win21 Privacy Policy — How We Handle Your Data

⚡ Privacy at a Glance

1. Introduction

win21 is committed to protecting the privacy of everyone who uses our platform. This Privacy Policy applies to all personal information collected by win21 in connection with your use of the win21 website, mobile site, and any related services. By registering an account or using win21, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and use of your personal information as described herein.

This Privacy Policy should be read alongside the win21 Terms & Conditions, which together govern your relationship with win21. If you do not agree with this Privacy Policy, you should not use win21. Questions about this policy may be directed to our support team at any time.

2. Data Controller

For the purposes of this Privacy Policy, win21 is the data controller responsible for your personal information. win21 determines the means and purposes of processing your personal data when you use the platform. All data-related enquiries and requests to exercise your rights should be directed to win21's support team via the live chat facility on the platform, or by email at [email protected].

3. Information We Collect

win21 collects the following categories of personal information from or about you when you use the platform:

4. How We Use Your Information

win21 uses your personal information for the following purposes, each of which is underpinned by a lawful basis as described in Section 5:

• To register and manage your win21 account, verify your identity, and confirm your eligibility to use the platform.
• To process deposits, withdrawals, and other financial transactions on your account via bKash, Nagad, Rocket, and other supported payment methods.
• To provide customer support and respond to your enquiries, complaints, and account-related requests.
• To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct, and to comply with our anti-money laundering (AML) and Know Your Customer (KYC) obligations.
• To monitor gameplay and betting behaviour for responsible gaming purposes, including identifying players who may be displaying signs of problem gambling.
• To send you service communications, security alerts, account notifications, and — where you have provided consent — promotional offers and bonus information relevant to your activity on win21.

5. Legal Basis for Processing

win21 processes your personal data on one or more of the following legal grounds, depending on the nature and purpose of the processing activity:

• Contractual necessity: Processing required to register your account, deliver our gaming services, process financial transactions, and honour withdrawal requests.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform performance optimisation, and responsible gaming oversight — activities that protect both win21 and its players.
• Legal obligation: Processing required to comply with applicable laws, including AML regulations, KYC requirements, and regulatory reporting obligations.
• Consent: Processing for direct marketing communications and promotional messaging, which occurs only where you have specifically consented to receive such communications. You may withdraw consent at any time.

6. Sharing Your Information

win21 does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. We may share your personal information in the following limited circumstances only:

• Service providers: Third-party companies that assist win21 in delivering its services, including payment processors (bKash, Nagad, Rocket), identity verification providers, fraud prevention partners, and IT infrastructure suppliers. These providers are contractually bound to process your data only as instructed by win21 and for no other purpose.
• Legal and regulatory authorities: Where win21 is required by applicable law, court order, or regulatory authority to disclose personal data, we will comply with such obligations. We will notify you where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of win21's business assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.
• Fraud and crime prevention: Where we have reasonable grounds to believe that sharing data with law enforcement or a fraud prevention organisation is necessary to protect win21 or its players from criminal activity, we may share relevant information.

7. Payment Data and Financial Privacy

win21 processes financial transactions in Bangladeshi Taka via bKash, Nagad, and Rocket. When you make a deposit or request a withdrawal, win21 records transaction reference numbers, amounts, timestamps, and the payment method used. win21 does not store full mobile wallet account credentials or complete payment authentication details on its own servers — these are handled directly by the respective payment service providers under their own security protocols.

Financial transaction records are retained for the period required by applicable law and regulatory requirements. These records may be used in the investigation and resolution of payment disputes and are provided to regulatory authorities when legally required.

8. Cookies and Tracking Technologies

win21 uses cookies and similar tracking technologies to operate the platform, enhance your experience, and analyse usage patterns. The cookies used by win21 fall into the following categories:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in during a gaming session and security cookies that protect against cross-site request forgery. These cookies cannot be disabled.
• Performance and analytics cookies: Used to collect anonymised information about how players use win21 — including pages visited, session length, and error reports — to help us improve the platform. These do not identify you personally.
• Functional cookies: Remember your preferences such as language settings and game display options to provide a more personalised experience on return visits.

You may adjust your browser settings to refuse or delete cookies at any time. Please note that disabling strictly necessary cookies will affect the functionality of the win21 platform and you may be unable to access certain features, including your account.

9. Data Retention

win21 retains your personal data for as long as your account remains active and for a defined period thereafter, in accordance with applicable legal and regulatory requirements. Specifically: account registration data and KYC verification documents are retained for a minimum of five years following account closure; financial transaction records are retained for a minimum of five years; gameplay and betting records are retained for a minimum of three years. After the applicable retention period has expired, your personal data is securely deleted or anonymised.

Where you have requested self-exclusion from win21, we retain sufficient personal data to enforce that exclusion and prevent re-registration during the exclusion period. This retention is in your interest and is based on our legitimate interest in operating a responsible gaming platform.

10. Your Data Rights

As a user of win21, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team via live chat or email:

• Right of access: You may request a copy of the personal data win21 holds about you. We will provide this within a reasonable timeframe upon verification of your identity.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to any legal retention obligations that require us to retain it.
• Right to restrict processing: You may request that we limit the way we use your personal data in certain circumstances, for example where you contest the accuracy of the data we hold.
• Right to data portability: Where processing is based on your consent or on a contract, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where our processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

11. Data Security

win21 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include 256-bit SSL encryption for all data in transit, access controls that restrict internal access to personal data on a strict need-to-know basis, regular security assessments and vulnerability testing, and secure server infrastructure with firewall protection.

While win21 takes all reasonable steps to safeguard your data, no internet-based platform can guarantee absolute security. You also have a responsibility to protect your own account by keeping your login credentials confidential and by notifying win21 immediately if you suspect any unauthorised access to your account.

12. Children and Minors

win21 is strictly intended for players who are 21 years of age or older. win21 does not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that information and close the associated account. If you believe that a minor has registered on win21, please contact our support team immediately.

13. Third-Party Links and Services

The win21 platform may reference or integrate with third-party services such as payment providers (bKash, Nagad, Rocket) and game content providers (Pragmatic Play, Evolution Gaming, and others). These third parties operate their own privacy policies and data practices, which are independent of win21. win21 is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of win21.

14. Changes to This Privacy Policy

win21 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will display a prominent notice on the platform and update the "Last updated" date at the top of this page. Your continued use of win21 following any changes to this Privacy Policy constitutes your acceptance of the revised policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. Contact Us About Privacy

If you have any questions, concerns, or requests relating to this Privacy Policy or the way win21 handles your personal data, please contact our support team. Our support team is available 24/7 via live chat on the win21 platform and responds to all privacy-related queries in Bangladesh Standard Time (BST, UTC+6).

You may also reach us by email at [email protected]. For urgent privacy matters, we recommend using the live chat facility for the fastest response. We aim to acknowledge all privacy enquiries within 24 hours and to resolve them fully within 30 days.