Privacy Policy – wln7 Data Protection Commitment

1.Who We Are – Data Controller Identity

1.1 For the purposes of this Privacy Policy, wln7 is the data controller responsible for the personal data of players and visitors collected through the wln7.com platform. wln7 operates under an international gaming license and is responsible for determining the purposes and means by which your personal data is processed.

1.2 As a data controller, wln7 is legally accountable for ensuring that all personal data processing activities described in this policy are carried out on a valid lawful basis, are proportionate to the stated purpose, and are conducted in a manner that respects the rights and freedoms of the individuals whose data is being processed.

1.3 If you have any questions about how wln7 uses your data or wish to exercise any of your data rights, please contact the wln7 Data Protection team using the details set out in Section 14 of this policy.

2.Personal Data We Collect

2.1 wln7 collects personal data in several categories depending on the nature of your interaction with the platform. The following table sets out the categories of personal data collected and the primary context in which each category arises:

2.2 wln7 does not intentionally collect special category data (such as health information, racial or ethnic origin, religious beliefs, or biometric data) from Players. If any such data is incidentally disclosed during support communications, it will not be stored beyond the immediate operational need that prompted its disclosure.

3.How We Collect Your Data

3.1 wln7 collects personal data through the following primary methods:

• Direct Submission: Data you provide directly during account registration, KYC document upload, support contact, or promotional opt-in processes.
• Automated Technical Collection: Data collected automatically when you access wln7.com, including IP addresses, device identifiers, and browser characteristics collected via server logs and cookies. See Section 7 for full cookie details.
• Payment Provider Data: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 processing partners when deposits or withdrawals are initiated.
• KYC Verification Partners: Identity verification data cross-referenced through our licensed KYC service providers to confirm the accuracy of documents submitted by Players.
• Fraud and AML Detection Systems: Behavioural and transactional signals processed by our automated fraud detection infrastructure to identify suspicious account activity.

3.2 wln7 does not purchase personal data lists or obtain personal data from data brokers for marketing or any other purpose.

4.Lawful Basis for Processing

4.1 wln7 processes personal data only where a valid lawful basis exists under applicable data protection law. The following lawful bases apply to wln7's processing activities:

• Contractual Necessity: Processing required to perform the contract between wln7 and the Player — including account management, payment processing, game access, and withdrawal fulfilment.
• Legal Obligation: Processing required to comply with wln7's obligations under its international gaming license, including KYC verification, anti-money laundering (AML) record-keeping, and regulatory reporting to licensing authorities.
• Legitimate Interests: Processing necessary for wln7's legitimate business interests where those interests are not overridden by the Player's rights — including fraud prevention, platform security, responsible gaming monitoring, and product analytics used to improve the player experience.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for optional marketing communications such as promotional emails and SMS notifications about bonuses, new games, or PSL cricket betting offers. Consent may be withdrawn at any time via Account Settings without affecting the lawfulness of prior processing.

4.2 Where wln7 relies on legitimate interests as a lawful basis, a legitimate interests assessment has been carried out to ensure that the relevant processing is necessary, proportionate, and balanced against the privacy rights of Players. Summaries of these assessments are available upon written request to the Data Protection team.

5.How We Use Your Personal Data

5.1 wln7 uses the personal data described in Section 2 for the following specific purposes:

• Creating, maintaining, and securing your wln7 Account, including authentication and password reset procedures.
• Processing PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 — and maintaining transaction records as required by our AML obligations.
• Conducting identity verification (KYC) to confirm your eligibility to hold a wln7 Account and to comply with our licensing requirements.
• Providing access to live dealer games, slot titles, jackpot products, cricket betting markets, and all other wln7 platform features.
• Delivering customer support through live chat and email, including investigating complaints, processing disputes, and maintaining records of support interactions for quality assurance.
• Monitoring account activity for signs of problem gambling and proactively engaging responsible gaming tools where wln7's systems identify behavioural indicators of concern.
• Detecting, investigating, and preventing fraud, cheating, money laundering, and other prohibited activities as defined in our Terms & Conditions.
• Sending transactional communications essential to your Account, such as deposit confirmations, withdrawal status updates, and security alerts.
• Sending optional marketing communications about promotions, bonuses, and new platform features — only where you have given explicit consent and only until that consent is withdrawn.
• Conducting anonymised and aggregated platform analytics to understand how players across Karachi, Lahore, Islamabad, and Faisalabad use wln7, in order to improve product features and user experience.
• Complying with any lawful request from a regulatory authority, court, or law enforcement body with jurisdiction over wln7's operations.

5.2 wln7 does not use personal data for automated decision-making that produces legal or similarly significant effects on Players without human review, except where such processing is required by our AML obligations and is subject to oversight by our compliance team.

6.Data Sharing and Third Parties

6.1 wln7 does not sell personal data. Personal data is shared with third parties only in the following limited circumstances, and only to the minimum extent necessary for the stated purpose:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 network processors receive the transactional data necessary to execute deposit and withdrawal instructions.
• KYC and Identity Verification Providers: Licensed third-party verification services receive identity document data for the purpose of confirming document authenticity and cross-referencing against sanctions and PEP screening lists as required by our AML policy.
• Game Content Providers: RNG and live dealer game suppliers may receive anonymised session identifiers to support game round resolution, technical support, and payout verification. No personally identifiable information is shared with game providers beyond what is technically necessary.
• Fraud and Security Vendors: Our automated fraud detection infrastructure may involve data processing by specialist security vendors operating under binding data processing agreements with wln7.
• Regulatory and Legal Authorities: wln7 will disclose personal data to its licensing authority, relevant financial intelligence units, or law enforcement agencies where required by law, court order, or regulatory directive. wln7 will notify affected Players of such disclosures where legally permitted to do so.
• Cloud and Hosting Infrastructure: Personal data is stored on servers operated by enterprise-grade cloud infrastructure providers. All hosting arrangements are governed by data processing agreements that prohibit sub-processors from using wln7 player data for any purpose other than infrastructure provision.

6.2 All third-party data processors engaged by wln7 are required to implement technical and organisational security measures equivalent to or exceeding wln7's own data protection standards. wln7 maintains a current register of active data processors, summaries of which are available to Players upon request.

7.Cookies and Tracking Technologies

7.1 wln7 uses cookies and similar tracking technologies to support platform functionality, security, and performance analytics. The following cookie categories are in use on wln7.com:

• Strictly Necessary Cookies: Essential for platform operation. These cookies maintain your login session, manage security tokens, and enable core gaming functionality. They cannot be disabled without preventing your ability to use wln7.
• Functional Cookies: Store your preferences such as language settings, responsible gaming limit configurations, and notification preferences to personalise your experience across sessions.
• Analytical Cookies: Collect anonymised data about how players navigate wln7.com — pages visited, session durations, and feature interactions. This data is used in aggregate form only to identify areas for platform improvement. No individual player profiles are built from analytical cookie data.
• Security Cookies: Support our fraud detection and bot-prevention systems by recording technical signals such as mouse movement patterns and interaction timing to distinguish genuine player behaviour from automated activity.

7.2 wln7 does not deploy third-party advertising cookies or behavioural profiling cookies that track your activity across other websites outside the wln7.com domain.

7.3 You may manage cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies will affect your ability to log in and use the wln7 platform. Detailed cookie management instructions for common browsers are available from your browser provider's help documentation.

8.Data Retention Periods

8.1 wln7 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and our licensing obligations. The following standard retention periods apply:

• Account and Identity Data: Retained for the duration of your active Account plus a minimum of five (5) years following Account closure, as required by our AML and gaming license obligations.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification, in compliance with anti-money laundering record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction for AML and tax-related regulatory compliance.
• Customer Support Communications: Retained for three (3) years from the date of the last communication in a support thread, to support dispute resolution and quality assurance processes.
• Analytical and Usage Data: Retained in anonymised and aggregated form indefinitely for platform analytics. Individual session records are retained for up to twelve (12) months before anonymisation.
• Marketing Consent Records: Retained for the duration of active consent plus three (3) years following consent withdrawal, to demonstrate compliance with consent requirements if challenged.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where data is anonymised rather than deleted, the resulting anonymised dataset can no longer be linked back to any individual Player and therefore falls outside the scope of data protection law.

9.Your Data Rights

9.1 As a Player whose personal data is processed by wln7, you hold the following rights. These rights may be exercised by contacting the wln7 Data Protection team as described in Section 14:

Exercising Your Rights

9.2 To exercise any of the rights described above, please submit a written request to the wln7 Data Protection team via live chat support within your Account dashboard or by email at [email protected] with the subject line "Data Rights Request – [Your Username]".

9.3 wln7 will acknowledge receipt of a data rights request within 48 hours and will provide a substantive response within 30 calendar days. Where a request is complex or where a large volume of requests has been received simultaneously, this period may be extended by up to a further 60 days, in which case wln7 will notify you of the extension and the reason for it within the initial 30-day period.

9.4 wln7 will not charge a fee for processing data rights requests unless the request is manifestly unfounded, repetitive, or excessive — in which case a reasonable administrative fee may be applied, or the request may be declined. In either case, wln7 will inform you of the basis for its decision.

9.5 For the protection of your data, wln7 may request additional identity verification before fulfilling a data rights request to ensure that personal data is not disclosed to an unauthorised party claiming to act on your behalf.

10.Children and Minors

10.1 wln7 is strictly prohibited for use by individuals under the age of 21. wln7 does not knowingly collect personal data from anyone under 21 years of age. Account registration requires confirmation of date of birth and is subject to mandatory KYC verification to enforce this age restriction.

10.2 If wln7 becomes aware, through KYC verification, support disclosures, or any other means, that personal data has been collected from an individual under 21, the Account will be immediately suspended, all associated data will be deleted or anonymised to the extent permitted by law, and any funds in the Account will be returned following investigation.

10.3 If you are a parent or guardian and believe your child has registered a wln7 Account, please contact our support team immediately via live chat or at [email protected] so that the situation can be investigated and resolved without delay. wln7 takes underage gambling extremely seriously and will take all available steps to prevent it.

11.Data Security Measures

11.1 wln7 implements the following technical and organisational security measures to protect player data against unauthorised access, accidental loss, destruction, or disclosure:

• Encryption: All data in transit is encrypted using TLS 1.3. Sensitive data at rest — including identity documents and financial records — is encrypted using AES-256 encryption standards.
• Access Controls: Access to personal data within wln7's internal systems is restricted on a strict need-to-know basis. All staff with data access privileges are subject to confidentiality obligations and background screening.
• Two-Factor Authentication: Available for all Player accounts and mandatory for all wln7 staff accounts with access to player data.
• Regular Security Testing: wln7 conducts periodic penetration testing and vulnerability assessments of its platform infrastructure to identify and remediate security weaknesses proactively.
• Incident Response: wln7 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to Player rights, wln7 will notify affected Players and the relevant regulatory authority within the timeframes required by applicable law.

11.2 Whilst wln7 takes all reasonable precautions to protect personal data, no online platform can guarantee absolute security against all possible threats. You are responsible for maintaining the confidentiality of your Account credentials and for ensuring your own device and network security. If you suspect unauthorised access to your Account, please contact wln7 support immediately.

12.International Data Transfers

12.1 wln7 operates on infrastructure that may involve transferring personal data to servers located outside Pakistan. Where personal data is transferred internationally, wln7 ensures that appropriate safeguards are in place to maintain a level of data protection equivalent to that applied within Pakistan, including:

• Contractual obligations in the form of standard data protection clauses incorporated into agreements with all international data processors.
• Transfer only to jurisdictions assessed as providing adequate levels of data protection for the purposes of wln7's licensing obligations.
• Technical measures — including encryption and pseudonymisation — applied to data prior to international transfer where additional protection is warranted.

12.2 Players may request information about the specific safeguards applied to international transfers of their personal data by contacting the wln7 Data Protection team as described in Section 14.

13.Changes to This Privacy Policy

13.1 wln7 reviews this Privacy Policy periodically and will update it to reflect changes in our data processing practices, changes in applicable law, or changes required by our licensing authority. The version number and effective date displayed at the top of this document identify the currently applicable version.

13.2 Material changes to this Privacy Policy — meaning changes that affect the rights of Players or introduce new categories of data processing — will be communicated to registered Players via email to the address on file no less than fourteen (14) days before the changes take effect. Non-material clarifications may be updated without individual notice, though the effective date at the top of the policy will always reflect the date of the most recent revision.

13.3 Continued use of the wln7 platform after the effective date of any revision to this Privacy Policy constitutes acceptance of the updated terms. If you do not accept any material change, you may request Account closure in accordance with Section 8.4 of the Terms & Conditions before the revised policy takes effect.

14.Contact the Data Protection Team

14.1 For all data protection enquiries, rights requests, complaints, or questions about this Privacy Policy, please contact the wln7 Data Protection team through the following channels:

• Live Chat: Available 24/7 inside your wln7 Account dashboard. For time-sensitive data security concerns such as suspected unauthorised access, live chat is the fastest channel available.
• Email: [email protected] — use the subject line "Privacy / Data Protection – [Your Username]" for all formal data rights requests and privacy-related correspondence.

14.2 wln7 is committed to resolving privacy-related concerns promptly and fairly. If you are not satisfied with wln7's response to a data protection complaint, you may have the right to escalate the matter to the data protection supervisory authority relevant to wln7's licensing jurisdiction. Details of the applicable supervisory authority are available upon request from the Data Protection team.