Privacy Policy

Introduction

10wln ("Platform", "Operator", "We", "Us") operates the online gaming and sports betting platform at https://10wln.cam. This Privacy Policy ("Policy") describes how 10wln collects, processes, stores, shares and protects the personal data of users ("Player", "User", "You") who access or use the Platform.

This Policy forms part of and should be read alongside the 10wln Terms & Conditions. By creating an Account, using the Platform or submitting personal information to 10wln, you acknowledge that you have read this Policy and consent to the processing of your personal data as described herein.

10wln is committed to protecting the privacy of its users and to handling personal data responsibly. We process personal data only where we have a lawful basis to do so and limit collection to what is genuinely necessary for the purposes described in this Policy.

Definitions

The following defined terms are used throughout this Policy:

• "Personal Data" — any information that identifies, or could reasonably be used to identify, a living individual, whether directly or indirectly.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, erasure and destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For this Platform, the Data Controller is 10wln.
• "Data Processor" — a third party that processes personal data on behalf of 10wln under a contractual data-processing agreement.
• "Consent" — a freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose.
• "KYC" — Know Your Customer: identity and age verification procedures required by the Operator and applicable compliance frameworks.
• "Cookies" — small text files placed on your device by the Platform to remember preferences, maintain sessions and collect analytical data.
• "Special Category Data" — data revealing racial or ethnic origin, political opinions, religious beliefs, health, biometric or genetic data, which receives heightened protection under applicable privacy frameworks.

Personal Data We Collect

10wln collects the following categories of personal data from users, depending on how you interact with the Platform:

Identity & Registration Data

• Full legal name, date of birth and gender;
• National identity information — CNIC number and/or Pakistani passport number where submitted for KYC;
• Username and account credentials (passwords are stored in hashed form and are never viewable by staff).

Contact Data

• Email address;
• Mobile phone number (used for account security and, with consent, SMS notifications);
• Residential address — required where proof of address is requested for KYC compliance.

Financial & Transaction Data

• Deposit and withdrawal history, including amounts in PKR and applicable payment method references;
• Payment method identifiers — such as mobile wallet account identifiers associated with Easypaisa or JazzCash references, or bank account identifiers for bank-transfer methods — where provided. Full payment credentials are handled by licensed payment processors and are not stored by 10wln;
• Source-of-funds information where required by enhanced due-diligence procedures.

Gambling Activity Data

• Bet history, game session data, wager amounts and outcomes;
• Responsible gambling preferences, including deposit limits, session limits and self-exclusion status;
• Bonus and promotional activity.

Technical & Device Data

• IP address, browser type and version, operating system and device identifiers;
• Session timestamps, page-view data and navigation paths within the Platform;
• Geolocation data derived from IP address (not GPS-level precision).

Communications Data

• Records of support conversations via live chat or email;
• Voluntary feedback and survey responses.

How Personal Data Is Collected

Personal data is collected through the following means:

• Direct submission — data you provide when registering an Account, completing KYC verification, making a deposit, contacting support or filling in any Platform form;
• Automated collection — technical and session data collected automatically when you access the Platform, including via cookies and similar tracking technologies;
• Third-party sources — identity verification data returned by our licensed KYC verification partners following document checks; fraud-screening data from licensed fraud-prevention services; and payment status data from payment processors;
• Publicly available sources — where permitted by applicable law and necessary for compliance purposes, such as sanctions-screening databases.

Purposes of Processing

10wln processes personal data for the following purposes:

Account Management & Service Delivery

To create, maintain and administer your Account; to authenticate your identity at login; to process deposits, wagers and withdrawals; and to deliver the games, betting products and features available on the Platform.

Identity Verification & Compliance (KYC/AML)

To verify your identity and age in compliance with the Operator's licensing obligations; to conduct Anti-Money Laundering (AML) checks; and to screen against applicable sanctions lists. This processing is mandatory — without it, withdrawals cannot be approved and Account functionality may be restricted.

Responsible Gambling

To administer responsible gambling tools including deposit limits, session limits, cooling-off periods and self-exclusion; to monitor gambling patterns that may indicate problem gambling; and to contact players where concern is identified.

Security & Fraud Prevention

To protect the integrity of the Platform, detect and prevent fraud, identify unauthorised access and investigate security incidents. This includes IP monitoring, device fingerprinting and transaction monitoring.

Customer Support

To respond to Account queries, technical support requests, complaints and responsible gambling requests, including records of communications for quality assurance and dispute resolution.

Marketing & Promotions

Where you have given explicit consent, to send you promotional communications about bonuses, new games, sports betting markets and platform updates via email or SMS. Consent may be withdrawn at any time from your Account settings or by contacting support.

Platform Improvement & Analytics

To understand how the Platform is used, identify technical issues, measure feature performance and improve the overall user experience — including for Pakistani users across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.

Legal Basis for Processing

10wln relies on one or more of the following lawful bases for each category of processing activity:

• Contractual necessity — processing required to provide the service you have agreed to under the Terms & Conditions, including Account management, payment processing and game access;
• Legal obligation — processing required to comply with applicable legal and regulatory obligations, including KYC/AML requirements under the Operator's licensing terms;
• Legitimate interests — processing necessary for 10wln's legitimate operational interests, including fraud prevention, security monitoring, IT operations and analytics, where those interests are not overridden by your privacy rights;
• Consent — processing for marketing communications and non-essential cookies, where your explicit consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Data Sharing & Third Parties

10wln does not sell, rent or trade your personal data to third parties for commercial marketing purposes. Personal data is shared only in the following limited circumstances and only with parties subject to appropriate contractual data-protection obligations:

Licensed Service Providers (Data Processors)

• KYC verification partners — licensed identity-verification service providers who process identity documents and return verification results;
• Payment processors — licensed payment service providers who handle deposit and withdrawal transactions. Payment method references familiar to Pakistani users — such as those associated with Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — are handled by respective providers under their own privacy terms. 10wln does not claim that these providers endorse gambling;
• Fraud-prevention services — licensed third-party services that screen transactions and account activity for signs of fraud or financial crime;
• IT infrastructure and hosting providers — cloud and server infrastructure providers under strict data-processing agreements;
• Customer support platforms — tools used to manage live chat, email and ticketing support interactions.

Regulatory & Legal Disclosures

10wln may be required to disclose personal data to regulatory authorities, law enforcement agencies, financial intelligence units or courts where required or permitted by applicable law, including obligations arising from the Operator's licensing terms. 10wln will not disclose more than is required by the relevant legal obligation.

Business Transfers

In the event of a merger, acquisition, restructuring or sale of assets involving 10wln, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any change to applicable privacy terms before the transfer takes effect, where reasonably practicable.

Data Retention

10wln retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or for such longer period as is required or permitted by applicable law or regulatory obligation.

The following general retention principles apply:

• Active Account data — retained for the duration of your Account and for a minimum period following Account closure as required by the Operator's applicable licensing terms (typically 5 years from Account closure);
• Transaction and financial data — retained for the period required by applicable AML, licensing and financial record-keeping obligations (typically a minimum of 5 years);
• KYC and identity documents — retained for the period required by the applicable licensing and AML framework;
• Support communication records — retained for up to 3 years following the close of the relevant interaction, unless a longer period is required for dispute resolution;
• Marketing consent records — retained until consent is withdrawn and for a reasonable period thereafter as evidence of lawful processing;
• Technical logs and session data — retained for operational security purposes for a limited rolling period.

Where personal data is no longer required, it is deleted or anonymised in accordance with 10wln's data-deletion procedures.

Data Security

10wln implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration or disclosure. Key security measures include:

• HTTPS/TLS encryption for all data transmitted between your browser or app and 10wln's servers;
• Industry-standard cryptographic hashing of account passwords — plaintext passwords are never stored or visible to staff;
• Access controls limiting staff access to personal data on a strict need-to-know basis;
• Two-factor authentication options for player Accounts;
• Regular security assessments and monitoring of Platform infrastructure;
• Contractual data-security obligations imposed on all third-party processors.

While 10wln takes security seriously, no platform operating over the internet can guarantee absolute security. You are responsible for maintaining the confidentiality of your own Account credentials. If you suspect unauthorised access to your Account, contact support at [email protected] immediately.

Cookies & Tracking Technologies

10wln uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies may be placed on your device:

Strictly Necessary Cookies

These cookies are essential to the operation of the Platform and cannot be disabled. They include session authentication cookies, security tokens and load-balancing cookies. No consent is required for strictly necessary cookies.

Functional Cookies

These cookies remember your preferences — such as your display language, currency selection (PKR), responsible gambling settings and device type — to provide a consistent experience across sessions.

Analytical Cookies

With your consent, analytical cookies collect aggregated data about how the Platform is used — including page views, session duration and navigation paths. This data is used to identify technical issues and improve Platform performance.

Marketing Cookies

Where consent has been given, marketing cookies may be used to measure the effectiveness of promotional campaigns. You may withdraw consent for marketing cookies at any time from your Account settings.

You can also manage cookies through your browser settings; however, disabling strictly necessary cookies may impair Platform functionality. Continued use of the Platform with cookies enabled in your browser indicates acceptance of functional and analytical cookies where consent is not separately requested.

International Data Transfers

Given that 10wln is an internationally operating platform with infrastructure and service providers located in various jurisdictions, personal data may be transferred to and processed in countries outside Pakistan. Such transfers may be to jurisdictions that do not have data-protection laws equivalent to those in Pakistan.

Where personal data is transferred internationally, 10wln takes reasonable steps to ensure that the transfer is subject to appropriate safeguards — which may include contractual data-transfer clauses, binding corporate rules or the equivalent in the relevant jurisdiction — to ensure that your data continues to be processed in a manner consistent with the principles of this Policy.

By using the Platform, you acknowledge that your personal data may be transferred to, stored and processed outside Pakistan.

Your Data Rights

Subject to applicable law and any overriding compliance obligations, you have the following rights in relation to your personal data held by 10wln:

To exercise any of these rights, contact 10wln at [email protected]. We will acknowledge your request promptly and respond within a reasonable timeframe, subject to identity verification to prevent unauthorised access to your data. Requests may be declined where they conflict with mandatory legal or regulatory obligations — in which case we will explain the reason.

Minors

The 10wln Platform is strictly for adults aged 18 or older, or the higher minimum age required by the Operator's license jurisdiction. 10wln does not knowingly collect personal data from individuals under the applicable minimum age. If you are a parent or guardian and believe that a minor has provided personal data to 10wln without your knowledge, please contact [email protected] immediately. Upon verification, we will delete the relevant data and close any associated Account.

Third-Party Links & Integrations

The 10wln Platform may contain references to, or be integrated with, third-party services — including payment processors and identity-verification providers — which are subject to their own privacy policies. 10wln is not responsible for the privacy practices of third-party services and this Policy does not apply to the independent collection of data by those services.

Payment method names familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — represent independent services with their own terms and privacy policies. 10wln does not control and is not responsible for data handling by those providers. Their mention is for contextual familiarity only and does not imply a formal partnership, endorsement of gambling or any data-sharing arrangement beyond what is necessary for payment processing where applicable.

Changes to This Privacy Policy

10wln reserves the right to update or modify this Privacy Policy at any time. Where changes are material — such as a change to the categories of data collected, a new purpose for processing or a change to data-sharing arrangements — we will provide reasonable advance notice via a prominent notice on the Platform and/or by email to your registered address.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the changes. We recommend reviewing this Policy periodically, particularly before submitting sensitive documents or registering a new Account.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to raise a concern about how your personal data is being handled, please contact the 10wln team using the details below. Our support team provides assistance in English, with Urdu-language assistance available on request.

Email: [email protected]
This is a plain-text address. Copy and paste it into your email client. Do not attempt to click it as a mailto link.

All data-subject requests should be submitted in writing to the support email address, including your Account username and a description of your request. We will acknowledge receipt promptly and may require identity verification before processing the request.