10wen Privacy Policy

1 Introduction

10wen ("10wen", "we", "us", "the Platform") is committed to protecting the privacy and personal data of all users of the 10wen platform. This Privacy Policy describes the personal data 10wen collects about you, the purposes for which it is collected, how it is used and stored, with whom it may be shared, how long it is retained, and the rights you have over your personal data.

This Privacy Policy is written in English and is intended to be read and understood by our Pakistani user base. Where technical or legal terminology is unavoidable, we have endeavoured to explain it clearly. This Policy should be read alongside the 10wen Terms & Conditions, which are incorporated herein by reference.

2 Data Controller

10wen operates as the data controller in respect of personal data collected through the 10wen platform. As data controller, 10wen determines the purposes for which and the manner in which your personal data is processed. Questions or requests relating to your personal data should be directed to 10wen using the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

10wen collects personal data from you in the following categories:

4 How 10wen Uses Your Personal Data

10wen uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your 10wen account, including authentication and login security.
• Payment Processing: To process deposits via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and Bank Alfalah, and to process withdrawal requests in PKR to your verified payment methods.
• Identity Verification (KYC): To verify your identity and age as required by applicable regulatory obligations and to prevent underage gambling.
• Gaming Services: To provide access to casino games, sports betting including PSL cricket odds, live dealer tables, Monster games, and all other 10wen platform features.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, and other prohibited conduct on the platform.
• Responsible Gaming: To monitor gaming behaviour patterns, enforce deposit limits and self-exclusion restrictions set by you, and identify players who may be at risk of gambling-related harm.
• Communications: To send you transactional communications including deposit confirmations, withdrawal notifications, and account security alerts.
• Legal Compliance: To comply with applicable legal and regulatory obligations, including responding to lawful requests from competent authorities.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the performance, features, and user experience of the 10wen platform.

5 Legal Basis for Processing

10wen processes your personal data on the following legal grounds:

• Contract Performance: Processing necessary to perform the contract between you and 10wen – providing gaming services, processing payments, and managing your account.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, age verification requirements, and responses to lawful authority requests.
• Legitimate Interests: Processing carried out in pursuit of 10wen's legitimate interests where not overridden by your rights – including fraud detection, platform security, and responsible gaming monitoring.
• Consent: Where required for specific processing activities not covered by the grounds above, 10wen will seek your consent and process data only to the extent permitted by that consent. You may withdraw consent at any time, subject to processing already carried out in reliance on that consent.

6 Data Sharing and Disclosure

10wen does not sell your personal data to third parties. 10wen may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment Processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and other payment service providers used to process your deposits and withdrawals. These providers process your data under their own privacy policies and in accordance with applicable financial regulations.
• Identity Verification Providers: Third-party KYC service providers engaged to assist with identity and age verification processes.
• Gaming Software Providers: Third-party game studios and software providers whose games are offered on the 10wen platform. These providers may receive anonymised session data for game performance and integrity purposes.
• Fraud Prevention Services: Third-party fraud detection and anti-money laundering screening services engaged to protect the platform and its users.
• Legal Authorities: Competent regulatory bodies, law enforcement agencies, or courts where 10wen is legally required to disclose data in response to a lawful request.
• Professional Advisers: Legal, accounting, and auditing professionals engaged by 10wen, who are bound by professional confidentiality obligations.

7 Cookies and Tracking Technologies

10wen uses cookies and similar tracking technologies on its platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that maintain your logged-in state and security cookies. These cannot be disabled.
• Functional Cookies: Used to remember your preferences such as language, currency display (PKR), and game lobby settings to improve your experience on return visits.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate the 10wen platform. This data is used to improve the platform's performance and user experience. No personally identifiable information is collected through analytics cookies.
• Fraud Prevention Cookies: Used to support fraud detection and security monitoring on the platform.

You can manage cookie preferences through your browser settings. Disabling functional or analytics cookies may affect your experience on the 10wen platform. Strictly necessary cookies cannot be disabled through browser settings without affecting platform functionality.

8 Data Security

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

• SSL/TLS encryption for all data transmitted between your device and 10wen's servers.
• Encryption of sensitive personal data and payment information at rest.
• Strict access controls limiting data access to authorised personnel with a legitimate operational need.
• Regular security assessments and monitoring of the platform's technical infrastructure.
• Two-factor authentication available for all user accounts to protect against unauthorised login.

While 10wen takes data security seriously, no digital system can guarantee absolute security. In the event of a data breach that presents a material risk to your rights and freedoms, 10wen will notify affected users in accordance with applicable legal requirements.

9 Data Retention

10wen retains your personal data for the following periods:

• Account Data: Retained for the duration of your account and for a minimum of five years following account closure, as required by applicable anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five years from the date of each transaction, in compliance with applicable financial record-keeping requirements.
• KYC Documentation: Retained for the period required under applicable AML regulations, typically five years from the end of the business relationship.
• Gaming Activity Logs: Retained for a minimum of three years to support dispute resolution, fraud investigations, and regulatory compliance.
• Support Communications: Retained for two years from the date of the communication to support quality assurance and dispute resolution.
• Technical Logs: Retained for up to 12 months for security monitoring purposes.

Where data is no longer required for any of the above purposes and retention is not mandated by law, 10wen will securely delete or irreversibly anonymise the relevant data.

10 Your Data Rights

Subject to applicable law and certain limitations, you have the following rights in respect of your personal data held by 10wen:

• Right of Access: You may request a copy of the personal data 10wen holds about you.
• Right to Rectification: You may request that inaccurate or incomplete personal data is corrected or completed.
• Right to Erasure: You may request deletion of your personal data in certain circumstances, subject to 10wen's legal obligations to retain data.
• Right to Restriction: You may request that processing of your data is restricted in certain circumstances while a query about its accuracy or legality is resolved.
• Right to Object: You may object to processing carried out on the basis of 10wen's legitimate interests.
• Right to Data Portability: Where processing is carried out by automated means on the basis of your consent or contract performance, you may request your data in a structured, machine-readable format.

11 Children and Minors

The 10wen platform is strictly for adults aged 18 and over. 10wen does not knowingly collect, process, or retain personal data relating to individuals under 18 years of age. If 10wen becomes aware that personal data has been collected from a person under 18, the relevant account will be closed immediately, any balance will be subject to review, and the personal data will be deleted. If you believe that a minor has registered an account on 10wen, please contact our support team immediately.

12 International Data Transfers

10wen's platform and associated infrastructure may involve the transfer of personal data to countries outside of Pakistan. Where such transfers occur, 10wen ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that described in this Policy, including through contractual protections with data recipients. By using 10wen, you acknowledge that your data may be transferred internationally for the purposes described in this Policy.

13 Changes to This Privacy Policy

10wen reserves the right to update this Privacy Policy at any time. When material changes are made, 10wen will notify registered users via their registered contact details and/or a prominent notice on the platform. The date of the most recent update is shown at the top of this Policy. Your continued use of the 10wen platform following notification of changes constitutes acceptance of the revised Policy. If you do not accept the revised Policy, you must close your account and cease using the platform.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or 10wen's handling of your personal data, please contact the 10wen data team: