Privacy Policy

Introduction

This Privacy Policy ("Policy") is issued by Malwin ("Malwin", "we", "us", "our"), the operator of the online gambling platform accessible at malwin.cam ("the Platform"). It describes how we collect, use, disclose, store and protect the personal data of individuals ("Users", "you", "your") who register for, access or use the Platform.

By registering an Account or continuing to use the Platform, you acknowledge that you have read, understood and agree to the data practices described in this Policy. If you do not agree, please discontinue use of the Platform and contact us to request account closure.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference and govern your use of the Platform.

Definitions

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

• "Account" — the individual registered user account created on the Platform.
• "Cookie" — a small text file placed on your device by the Platform to support functionality, analytics and preference management.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For this Platform, Malwin acts as the data controller for User data collected through the Site.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller under contractual instruction.
• "KYC" — Know Your Customer: identity and age verification processes required by the Operator before certain Account activities (particularly withdrawals) are permitted.
• "Personal Data" — any information relating to an identified or identifiable natural person, including name, contact details, financial information and device identifiers.
• "Platform" — the malwin website, mobile-optimised site and any associated applications available at malwin.cam.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, amendment and deletion.
• "User" — any individual who registers for, accesses or uses the Platform.

Data We Collect

Malwin collects personal data in several categories depending on how you interact with the Platform. The categories of data we may collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on official identity documents.
• Date of birth (for age verification purposes).
• Residential address, including city — which may include Pakistani cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar.
• Email address used for account registration and communications.
• Username and hashed/encrypted password credentials.
• Mobile or telephone number, where provided during registration.

3.2 KYC & Verification Documents

• Government-issued identity documents such as a Pakistani CNIC (Computerised National Identity Card), passport or driving licence.
• Proof of address documentation where required.
• Source of funds documentation, where required by the Operator's compliance procedures.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts (displayed in PKR), dates and method references.
• Payment method identifiers — for example, mobile wallet references associated with familiar Pakistani payment contexts such as Easypaisa, JazzCash, Raast or bank account details for HBL, UBL, Meezan Bank or Bank Alfalah transfers. These references are for transaction processing records only and do not imply endorsement by those providers.
• Wagering and gaming activity records, including bet amounts, game types, outcomes and session data.

3.4 Technical & Device Data

• IP address and approximate geolocation data.
• Device type, operating system and browser information.
• Session identifiers, login timestamps and access logs.
• Cookie data and similar tracking technologies as described in Section 10.

3.5 Communications Data

• Records of communications between you and Malwin's support team via Live Chat, Help Center or email.
• Responses to surveys or feedback requests, where voluntarily provided.

How We Collect Data

Personal data is collected through the following channels:

• Direct collection: Data you provide when registering an Account, completing KYC, making a deposit or withdrawal, contacting support, or responding to surveys.
• Automated collection: Data collected automatically through cookies, web beacons and server logs as you browse and use the Platform.
• Third-party sources: Data received from identity verification services, fraud prevention databases and payment processing intermediaries in connection with KYC and transaction processing.
• Responsible gambling tools: Data generated through your use of limit-setting tools, cooling-off requests and self-exclusion features, which is processed to manage your account restrictions.

Data Processing & Purpose

Malwin processes personal data only for specific, lawful purposes. The table below sets out the primary purposes for which your data is processed:

• Account management: Creating, maintaining and managing your registered Account, including authentication and security.
• Identity verification (KYC): Verifying your identity and age to comply with the Operator's licensing obligations and prevent underage gambling.
• Transaction processing: Processing deposits, withdrawals and wager settlements in PKR, and maintaining accurate financial records.
• Regulatory compliance: Complying with anti-money laundering (AML), counter-terrorism financing (CTF) and other applicable regulatory requirements imposed on the Operator by its licensing jurisdiction.
• Fraud prevention: Detecting, investigating and preventing fraudulent activity, bonus abuse, multi-accounting and other prohibited conduct.
• Responsible gambling: Managing limit settings, cooling-off periods and self-exclusion requests to protect vulnerable Users.
• Customer support: Responding to your enquiries, resolving disputes and maintaining records of support interactions.
• Platform improvement: Analysing aggregated usage data to improve Platform performance, user experience and content relevance.
• Marketing communications: Sending promotional offers and updates, where you have given consent or where permitted by applicable law. You may opt out at any time.

Legal Basis for Processing

Where data protection frameworks require a legal basis for processing, Malwin relies on the following grounds, as applicable to each processing activity:

• Contractual necessity: Processing required to perform the contract between you and Malwin — including account creation, transaction processing and support.
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC, AML and CTF obligations.
• Legitimate interests: Processing for fraud prevention, security monitoring and Platform improvement, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where your consent has been obtained. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

Data Sharing & Disclosure

Malwin does not sell, rent or trade your personal data to third parties for their own independent commercial purposes. We may share your personal data with the following categories of recipients for the purposes described in this Policy:

7.1 Service Providers & Data Processors

Third-party service providers who process data on our behalf under contractual data processing agreements, including:

• KYC and identity verification service providers.
• Payment processing intermediaries (which may include references to locally familiar Pakistani payment infrastructure such as Easypaisa, JazzCash, Raast or banking intermediaries).
• Fraud detection and AML screening providers.
• Cloud hosting and infrastructure providers.
• Customer support platform providers.
• Analytics and Platform performance tools.

7.2 Regulatory & Law Enforcement Authorities

We may disclose personal data to regulators, law enforcement agencies or courts where required to do so by applicable law, court order or regulatory instruction. We will use reasonable endeavours to notify you of such a requirement unless doing so is prohibited by law.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of Malwin's business, personal data may be transferred to the successor entity as part of that transaction. Affected Users will be notified of any such transfer that materially affects the processing of their personal data.

Data Retention

Malwin retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulatory obligation. The following general retention guidelines apply:

• Account data: Retained for the duration of your Account and for a minimum period following account closure as required by the Operator's licensing obligations.
• KYC documents: Retained for a minimum of five (5) years following account closure, or such longer period as required by applicable AML or regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years following the transaction date.
• Support communications: Retained for a reasonable period to support dispute resolution and service quality improvement.
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter for compliance record-keeping.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

User Rights

Subject to applicable data protection law, you have the following rights in relation to your personal data held by Malwin:

To exercise any of these rights, please contact Malwin's support team via Live Chat or the Help Center. We will respond to verified requests within a reasonable timeframe. Please note that certain rights may be limited or unavailable where data is required for legal compliance, fraud prevention or Operator licensing obligations.

Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the Platform. They are used to support Platform functionality, remember your preferences, maintain login sessions, support responsible gambling tool settings and analyse usage patterns.

10.2 Categories of Cookies Used

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management, login state and security cookies. They cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences, language settings and display options to improve your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how Users interact with the Platform, used to improve performance and content relevance.
• Marketing Cookies: Used to deliver relevant promotional content, where you have given consent. These may track your activity across sessions.

10.3 Cookie Management

You can manage and disable non-essential cookies through your browser settings or through any cookie preference mechanism presented on the Platform. Disabling certain cookies may affect Platform functionality or your ability to access certain features.

Data Security

Malwin implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• Encryption of data in transit using Transport Layer Security (TLS).
• Encryption of sensitive data at rest, including KYC documents and payment information.
• Access controls limiting personal data access to authorised personnel on a need-to-know basis.
• Regular security reviews and vulnerability assessments of Platform infrastructure.
• Secure data disposal procedures upon expiry of retention periods.

Notwithstanding these measures, no internet transmission or storage system can be guaranteed as completely secure. If you have reason to believe that your Account has been compromised, please notify Malwin's support team immediately via Live Chat or the Help Center.

Children's Privacy

The Platform is strictly for adults aged 18 and over — or the higher minimum age required by the Operator's license jurisdiction. Malwin does not knowingly collect personal data from individuals under the age of 18.

If we become aware that personal data has been collected from a minor, we will take prompt steps to delete that data and close the associated Account. Parents or guardians who believe that a minor has registered on the Platform should contact us immediately via Live Chat or the Help Center.

International Data Transfers

Malwin operates internationally and your personal data may be transferred to, stored or processed in countries other than Pakistan. These countries may have data protection laws that differ from those applicable in Pakistan.

Where personal data is transferred internationally, Malwin uses appropriate safeguards to ensure that the data continues to be protected to a standard consistent with this Policy. These safeguards may include contractual clauses with data processors, adherence to recognised international data transfer frameworks, or transfer to jurisdictions with adequate data protection standards as assessed by the Operator's legal counsel.

Third-Party Services

The Platform may reference or interact with third-party services — for example, payment processing intermediaries or identity verification providers. Malwin is not responsible for the privacy practices of third-party services. References to payment brands such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah in this Policy are contextual only and do not indicate confirmed data processing relationships with those entities.

Where we engage third-party data processors, we do so under contractual data processing agreements that impose appropriate data protection obligations on those processors, consistent with the standards described in this Policy.

Policy Amendments

Malwin reserves the right to update or amend this Privacy Policy at any time. Where amendments are material — for example, where we introduce a new processing purpose or change how we share data — we will notify registered Users via email or a prominent Platform notice before the amendments take effect.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, please discontinue use of the Platform and contact us to request account closure.

The date of the most recent update to this Policy is displayed at the top of this page. We encourage you to review this Policy periodically.

Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact Malwin's support team through the following channels:

• Live Chat: Available via the Platform 24 hours a day, 7 days a week.
• Help Center: Accessible from the support section of the Platform.
• Email (plain text only): [email protected]

The email address above is displayed as plain text only and is not a clickable link. For data subject rights requests — such as access, correction or deletion requests — please contact us via Live Chat or the Help Center and clearly state the nature of your request. We will respond within a reasonable timeframe following identity verification.