milwan Privacy Policy – How We Handle Your Personal Data

1. Who We Are

milwan ("milwan", "we", "us", "our") operates the online sports betting and casino platform accessible at milwan.app. milwan is the data controller in respect of personal data collected from users of the platform. This Privacy Policy applies to all services offered under the milwan brand, including the sportsbook, milwan Casino, slots lobby, loyalty programme, and all associated account features.

For any privacy-related enquiry, including the exercise of your data rights, you may contact milwan using the support details provided in Section 16 of this Policy. All contact is by plain-text communication — no automated personal data should be shared in initial enquiry messages.

2. Data We Collect

milwan collects personal data in several categories depending on the nature of your interaction with the platform:

Identity Data: Full name, date of birth, CNIC number or passport number, gender, and nationality. This data is collected during registration and may be supplemented during KYC verification.

Contact Data: Mobile phone number (typically in +92 format for Pakistani players), email address, and city or region of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad).

Financial Data: Payment method identifiers such as JazzCash account numbers, Easypaisa mobile wallet details, bank account information for HBL, UBL, Meezan Bank, or Bank Alfalah transfers, Visa/Mastercard last four digits, and USDT wallet addresses. milwan does not store full card numbers — card payments are processed through PCI-DSS compliant payment processors who hold card data on milwan's behalf.

Transaction Data: A complete record of deposits, withdrawals, bets placed, casino sessions, bonus usage, and account balance changes.

Technical Data: IP address, browser type and version, device type, operating system, time zone, screen resolution, and session duration logs.

Usage Data: Pages visited on milwan, navigation paths, search queries within the platform, game preferences, betting patterns, and feature usage frequency.

Verification Data: Copies of identity documents, selfie verification images, and proof of address documents submitted during KYC.

Communications Data: Records of your communications with milwan's support team, including chat logs, email correspondence, and any feedback or dispute records.

3. How We Collect Your Data

milwan collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC, making a deposit, or contacting milwan support;
• Automated technical collection: Data gathered automatically when you access the milwan platform, including IP address logging, cookie data, and session analytics;
• Third-party providers: Identity verification agencies, payment processors, fraud prevention services, and analytics providers who share data with milwan in connection with the services they perform on our behalf;
• Publicly available sources: Where milwan is legally required to conduct enhanced due diligence, information from publicly available registers or databases may be used to supplement identity verification.

4. How We Use Your Data

milwan uses your personal data for the following purposes:

• To create and manage your milwan account, including identity verification and KYC compliance;
• To process deposits and withdrawals through your chosen payment method and maintain accurate transaction records;
• To deliver the sportsbook, milwan Casino, and slots services — including settlement of bets, crediting of winnings, and application of bonuses;
• To operate the milwan loyalty programme and calculate tier status, cashback, and associated benefits;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited conduct;
• To comply with applicable legal and regulatory obligations, including anti-money laundering, counter-terrorism financing, and age verification requirements;
• To communicate with you regarding your account, including transaction confirmations, security alerts, and service updates;
• To send marketing communications where you have consented or where milwan has a legitimate interest in communicating relevant offers to existing customers;
• To conduct platform analytics, improve milwan's products and services, and personalise your experience;
• To administer milwan's responsible gaming programme, including monitoring for problematic play patterns and delivering limit and self-exclusion tools.

5. Legal Basis for Processing

milwan processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil the milwan user agreement — account management, payment processing, bet settlement, and customer support;
• Legal obligation: Processing required to comply with applicable laws — KYC/AML verification, age verification, financial record-keeping, and regulatory reporting;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your data protection rights;
• Consent: Processing for direct marketing communications, optional analytics cookies, and any other processing for which milwan has requested and received your express consent. You may withdraw consent at any time.

6. Data Sharing & Disclosure

milwan does not sell your personal data to any third party. milwan may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate confidentiality and data protection obligations:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, Visa/Mastercard networks, Skrill, Neteller, and USDT processing partners, to the extent necessary to execute your transactions;
• Identity verification providers: Third-party KYC and document verification services that process identity documents on milwan's behalf;
• Fraud and AML screening providers: Services used to screen transactions and accounts against sanctions lists and fraud databases;
• Platform and technology providers: Cloud hosting providers, casino game suppliers, analytics platforms, and customer support tools operating under data processing agreements with milwan;
• Legal and regulatory authorities: Where milwan is required by law, court order, or regulatory direction to disclose personal data — including to financial intelligence units in connection with anti-money laundering obligations;
• Successors in business: In the event of a corporate restructuring, merger, or acquisition, personal data held by milwan may be transferred to the successor entity, subject to equivalent privacy protections.

7. Cookies & Tracking Technologies

milwan uses cookies and similar tracking technologies on the platform. Cookies are small data files stored on your device that help milwan recognise returning users, maintain login sessions, prevent fraud, and understand how the platform is used.

Essential cookies are necessary for the platform to function — they maintain your logged-in session and remember preferences such as language. These cannot be disabled without impairing platform functionality.

Analytics cookies collect anonymised data about how players navigate milwan — which pages are visited most frequently, where users spend the most time, and how they move through the deposit flow. This data is used to improve the platform experience.

Marketing cookies track whether you arrived at milwan through a particular affiliate link or campaign, allowing milwan to attribute registrations accurately and manage its marketing spend. These are active only where consent has been given.

You may manage your cookie preferences at any time through your browser settings. Disabling essential cookies will affect your ability to use the milwan platform.

8. Data Retention

milwan retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and transaction records: Retained for a minimum of five years following account closure, as required by applicable financial record-keeping and anti-money laundering regulations;
• KYC verification documents: Retained for a minimum of five years following the last transaction associated with the account;
• Self-exclusion records: Retained indefinitely to prevent re-registration by self-excluded players;
• Support communications: Retained for three years following the last interaction, or longer where a dispute is pending;
• Marketing consent records: Retained until consent is withdrawn, plus a reasonable period thereafter to demonstrate compliance.

On expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be associated with any individual.

9. Data Security

milwan implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. Security measures include:

• TLS encryption for all data transmitted between your device and the milwan platform;
• Encryption of personal data at rest in milwan's databases;
• Access controls limiting milwan staff access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of the platform infrastructure;
• Two-factor authentication options for player accounts to prevent unauthorised login;
• Incident response procedures for the detection and notification of data security breaches.

No internet transmission is completely secure. While milwan takes all reasonable steps to protect your data, players are also responsible for maintaining the security of their own device and milwan login credentials.

10. Your Rights

Subject to applicable law, you have the following rights in respect of your personal data held by milwan:

• Right of access: You may request a copy of the personal data milwan holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data;
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to milwan's legal retention obligations;
• Right to restriction: You may request that milwan restrict processing of your data in certain circumstances, such as while a dispute is under investigation;
• Right to data portability: You may request a copy of data you have provided to milwan in a structured, machine-readable format;
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing;
• Right to object: You may object to processing based on legitimate interests, including direct marketing.

To exercise any of these rights, contact milwan support using the details in Section 16. milwan will respond to verified requests within a reasonable period. Identity verification may be required before milwan can process a data rights request.

11. Children's Privacy

milwan is strictly an 18+ platform. milwan does not knowingly collect personal data from persons under the age of 18. If milwan discovers that personal data has been collected from a minor, that account will be immediately closed, any balance forfeited, and the associated personal data deleted. If you believe a minor has registered on milwan, please notify us immediately using the support contact in Section 16.

12. International Data Transfers

milwan may process or store personal data on servers located outside Pakistan. Where personal data is transferred internationally, milwan ensures that appropriate safeguards are in place — such as contractual data protection clauses — to protect your data to a standard equivalent to that required under applicable data protection principles.

13. Third-Party Links

The milwan platform may contain references to third-party services — such as payment providers — where contextually necessary. milwan is not responsible for the privacy practices of third-party platforms. This Privacy Policy applies solely to data processed by milwan in connection with the milwan platform. Players should review the privacy policies of any third-party service they use in connection with milwan transactions.

14. Marketing Communications

milwan may send you promotional communications about bonuses, new features, seasonal offers, and platform updates. Existing players may receive such communications based on milwan's legitimate interest in communicating relevant offers to its customer base, unless you have opted out. New registrations may be asked to explicitly opt in to marketing at the time of account creation.

You may opt out of marketing communications at any time by updating your communication preferences in your milwan account settings, or by notifying milwan support. Opt-out requests are processed within five business days. Note that opting out of marketing does not affect transactional communications about your account.

15. Changes to This Privacy Policy

milwan may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or platform features. Material changes will be communicated to registered players via the email address on file or through a prominent notice on the milwan platform. The date at the top of this Policy reflects when it was last updated. Continued use of the milwan platform after the effective date of any revision constitutes acceptance of the updated Policy.

16. Contact Us

For any questions, concerns, or data rights requests relating to this Privacy Policy or milwan's data practices, please contact the milwan support team. Our registered support email is [email protected] — displayed as plain text only and not a clickable link. Please include "Privacy" in your subject line to ensure your message is routed to the appropriate team.