Privacy Policy

This Privacy Policy ("Policy") sets out how tenwin ("we", "us", "our", the "Operator" or the "Platform") collects, uses, stores, discloses and otherwise processes personal data relating to individuals ("you", "the User", "the Player") who access or use the tenwin platform at tenwin.cam.

tenwin is an English-language online gaming information and platform site targeting players in Pakistan. We are committed to handling your personal data responsibly, transparently and in accordance with applicable data protection principles. This Policy applies to all Users of the Platform regardless of their location, including users based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and other cities across Pakistan.

By registering an account, depositing funds, placing a wager or otherwise accessing any feature of the tenwin Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data-processing activities described herein. If you do not agree to this Policy, please do not use the Platform.

In this Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, contact details, identification documents, financial information and online identifiers.
• "Processing" — any operation or set of operations performed on personal data, including collection, storage, use, transfer, deletion and any other handling.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, the tenwin Operator is the Data Controller.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller under a contractual agreement.
• "KYC" — Know Your Customer identity verification procedures conducted to confirm a User's identity and comply with AML (Anti-Money Laundering) obligations.
• "Cookies" — small text files placed on a User's device by the Platform to support session management, functionality and analytics.
• "Sensitive Personal Data" — personal data of a particularly sensitive nature, including government-issued identity document numbers (such as CNIC), financial account details and similar categories that require enhanced protection.

tenwin collects personal data from various sources. The categories of data collected and their primary sources are set out in the table below:

We do not collect or process sensitive categories of personal data beyond what is necessary for KYC compliance and fraud prevention purposes. We do not collect biometric data, health data or political/religious beliefs.

tenwin processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and the Operator — including account creation, game access, payment processing and withdrawal handling.
• Legal Obligation: Processing required to comply with applicable legal obligations, including KYC identity verification, AML transaction monitoring, record-keeping requirements and reporting to regulatory bodies where obligated by law.
• Legitimate Interests: Processing carried out in pursuit of the Operator's legitimate business interests where those interests are not overridden by your fundamental rights and freedoms — including fraud prevention, platform security, analytics and improving the gaming experience.
• Consent: Where you have provided specific, informed and freely given consent for a particular processing activity — such as receiving marketing communications or the use of non-essential cookies. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5.1 Account ManagementWe use your registration data to create and maintain your account, verify your identity, authenticate your logins and manage account settings including responsible gambling controls such as deposit limits, session timers and self-exclusion requests.

5.2 Transaction ProcessingYour financial and payment data is used to process deposits and withdrawals via available payment rails — which for Pakistan-based Users may include options such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah and cryptocurrency channels where supported. These provider names are used as familiar payment context; we do not imply endorsement of gambling by any payment provider.

5.3 KYC & AML ComplianceIdentity verification and transaction-monitoring data is used to comply with the Operator's Know Your Customer and Anti-Money Laundering obligations. This may involve sharing data with third-party KYC verification service providers under data-processing agreements.

5.4 Fraud Prevention & SecurityDevice data, IP addresses, login history and transaction patterns are analysed to detect and prevent fraudulent activity, account takeovers, bonus abuse and money laundering. Where fraud or criminal activity is identified, data may be shared with relevant authorities.

5.5 Customer SupportCommunication data including support chat transcripts and email correspondence is used to respond to your queries, resolve disputes and improve service quality. Support interactions may be retained for a defined period for quality assurance and regulatory purposes.

5.6 Platform Improvement & AnalyticsAggregated and anonymised usage data is analysed to understand user behaviour, identify technical issues, improve platform performance and develop new features. Where technically possible, analytics are conducted on non-personally-identifiable data.

5.7 Marketing CommunicationsWhere you have opted in to marketing communications, we may send you information about promotions, new games, cricket betting events (including PSL and ICC tournaments), and other Platform features by email or in-platform notification. You may withdraw marketing consent at any time through your account settings or by contacting support.

tenwin does not sell, rent or trade your personal data to third parties for commercial purposes. Your data may be shared in the following limited circumstances:

• KYC & Identity Verification Providers: Third-party services used to perform identity document verification and liveness checks as part of the registration and KYC process. These providers act as Data Processors under contractual data-protection obligations.
• Payment Processors: Financial intermediaries and payment technology providers that facilitate deposit and withdrawal transactions. Data shared is limited to what is necessary to execute the transaction.
• Fraud Prevention & Risk Services: Third-party providers used to assess transaction risk, detect account anomalies and prevent financial crime. Data shared is subject to contractual restrictions on further use.
• Technology & Hosting Providers: Cloud infrastructure and software-as-a-service providers on whose platforms the tenwin Platform is hosted or supported. These providers do not use your data for their own commercial purposes.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order or regulatory instruction, we may disclose personal data to competent authorities. We will notify you of such disclosures where legally permitted to do so.
• Corporate Transactions: In the event of a merger, acquisition or sale of assets, personal data may be transferred to a successor entity. Users will be notified of any such transfer and the privacy protections that apply.

tenwin retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal and regulatory obligations. Retention periods are determined by the nature of the data and the purpose of processing:

• Account and Registration Data: Retained for the duration of the account relationship and for a period of five (5) to seven (7) years following account closure, as required to satisfy AML record-keeping obligations and potential legal proceedings.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification or the end of the business relationship, in compliance with AML regulatory requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years in line with standard AML and financial record-keeping requirements.
• Support Communications: Retained for up to two (2) years from the date of the interaction for quality assurance and dispute resolution purposes.
• Marketing Data: Retained until you withdraw consent or for two (2) years from the last recorded interaction, whichever is earlier.
• Technical/Log Data: Server logs and device data are typically retained for up to twelve (12) months for security and analytics purposes.

Following the expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised. Where anonymisation is applied, the resulting data is no longer subject to this Policy.

tenwin implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration or disclosure. These measures include:

• Transport Layer Security (TLS/HTTPS): All data transmitted between your browser or device and the tenwin Platform is encrypted using industry-standard TLS protocols.
• Access Controls: Access to personal data within the Operator's systems is restricted on a need-to-know basis. Staff with access to personal data are subject to confidentiality obligations.
• Encryption at Rest: Sensitive data categories, including identity documents and payment credentials, are stored using encryption measures appropriate to the sensitivity of the data.
• Authentication Controls: Multi-factor authentication options are available for user accounts. Internal system access by Operator staff requires enhanced authentication.
• Incident Response: The Operator maintains data breach detection and response procedures. In the event of a breach affecting your rights and freedoms, we will notify affected Users and relevant authorities within timeframes required by applicable obligations.

tenwin uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. The categories of cookies we use are described below:

You can manage or block non-essential cookies through your browser settings at any time. Note that disabling functional cookies may affect the Platform's ability to remember your preferences and settings between sessions.

tenwin operates as an international online gaming platform. As a consequence, your personal data may be transferred to and processed in countries other than your country of residence, including countries where the Operator, its technology providers or KYC/payment processors are based.

Where personal data is transferred internationally, the Operator takes steps to ensure that appropriate data-protection safeguards are in place — including contractual data-processing agreements with third-party processors that require them to handle your data in accordance with applicable data-protection standards.

Users based in Pakistan should be aware that Pakistan has its own data-protection framework, and data transferred internationally may be subject to the laws of the receiving country. By using the tenwin Platform, you consent to such transfers as described in this Policy.

Depending on applicable data-protection law, you may hold some or all of the following rights in relation to your personal data held by tenwin. To exercise any of these rights, contact our support team using the details in Section 15.

The tenwin Platform is strictly intended for use by adults aged 18 years and above, or the higher minimum age required by the operator's license jurisdiction. The Platform is not directed at, and should not be used by, any person under this age threshold.

tenwin does not knowingly collect personal data from minors. Where we become aware or have reasonable grounds to believe that a User is under the applicable minimum age, we will immediately suspend the account, delete associated personal data and, where required, report the matter to relevant authorities.

If you are a parent or guardian and believe that a person under the applicable minimum age has registered on our Platform, please contact us immediately at the support email address listed in Section 15. We take child protection obligations seriously and will act promptly on verified reports.

The tenwin Platform does not include links to third-party external websites in its public-facing navigation or content (in accordance with the Platform's link policy). Where game technology partners or payment-processing infrastructure is provided by third-party services, those providers operate under separate terms and privacy policies.

tenwin is not responsible for the privacy practices of third-party technology or payment providers whose services are integrated within the Platform's backend infrastructure. Data shared with such providers is limited to what is strictly necessary for the provision of the relevant service and is governed by data-processing agreements.

tenwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, data-processing practices or Platform functionality. Where amendments are material, we will provide notice by updating the "Last Updated" date at the top of this page and, where appropriate, by notifying registered Users via email or in-platform notification.

We encourage you to review this Policy periodically. The current version of this Policy is always accessible at this URL. Your continued use of the Platform following publication of an updated Policy constitutes your acceptance of the revised terms.

If you have any questions, concerns or requests relating to this Privacy Policy or the handling of your personal data, please contact the tenwin support team using the details below. All privacy-related inquiries are handled with confidentiality and are addressed within 30 days of receipt.

Support Email: [email protected]

Live Chat: Available 24/7 via the operator-provided support widget on the Platform.

Email Response Time: Within 24 hours on business days. Data-rights requests and privacy complaints may require up to 30 days for full resolution.

When submitting a data-rights request, please include your registered email address and a brief description of the data category or request type to assist us in responding efficiently. We may request identity verification before acting on your request.