdiction should be directed to our support team at the contact address provided in Section 15 of this Policy.

3. Personal Data We Collect

milwan collects personal data from you through several channels: directly from you during registration and account management, automatically through your use of the platform, and from third-party identity verification and payment processing partners. The categories of data we collect include:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (for age verification – milwan is a 21+ platform)
• Residential address, including city and postal code
• Email address (used for account communications and notifications)
• Mobile telephone number (used for account security and verification)
• Copies of identity documents submitted for KYC verification (CNIC, passport, or equivalent)
• Proof of address documents where required for verification

3.2 Financial and Transaction Data

• Deposit and withdrawal transaction records in PKR
• Payment method identifiers (such as JazzCash wallet number, EasyPaisa account, bank name, or partial card details)
• Account balance history and transaction timestamps
• Bonus and promotional credit records

3.3 Gaming and Behavioural Data

• Gameplay history including game titles played, stake amounts, and outcomes
• Sports betting selections, stake amounts, and settlement results
• Session duration, login timestamps, and session frequency
• Responsible gaming tool settings including deposit limits and self-exclusion records

3.4 Technical Data

• IP address at the time of account access
• Browser type, version, and operating system
• Device type and device identifiers
• Referring URL and navigation path data
• Cookie identifiers (see Section 9)

3.5 Communications Data

• Content of customer support correspondence via email
• Records of complaints, disputes, and their resolutions
• Preferences and consents relating to marketing communications

4. How milwan Uses Your Personal Data

milwan uses the personal data collected from players for specific, defined purposes. We do not use your data for any purpose that is incompatible with the purposes listed below without first obtaining your explicit consent:

4.1 Marketing Communications

milwan will only send you promotional emails, bonus notifications, and platform news where you have given explicit consent to receive such communications at the time of registration or through your account settings. You may withdraw consent for marketing communications at any time by updating your account preferences or contacting milwan support. Withdrawal of marketing consent does not affect your ability to use the platform or receive service-related communications such as account notifications and transaction confirmations.

5. Legal Basis for Processing

milwan processes your personal data on the following legal bases, depending on the purpose of processing:

• Contractual necessity: Processing required to fulfil our obligations under the player agreement with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws and our international gaming licence conditions, including KYC verification, anti-money laundering checks, and responsible gaming obligations.
• Legitimate interests: Processing carried out for milwan's legitimate business interests where these interests are not overridden by your data protection rights, including fraud prevention, platform security, and service analytics.
• Consent: Processing carried out only where you have provided a clear, informed, and freely given consent, including direct marketing communications and the use of non-essential cookies.

6. Sharing Your Personal Data

milwan does not sell, rent, or trade your personal data to any third party for commercial gain. We share your personal data only in the following defined circumstances:

6.1 Service Providers and Data Processors

milwan engages carefully selected third-party service providers who process personal data on our behalf to support the delivery of platform services. These include:

• KYC and identity verification providers – to verify the identity and age of players during account registration and at subsequent verification points.
• Payment processing partners – including processors facilitating transactions via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard, for the purpose of completing deposits and withdrawals in PKR.
• Game software providers – who may receive session and gameplay data necessary to deliver their game content on the milwan platform.
• Fraud and AML screening services – who assist milwan in detecting suspicious activity, verifying payment source legitimacy, and fulfilling anti-money laundering obligations.
• Customer support platforms – used to manage player communications, support tickets, and complaint records.
• Analytics and platform performance providers – who receive anonymised or aggregated technical and behavioural data to support site optimisation.

All third-party data processors engaged by milwan are contractually bound to process personal data only on milwan's documented instructions and to maintain appropriate technical and organisational security measures.

6.2 Regulatory and Law Enforcement Authorities

milwan may be required to disclose your personal data to regulatory authorities, gaming licence bodies, financial intelligence units, or law enforcement agencies where such disclosure is required by law or by a binding order. milwan will notify affected players of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of milwan's business assets, your personal data may be transferred to the acquiring entity as part of the transaction. milwan will endeavour to provide reasonable notice of any such transfer and ensure that the acquiring entity is bound by privacy obligations no less protective than those set out in this Policy.

7. International Data Transfers

milwan operates as an internationally licensed platform and, as a result, your personal data may be transferred to and processed in countries outside Pakistan. This includes transfers to countries where milwan's data processing infrastructure, identity verification partners, or game software providers are located.

Where personal data is transferred internationally, milwan takes steps to ensure that appropriate safeguards are in place to protect your data in the destination country. These safeguards may include contractual data transfer agreements, standard contractual clauses, or confirmation that the destination country provides an adequate level of data protection as assessed under our licensing framework.

By using milwan and providing your personal data, you acknowledge and consent to the transfer of your data to jurisdictions outside Pakistan as described in this section.

8. Data Retention

milwan retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements applicable to our gaming licence.

As a general principle, milwan retains account-related personal data for a minimum period of five (5) years following account closure or the date of the last transaction, whichever is the later. This retention period reflects our obligations under anti-money laundering regulations applicable to licensed gaming operators.

Transaction records, including deposit and withdrawal histories in PKR, are retained for a minimum of five years for AML and audit purposes. KYC documentation is retained for the same minimum period from the date of verification. Customer support correspondence is retained for three years from the date of the most recent interaction.

Technical data including IP logs and session records may be retained for shorter periods for security and fraud detection purposes, typically twelve months, unless retention for a longer period is required in connection with a specific investigation or legal proceeding.

Upon expiry of the applicable retention period, milwan will securely delete or anonymise personal data so that it can no longer be attributed to an individual.

9. Cookies and Tracking Technologies

milwan uses cookies and similar tracking technologies on the milwan.bet platform. Cookies are small text files stored by your browser on your device when you visit a website. They allow milwan to maintain your session, remember your preferences, and analyse how the platform is being used.

9.1 Types of Cookies milwan Uses

• Strictly necessary cookies: Essential for the platform to function correctly. These include session authentication cookies that keep you logged in during your visit. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences and settings, such as display language and notification preferences, to provide a more personalised experience.
• Performance and analytics cookies: Collect anonymised information about how players use the milwan platform, including pages visited, time spent on each section, and error encounters. This data is used solely to improve platform performance.
• Security cookies: Support milwan's fraud detection and platform security systems by helping identify unusual or suspicious access patterns.

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse non-essential cookies, delete existing cookies, and configure alerts when cookies are being placed. Please note that disabling certain cookies may affect the functionality of the milwan platform, including the ability to maintain a logged-in session.

milwan does not use third-party advertising or behavioural targeting cookies. No cookie data collected by milwan is shared with external advertising networks.

10. Your Data Subject Rights

As a player on milwan, you hold the following rights in respect of your personal data. milwan will respond to all valid data subject requests within thirty (30) days of receipt, and without charge in most circumstances:

• Right of access: You may request a copy of the personal data that milwan holds about you, along with information about how it is being processed.
• Right to rectification: You may request that milwan corrects any inaccurate or incomplete personal data held about you. For basic account details such as your email address or phone number, you can update these directly within your account settings.
• Right to erasure: In certain circumstances, you may request that milwan deletes your personal data. This right is subject to milwan's legal and regulatory retention obligations – milwan is required to retain certain data for a minimum period under its gaming licence and AML obligations.
• Right to restrict processing: You may request that milwan restricts the processing of your personal data in certain circumstances, for example while a correction request is being assessed.
• Right to data portability: Where processing is based on your consent or on a contractual basis and is carried out by automated means, you may request that milwan provides your personal data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing carried out on the basis of milwan's legitimate interests. milwan will cease such processing unless it can demonstrate compelling legitimate grounds that override your rights.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

11. Children and Minors

milwan is strictly an adults-only platform. The minimum age requirement for registration and participation on milwan is 21 years of age. milwan does not knowingly collect personal data from individuals under the age of 21.

milwan employs automated age verification checks during registration and reserves the right to request documentary proof of age at any point during a player's account lifecycle. Where milwan discovers that personal data has been collected from a person under 21, the relevant account will be immediately suspended, all associated data will be deleted to the extent permitted by law, and any funds in the account will be handled in accordance with milwan's Terms and Conditions and applicable regulations.

If you are a parent or guardian and believe that your child under the age of 21 has registered on milwan or submitted personal data to milwan, please contact our support team immediately so that the appropriate steps can be taken without delay.

12. Security Measures

milwan implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes:

• Encryption: Personal data transmitted between your device and milwan's servers is protected using Transport Layer Security (TLS) encryption. Stored personal data is encrypted at rest.
• Access controls: Access to personal data within milwan is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged and audited.
• Intrusion detection: milwan's platform is monitored for suspicious activity using automated intrusion detection systems.
• Regular security assessments: milwan conducts periodic reviews of its information security practices to identify and address vulnerabilities.
• Password security: Account passwords are stored in hashed form using industry-standard algorithms. milwan staff cannot view your password in plaintext.

While milwan takes all reasonable steps to protect your personal data, no internet-based platform can provide absolute security guarantees. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, milwan will notify affected players as soon as reasonably practicable.

You also play an important role in keeping your account secure. Please ensure your milwan account password is strong and unique, and do not share your login credentials with any other person. If you suspect unauthorised access to your account, contact milwan support at [email protected] immediately.

13. Third-Party Links and Services

The milwan platform may contain references to third-party services such as payment processors and game providers. milwan is not responsible for the privacy practices or content of any third-party services. When you interact with a third-party service in connection with your milwan account – for example, completing a JazzCash or EasyPaisa transaction through your mobile banking application – you do so subject to that third party's own privacy policy and terms.

milwan recommends that players review the privacy policies of any third-party services they interact with in connection with their milwan account activity.

14. Updates to This Privacy Policy

milwan reserves the right to update or revise this Privacy Policy at any time. Where changes are material, milwan will notify registered players by email to the registered account address or via a prominent notice on the platform prior to the changes taking effect. The effective date at the top of this Policy will be updated with each revision.

Your continued use of the milwan platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the revised policy. If you do not agree to the revised policy, you should discontinue use of milwan and may request account closure in accordance with milwan's Terms and Conditions.

We encourage all players across Pakistan – whether in Karachi, Lahore, Islamabad, Faisalabad, or elsewhere – to review this Privacy Policy periodically so they remain informed about how milwan is protecting their data.

15. Contact Information and Data Queries

For any questions, concerns, or requests relating to this Privacy Policy or the personal data milwan holds about you, please contact our team:

• Email: [email protected]
• Subject Line: Privacy Request – [Your Registered Username]
• Response Time: Data-related requests acknowledged within 5 business days; full response within 30 days
• Support Hours: 24 hours a day, 7 days a week

When submitting a data-related request, please include your registered username and a clear description of your request or concern. milwan may need to verify your identity before processing any access, rectification, or erasure request to ensure that personal data is not disclosed to or modified by an unauthorised party.