Privacy Policy
How 45win Collects,
Uses & Protects Your Data

This Privacy Policy ("Policy") describes the data practices of 45win ("45win", "we", "us", "our"), the operator of the online gaming platform located at 45win.im. 45win acts as the data controller in respect of personal data collected from users ("you", "Player", "User") of the 45win platform.

This Policy applies to all personal data collected through the 45win website, mobile-optimised platform, and any related 45win communications — including registration forms, KYC submissions, payment transactions, live chat interactions, and email correspondence with 45win support. It applies to all registered players and visitors to 45win.im, including players from across Pakistan — Karachi, Lahore, Islamabad, Faisalabad, and all other cities.

This Privacy Policy should be read together with 45win's Terms and Conditions and Responsible Gaming Policy, which together form the complete framework governing your use of the 45win platform. In the event of any conflict between this Policy and another 45win document, this Policy shall govern in respect of data privacy matters.

45win collects personal data across several categories. The table below summarises the main data types, the context in which they are collected, and the primary purpose of collection:

45win does not intentionally collect sensitive personal data beyond what is strictly required for identity and age verification (such as CNIC/passport data). Where such sensitive data is collected, it is handled with the highest level of technical and organisational security measures.

45win collects personal data through the following channels and mechanisms:

• Direct submission by you: When you register a 45win account, complete the KYC verification process, make a deposit or withdrawal, contact 45win support via live chat or email, or update your account settings, you directly provide personal data to 45win.
• Automated collection: When you access and navigate the 45win platform, technical data — including your IP address, device identifiers, browser information, and session activity — is automatically collected through server logs, cookies, and similar tracking technologies.
• Payment processors: When you initiate a financial transaction through JazzCash, EasyPaisa, a Pakistani bank transfer, or a cryptocurrency network, payment-related data is transmitted to and from the relevant payment service provider. 45win receives confirmation and reference data relating to the transaction.
• KYC and identity verification partners: 45win may use licensed third-party identity verification services to assist with the KYC process. These providers process identity document images and return verification status data to 45win. The handling of your data by these providers is governed by their own privacy policies, which comply with the data processing requirements imposed by 45win.
• Third-party game providers: Game studios and content providers whose games are available on the 45win platform may collect gameplay data as part of the game operation. Such data collection is governed by the contractual arrangements between 45win and its licensed game providers.

45win processes your personal data on the basis of one or more of the following legal grounds, depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between you and 45win — including account management, game access, payment processing, and customer support — is carried out on the basis of contractual necessity.
• Legal obligation: 45win is subject to anti-money laundering (AML), counter-terrorism financing (CTF), and responsible gaming obligations under its international gaming license. Processing necessary to meet these legal obligations — including KYC verification, transaction monitoring, and responsible gaming record-keeping — is carried out on the basis of legal obligation.
• Legitimate interests: Certain processing activities — including fraud detection, platform security monitoring, and analytical activities aimed at improving the 45win platform — are carried out on the basis of 45win's legitimate interests, provided that these interests are not overridden by your rights and interests.
• Consent: Where 45win processes your data for marketing communications or optional personalisation features, we rely on your consent as the legal basis. You may withdraw consent for such processing at any time through your account settings or by contacting support.

45win uses the personal data collected from you for the following specific purposes:

• Creating, managing, and maintaining your 45win player account.
• Verifying your identity and age as part of the mandatory KYC process before withdrawal of funds.
• Processing deposits and withdrawals through your chosen payment methods — JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, or USDT.
• Monitoring gaming activity to detect and prevent problem gambling, in fulfilment of 45win's responsible gaming obligations under its operating license.
• Detecting, preventing, and investigating fraudulent activity, bonus abuse, money laundering, and other prohibited conduct as defined in the 45win Terms and Conditions.
• Providing customer support, resolving disputes, and responding to regulatory or law enforcement inquiries.
• Sending you transactional notifications relating to your 45win account — such as deposit confirmations, withdrawal status updates, and account security alerts.
• Sending marketing communications about 45win promotions and offers, where you have provided consent for such communications.
• Analysing aggregated, anonymised usage data to improve the performance, reliability, and user experience of the 45win platform.
• Complying with legal, regulatory, and licensing obligations applicable to 45win as an international online gaming operator.

45win does not sell your personal data. We share personal data with third parties only where necessary and under strict contractual data protection obligations. The categories of third parties with whom 45win may share your data are:

• Payment service providers: JazzCash, EasyPaisa, and banking partners (HBL, UBL, Meezan Bank, Raast, 1LINK) receive financial data necessary to process deposits and withdrawals. USDT transactions are processed via blockchain networks, where transaction data is inherently public by the nature of the technology.
• KYC and identity verification providers: Licensed third-party verification services process identity document data to assist 45win in meeting its KYC obligations. These providers are bound by contractual data protection obligations consistent with applicable data protection standards.
• Game content providers: Licensed game studios and content providers whose games are accessible through the 45win platform may process gameplay data as technically necessary to operate their games.
• Technology infrastructure providers: Cloud hosting, security, and platform infrastructure providers process data as technical necessities of operating the 45win platform. All such providers are bound by data processing agreements.
• Regulatory and law enforcement authorities: 45win will disclose personal data to relevant government authorities, regulators, or law enforcement bodies where required to do so by applicable law, court order, or the conditions of its operating license.
• Professional advisers: 45win's legal advisers, auditors, and compliance consultants may access personal data where necessary in the course of providing professional services to 45win, subject to professional confidentiality obligations.

The 45win platform uses cookies and similar tracking technologies to operate key platform functions, maintain your session, and analyse how players use the platform. Cookies are small text files placed on your device when you access 45win.im.

The following categories of cookies are used on the 45win platform:

• Strictly necessary cookies: These cookies are essential to the operation of the 45win platform — for example, maintaining your logged-in session, storing your language preference, and enabling payment checkout flows. These cookies cannot be disabled without impairing platform functionality.
• Performance and analytics cookies: These cookies collect anonymised or aggregated data about how players navigate the 45win platform — such as which pages are most visited, session duration, and error occurrences. This data is used to improve platform performance and user experience.
• Functional cookies: These cookies remember your preferences and settings — such as display preferences and responsible gaming tool configurations — to personalise your 45win experience across sessions.
• Security cookies: These cookies are used to detect and prevent fraudulent or abusive access to the 45win platform, including bot detection and session integrity verification.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent you from logging in to your 45win account or using certain platform features. Details of specific cookies in use, including their names and durations, are available in the 45win Cookie Information section accessible through your account settings.

45win retains personal data for as long as is necessary to fulfil the purpose for which it was collected and to comply with applicable legal and regulatory obligations. The following general retention principles apply:

• Account data: Retained for the duration of your active 45win account relationship, plus a minimum period following account closure as required by applicable AML and gaming regulations — typically five (5) years.
• KYC and identity documents: Retained for a minimum of five (5) years following the end of the customer relationship, in compliance with anti-money laundering regulatory requirements.
• Transaction records: Financial transaction data is retained for a minimum of five (5) years following the date of the transaction, as required by applicable financial regulations.
• Gaming activity data: Retained for the duration of the active account relationship and for a reasonable period thereafter for responsible gaming review, dispute resolution, and regulatory compliance purposes.
• Support communications: Live chat transcripts and email correspondence are retained for up to three (3) years following the last interaction, unless a longer retention period is required for ongoing dispute resolution or legal proceedings.
• Technical and log data: Server logs and technical access records are typically retained for up to twelve (12) months for security and fraud monitoring purposes.

Where personal data is no longer required for any legitimate purpose or legal obligation, 45win will securely delete or anonymise it. Anonymised aggregate data — from which individuals cannot be identified — may be retained indefinitely for statistical and analytical purposes.

45win implements a comprehensive range of technical and organisational security measures to protect your personal data from unauthorised access, loss, alteration, or disclosure. Key security measures include:

• SSL/TLS encryption for all data transmitted between your device and the 45win platform.
• Encryption at rest for sensitive personal data and KYC documents stored in 45win's systems.
• Access controls ensuring that 45win staff can only access personal data on a strict need-to-know basis, commensurate with their role and responsibilities.
• Multi-factor authentication requirements for internal 45win systems that process personal data.
• Regular security assessments, penetration testing, and vulnerability management processes.
• Incident response procedures to detect, contain, and notify in the event of a data breach, consistent with applicable regulatory requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 45win will notify you without undue delay and will take all technically and organisationally feasible steps to contain and remediate the breach.

As a data subject whose personal data is processed by 45win, you have the following rights. These rights are subject to applicable legal limitations — for example, 45win cannot delete data that it is legally required to retain under AML regulations.

• Right to Access: You have the right to request a copy of the personal data 45win holds about you, along with information about how it is being processed.
• Right to Rectification: If any personal data 45win holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure ("Right to be Forgotten"): You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations.
• Right to Restriction of Processing: You may request that 45win restrict the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to Data Portability: Where processing is based on your consent or on a contract, you have the right to receive your personal data in a structured, commonly used format to enable transfer to another service provider where technically feasible.
• Right to Object: You have the right to object to processing of your personal data carried out on the basis of 45win's legitimate interests, including profiling for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please contact 45win support via the live chat inside your account dashboard or by emailing [email protected]. 45win will respond to data subject requests within a reasonable timeframe and no later than the period required by applicable data protection law. We may need to verify your identity before processing your request.

The 45win platform is strictly intended for adults aged 21 years and older. 45win does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory component of the KYC process, and accounts determined to belong to persons under 21 will be immediately suspended and any data held will be handled in accordance with applicable legal requirements.

Parents and guardians are encouraged to use parental control software and internet filters to prevent minors from accessing gambling and gaming websites. 45win supports responsible gaming initiatives that aim to prevent underage gambling across the industry.

45win operates as an international online gaming platform under an international gaming license. As a result, personal data collected from players in Pakistan may be transferred to and processed in jurisdictions outside of Pakistan — including jurisdictions where 45win's infrastructure providers, payment processors, and compliance partners operate.

Where personal data is transferred internationally, 45win implements appropriate safeguards to ensure that your data continues to be protected in accordance with the standards set out in this Privacy Policy. These safeguards may include:

• Contractual data transfer clauses requiring recipients to maintain equivalent data protection standards.
• Selection of service providers based in jurisdictions recognised as providing adequate data protection standards.
• Technical measures such as encryption to protect data in transit and at rest regardless of processing location.

If you require further information about the specific jurisdictions in which your data may be processed or the safeguards applied to international data transfers, please contact 45win support.

45win reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in our data practices, changes in applicable law, or changes in the structure of the 45win platform. When material changes are made, 45win will make reasonable efforts to notify registered players — for example, by displaying a notice on the platform or by sending an email to the address associated with your account.

The "Effective Date" and "Last Reviewed" dates at the beginning of this Policy indicate when this version was published. It is your responsibility to periodically review this Policy to stay informed of any updates. Continued use of the 45win platform following the publication of a revised Privacy Policy constitutes your acceptance of the revised Policy.

Previous versions of this Privacy Policy are available upon request by contacting 45win support.

If you have any questions about this Privacy Policy, wish to exercise any of your data protection rights, or have concerns about how 45win processes your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 inside your 45win account dashboard — the fastest way to reach our support and compliance teams.
• Email: [email protected] — for formal data subject requests and privacy inquiries.

45win maintains a designated Data Protection Officer (DPO) responsible for overseeing data protection compliance and handling data subject inquiries. Formal data protection inquiries may be addressed to the attention of the DPO via the above contact channels.

45win is committed to resolving all data protection concerns promptly, transparently, and in good faith. Your privacy matters to us, and we welcome your feedback on how we can continue to improve our data practices.