bwina Privacy Policy – How We Handle Your Data

1. What Information We Collect

bwina collects personal information from you in several ways — directly when you register or use the platform, automatically through your device and browser, and occasionally from third-party sources as part of our verification processes.

The table below summarises the main categories of data we collect and why:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information unless it is directly relevant to a responsible gaming request you have made.

2. How We Use Your Information

bwina uses the personal data we collect for specific, legitimate purposes. We do not use your data in ways that are incompatible with the reason it was originally collected.

• To create and manage your bwina account and verify your identity.
• To process deposits and withdrawals via bKash, Nagad, and Rocket.
• To detect and prevent fraud, money laundering, and other illegal activity.
• To comply with legal and regulatory obligations, including anti-money laundering requirements.
• To provide customer support and resolve disputes.
• To send you account-related notifications such as security alerts and transaction confirmations.
• To send you promotional communications, if you have opted in to receive them.
• To monitor your gaming activity for responsible gaming purposes and intervene if necessary.
• To improve the bwina platform based on how players use it.
• To enforce our Terms and Conditions and protect the rights of bwina and its players.

When we use your data for marketing purposes, we will always give you a clear way to opt out. If you opt out, we will stop sending marketing communications within a reasonable timeframe, though you will still receive essential account-related messages.

3. Legal Basis for Processing

bwina processes your personal data on the following legal grounds:

• Contract performance: Processing your data is necessary to provide the bwina service you have signed up for, including account management and payment processing.
• Legal obligation: We are required to collect and retain certain data to comply with anti-money laundering laws, age verification requirements, and other applicable regulations.
• Legitimate interests: We process some data to protect the security of the platform, prevent fraud, and improve our services — provided these interests do not override your privacy rights.
• Consent: Where we rely on your consent — for example, for marketing communications — you can withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. Sharing Your Information

bwina does not sell your personal data. We share your information only in the following limited circumstances:

• Payment processors: We share necessary financial data with bKash, Nagad, and Rocket to process your transactions. These providers have their own privacy policies and security standards.
• Identity verification providers: We may share identity documents with third-party KYC verification services to confirm your age and identity as required by our compliance obligations.
• Game providers: When you play games on bwina, the relevant game provider may receive technical data such as your session ID and game activity. They do not receive your full personal profile.
• Legal authorities: We may disclose your data to law enforcement or regulatory bodies if required by law or in response to a valid legal request.
• Business transfers: In the event of a merger, acquisition, or sale of bwina's business, your data may be transferred to the new entity. You will be notified of any such transfer.

5. Cookies and Tracking

bwina uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse how the site is used. Cookies are small text files stored on your device when you visit bwina.

• Essential cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. You cannot opt out of these.
• Functional cookies: Remember your preferences such as language settings and display options. These improve your experience but are not strictly necessary.
• Analytics cookies: Help us understand how players use bwina — which pages are visited most, where users drop off, and how the platform performs. This data is aggregated and anonymised.
• Marketing cookies: Used to deliver relevant promotional content. These are only active if you have consented to marketing communications.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the bwina platform. For the mobile app, similar tracking technologies are used and can be managed through your device's app permissions settings.

6. Data Retention

bwina retains your personal data for as long as your account is active and for a period after account closure as required by law and our internal policies. The specific retention periods depend on the type of data:

• Account and identity data is retained for a minimum of five years after account closure to comply with anti- money laundering regulations.
• Transaction records are retained for a minimum of five years from the date of the transaction.
• Support communications are retained for three years after the matter is resolved.
• Marketing consent records are retained for as long as you remain opted in, plus two years after opt-out.
• Technical and usage data is typically retained for 12 months before being anonymised or deleted.

When your data is no longer required, bwina will securely delete or anonymise it. If deletion is not immediately possible due to technical constraints, we will isolate the data from further processing until deletion can be completed.

7. How We Protect Your Data

bwina takes data security seriously. We have implemented a range of technical and organisational measures to protect your personal information against unauthorised access, loss, alteration, or disclosure.

• All data in transit is protected by TLS 1.2 or higher encryption.
• Sensitive data at rest is encrypted using AES-256 or equivalent standards.
• Access to personal data within bwina is restricted to staff who genuinely need it to perform their role.
• All staff with access to personal data receive regular training on data protection obligations.
• Our systems are monitored continuously for suspicious activity and potential security incidents.
• We conduct regular security assessments and penetration testing to identify and address vulnerabilities.

While we do everything we can to protect your data, no system is completely immune to risk. You also play a role in keeping your account secure — use a strong, unique password for your bwina account and never share your login credentials with anyone.

8. Your Privacy Rights

As a bwina user, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team at [email protected]. We will respond within a reasonable timeframe and without charging a fee for standard requests.

• Right of access: You can request a copy of the personal data bwina holds about you.
• Right to rectification: If any of your personal data is inaccurate or incomplete, you can ask us to correct it.
• Right to erasure: You can request that we delete your personal data where there is no legitimate reason for us to continue holding it. Note that some data must be retained for legal compliance reasons even after account closure.
• Right to restrict processing: You can ask us to pause the processing of your data in certain circumstances, for example while a dispute is being resolved.
• Right to data portability: You can request a copy of your data in a structured, machine-readable format.
• Right to object: You can object to processing based on legitimate interests, including profiling for marketing purposes.
• Right to withdraw consent: Where processing is based on your consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

If you are not satisfied with how bwina has handled your personal data or a privacy request, you have the right to raise a complaint with the relevant data protection authority in your jurisdiction.

9. Children's Privacy

bwina is strictly an adult platform. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, you must not register or attempt to use bwina.

If we become aware that we have inadvertently collected personal data from a minor, we will delete that data immediately and close the associated account. If you believe a minor has registered on bwina, please contact our support team right away so we can investigate and take appropriate action.

10. Contact and Complaints

If you have any questions about this Privacy Policy, want to exercise your data rights, or have a concern about how bwina has handled your personal information, please get in touch with us:

• Email: [email protected]
• Live Chat: Available 24/7 through the bwina platform.

We take all privacy concerns seriously and aim to respond to every inquiry within 72 hours. If your concern relates to a data breach or urgent security matter, please mark your message as urgent and we will prioritise it accordingly.

bwina may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make significant changes, we will notify you by email and display a notice on the platform. The "Last Updated" date at the top of this page always reflects the most recent version.

Continuing to use bwina after an updated Privacy Policy takes effect means you accept the revised terms. If you do not agree with any changes, you should stop using the platform and contact us to close your account.