1. Introduction
This Privacy Policy ("Policy") describes how AliWin ("AliWin", "we", "us", "our") collects, processes, stores and protects the personal data of individuals ("User", "you", "your") who access or use the AliWin online gaming platform accessible at aliwin.cam (the "Platform" or "Site").
AliWin is an English-language online gaming platform providing sports betting, cricket markets, live dealer casino, slots and instant games, primarily serving users in Pakistan. All transactions are denominated in Pakistani Rupees (PKR).
We take your privacy seriously. This Policy is intended to be transparent, readable and accurate. It explains not just what data we collect but why we collect it, how long we hold it, and what choices you have. We encourage you to read it in full before registering an account.
Pakistan notice: AliWin does not hold a data protection licence or gambling licence issued by any Pakistani authority, including the Government of Pakistan, PTA, the State Bank of Pakistan or any provincial body. This Policy reflects our operational data practices. It does not constitute legal advice under Pakistani law. Users are responsible for understanding their local obligations.
2. Definitions
3. Data We Collect
AliWin collects personal data in several categories, depending on your interaction with the Platform. The table below summarises the main data types collected and their sources:
| Category | Examples | Source |
|---|---|---|
| Registration Data | Name, email address, date of birth, country of residence, username, password (hashed) | Provided by you at account creation |
| Identity / KYC Data | CNIC or passport copy, selfie or liveness image, proof of address (where required) | Provided by you during KYC verification |
| Financial Data | Deposit and withdrawal records, transaction amounts in PKR, payment method identifiers (masked) | Generated via cashier activity; received from payment processors |
| Gaming Activity Data | Bets placed, game history, wins/losses, session durations, bonus claims and usage | Generated automatically through platform use |
| Technical Data | IP address, device type and OS, browser, session timestamps, geolocation (country/city level) | Collected automatically via platform access |
| Communications Data | Support messages, email correspondence, feedback submitted to AliWin | Provided by you through support or contact channels |
| Cookie / Analytics Data | Page views, click paths, session behaviour, A/B test participation | Collected automatically via cookies and analytics tools |
Certain data fields — such as preferred language or optional profile information — are provided voluntarily. Where a data field is optional, it will be clearly indicated at the point of collection. Declining to provide optional data will not prevent you from accessing core Platform functionality.
You are responsible for ensuring that all personal data you provide to AliWin is accurate and up to date. Providing false, misleading or someone else's data (including CNIC details) is a breach of our Terms & Conditions and may constitute a criminal offence.
4. Legal Basis for Processing
AliWin processes personal data only where a recognised legal basis exists for doing so. The primary legal bases relied upon are as follows:
- Contractual necessity: Processing required to fulfil our obligations to you under the account agreement — including account management, transaction processing, game delivery and withdrawal handling.
- Legal obligation: Processing required to comply with applicable laws and regulations — including anti-money-laundering (AML) obligations, KYC requirements, fraud prevention, and any mandatory reporting to competent authorities.
- Legitimate interests: Processing necessary for AliWin's legitimate business purposes where those interests are not overridden by your rights — including fraud detection, platform security, analytics, responsible gambling monitoring and abuse prevention.
- Consent: Where we rely on consent as a legal basis (for example, for optional marketing communications), we will obtain your clear, freely given consent at the point of collection. You may withdraw consent at any time without affecting the lawfulness of prior processing.
5. How We Use Your Data
We use your registration and identity data to create and manage your Account, authenticate your logins, deliver the games and markets you access, and respond to support requests. Without this processing, we cannot provide the Platform's core services.
KYC data — including your CNIC or passport copy, selfie and any proof of address — is used solely to verify your identity and age, prevent fraud and meet our AML compliance obligations. This data is processed through AliWin's secure HTTPS verification portal and, where a third-party identity verification provider is used, under contractual data-processing obligations.
Transaction data is used to process deposits and withdrawals, reconcile account balances in PKR, detect and investigate suspicious financial activity, and meet financial crime prevention obligations. Payment method details are passed to payment processors only to the extent necessary to execute the relevant transaction.
Gaming activity data and session behaviour are analysed to monitor for indicators of problem gambling — including unusually high loss rates, extended session lengths or escalating deposit patterns. Where such indicators are detected, AliWin may contact the User to prompt use of responsible gambling tools or to apply protective account measures.
Technical data (including IP addresses, device fingerprints and session logs) is used to detect and prevent fraud, multi-accounting, automated abuse, collusion and other prohibited conduct. AliWin may share this data with fraud-prevention services under appropriate data-sharing agreements.
Aggregated, anonymised analytics data is used to understand how users interact with the Platform, identify usability issues and improve features and content. Individual users are not identified through analytics processing unless a specific investigation requires it.
Where you have provided consent, AliWin may use your email address or other contact details to send information about promotions, new games, platform updates or other communications you have opted in to receive. You may withdraw consent at any time by following the unsubscribe instructions included in each communication or by contacting our support team.
AliWin does not sell personal data to third parties. We do not transfer personal data for third-party advertising or profiling beyond what is described in this Policy.
6. Sharing & Disclosure of Personal Data
AliWin shares personal data only where necessary and only with parties that are subject to appropriate data-handling obligations. The categories of recipient are as follows:
- Payment processors: Transaction data necessary to execute deposits and withdrawals is shared with the relevant payment processor. This may include processor names familiar to Pakistani users such as Easypaisa, JazzCash, Raast-connected banks, HBL, UBL, Meezan Bank or Bank Alfalah — where they are the selected payment method — but only to the extent required to process the specific transaction. These brands do not endorse or partner with AliWin.
- Identity verification providers: KYC document data may be shared with a third-party identity verification service operating under a data-processing agreement with AliWin. These providers use the data solely for the purpose of identity and age verification.
- Fraud and AML services: Technical and transaction data may be shared with fraud-prevention or AML screening services for the purpose of detecting and preventing financial crime.
- Regulatory and law-enforcement authorities: AliWin may disclose personal data to competent regulatory or law-enforcement authorities where required by applicable law, court order or lawful request. AliWin will endeavour to notify affected Users where legally permissible to do so.
- Technology and infrastructure providers: Hosting, cloud storage, platform software and support tool providers may have access to personal data in the course of providing contracted services. All such providers operate under data-processing agreements requiring appropriate security standards.
- Business transfers: In the event of a merger, acquisition or sale of all or part of AliWin's business, personal data may be transferred to the acquiring entity as part of that transaction. Users will be notified of any material change to the Data Controller's identity.
In all cases, data shared with third parties is limited to the minimum necessary for the specific purpose and is governed by appropriate contractual protections.
7. Cookies & Tracking Technologies
AliWin uses cookies and similar tracking technologies to operate the Platform, maintain your session, remember your preferences and collect analytics data. The main categories of cookie used are:
- Strictly necessary cookies: Essential to the Platform's operation — including session management, authentication and security. These cannot be disabled without affecting core Platform functionality.
- Functional cookies: Used to remember your preferences and settings, such as language preference or interface configuration.
- Analytics cookies: Used to collect anonymised data about how users navigate the Site — pages visited, time spent and click paths. This data is used to improve the Platform.
- Performance cookies: Used to monitor Platform performance, identify errors and ensure stable delivery of games and markets.
You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. AliWin does not use cookies to serve third-party advertising.
8. Data Retention
Personal data is retained only for as long as it is necessary for the purpose for which it was collected, or as required by applicable legal, regulatory or compliance obligations.
| Data Category | Standard Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years post-closure | Legal / AML obligation |
| KYC / identity documents | Duration of account + 5 years post-closure | AML / regulatory compliance |
| Transaction records | Duration of account + 7 years post-closure | Financial records obligation |
| Gaming activity logs | Duration of account + 3 years post-closure | Responsible gambling / dispute resolution |
| Technical / session logs | Up to 12 months | Security and fraud prevention |
| Support communications | 3 years from last communication | Contractual / legitimate interest |
| Analytics data (anonymised) | Up to 26 months (aggregated) | Legitimate interest (platform improvement) |
Where you request deletion of your personal data, AliWin will action that request subject to any overriding legal retention obligations. Data that we are legally required to retain cannot be deleted before the applicable retention period expires, even following an account closure request.
9. Security Measures
AliWin applies a range of technical and organisational security measures to protect personal data against unauthorised access, loss, alteration or disclosure:
- HTTPS / SSL encryption on all pages and data transmissions between your browser and the Platform;
- Password hashing — passwords are never stored in plain text;
- Access controls — internal access to personal data is restricted to authorised personnel on a need-to-know basis;
- Secure document handling — KYC documents are processed through an encrypted verification portal and are not transmitted via email or unsecured channels;
- Fraud monitoring — automated systems monitor for unusual account behaviour that may indicate unauthorised access or identity theft;
- Regular security reviews — our systems and processes are reviewed periodically to assess and address security vulnerabilities.
While AliWin takes data security seriously and applies industry-standard protections, no internet-based system can be guaranteed to be completely secure. In the event of a data breach that poses a material risk to affected Users, AliWin will notify impacted individuals and relevant authorities in accordance with applicable obligations.
Your security responsibility: You are responsible for keeping your login credentials confidential. AliWin will never ask for your password via email, live chat or any unsolicited message. If you receive such a request, do not respond and contact support immediately at [email protected].
10. Your Data Rights
Depending on the data protection laws applicable in your jurisdiction, you may hold the following rights in relation to personal data AliWin holds about you:
You may request a copy of the personal data AliWin holds about you, together with information about how it is used and stored. Requests will be addressed within a reasonable period.
You may request that inaccurate or incomplete personal data be corrected. Some corrections may require re-verification of identity documents.
You may request deletion of personal data where it is no longer necessary for the purpose it was collected. This right is subject to overriding legal retention obligations — AML, financial records and regulatory data may not be deleted before mandatory retention periods expire.
You may request that processing of your data be restricted where you contest its accuracy, object to its use, or where processing is unlawful but you do not wish it to be deleted.
Where processing is based on your consent or contractual necessity and is carried out by automated means, you may request a copy of your personal data in a structured, machine-readable format.
You may object to processing based on legitimate interests. AliWin will assess the objection and cease processing unless compelling legitimate grounds exist that override your rights.
Where processing is based on your consent (e.g., marketing emails), you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
To exercise any of the above rights, please contact our support team at [email protected]. We will verify your identity before acting on any data rights request. Requests will be responded to within 30 days where technically feasible, or we will advise of any extension required.
11. Children's Privacy
AliWin is strictly an adults-only platform. We do not knowingly collect personal data from persons under the age of 18 — or the higher minimum age required by the applicable licence jurisdiction.
If you are under the applicable minimum age, you must not register an account, submit any personal data to AliWin or use any part of the Platform. Age verification is a mandatory part of the KYC process for all registered accounts.
If AliWin becomes aware that personal data has been collected from a person who is below the applicable minimum age, that account will be immediately suspended, all associated data will be deleted as far as legally permissible, and any deposits will be returned through the original payment method.
Parents or guardians who believe their child may have registered an account on AliWin should contact our support team immediately at [email protected].
12. International Data Transfers
AliWin may transfer personal data to third-party processors or infrastructure providers located outside Pakistan. Such transfers are made only where appropriate safeguards are in place — including contractual data-processing agreements that require the recipient to apply data protection standards consistent with this Policy.
By creating an account and using the Platform, you acknowledge that your personal data may be processed in jurisdictions other than Pakistan. AliWin will take reasonable steps to ensure that overseas recipients protect your data in a manner consistent with this Policy and applicable data protection principles.
13. Third-Party Links & Services
13.1 The Platform may reference third-party services — including payment providers (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) — as familiar contextual payment references for Pakistani users. These references do not constitute links to, or integrations with, third-party websites for browsing purposes.
13.2 Where your chosen payment method routes a transaction through a third-party payment processor, that processor's own privacy policy will govern how the processor handles any data you provide directly to them. AliWin is not responsible for the privacy practices of third-party payment processors beyond the contractual obligations we impose on them as Data Processors.
13.3 AliWin does not include third-party advertising networks or social media tracking pixels that would share browsing data with external advertising platforms without your knowledge.
14. Amendments to This Policy
14.1 AliWin reserves the right to amend this Privacy Policy at any time. The revised Policy will be published on the Platform with an updated "Last Updated" date.
14.2 Where an amendment is material — meaning it significantly affects your rights or the way we process your data — AliWin will notify registered Users via their registered email address or through a prominent notice on the Platform prior to the change taking effect.
14.3 Your continued use of the Platform following the publication of an amended Policy constitutes acceptance of the updated terms. If you do not accept a material amendment, you should close your account prior to the effective date.
14.4 We recommend reviewing this Policy periodically, particularly before submitting any new category of personal data.
15. Contact & Complaints
If you have any questions about this Privacy Policy, wish to exercise a data rights request, or have a complaint about how AliWin has handled your personal data, please contact us:
Data Enquiries: [email protected]
Response time: We aim to acknowledge all data rights requests within 5 business days and respond substantively within 30 days.
Security reminder: Never send KYC documents, passwords or payment details by email. Use only the secure in-platform verification portal for document submission.
AliWin takes all data complaints seriously. If you are not satisfied with our response, you may be entitled to raise a complaint with the data protection supervisory authority in the jurisdiction applicable to your situation. As AliWin is not regulated by a Pakistani authority, complaints relating to Pakistani data protection law should be assessed in the context of applicable local regulations.
For further information about your account rights, please review our Terms & Conditions. For responsible gambling support, visit the Responsible Gambling page.