Privacy Policy

Scope

This Privacy Policy explains how WishWin and its related subsidiaries ("WishWin," "we," "us," "our") handle personal data. It applies to registered account holders ("Players") and to visitors browsing the Website.

Who We Are

The operator of the Website acts as the Data Controller of your personal data, deciding how and why it is processed as described in this Policy. Together with any joint controller, we are responsible for the security and proper handling of the data you provide.

What Personal Data We Collect

Data you provide directly

• Registration data: to open an account, you provide your email address, date of birth, country, phone number, gender, full name, national identification number, postal code, and username. Your IP address and general location are captured automatically at registration.
• Due diligence data: to meet Know Your Customer (KYC) and anti-money-laundering obligations, and to comply with licensing requirements, we collect identity document numbers (passport, driving licence, or ID card), proof of address, national identification numbers, source-of-funds information, and banking details.
• Financial information: banking identifiers, payment card details, and payment system information are collected to process deposits and withdrawals, and to support KYC and AML compliance.

Data collected automatically

• Device information: IP address, operating system, and device identifiers connected to your access of our services.
• Usage information: records of how you interact with the Website, including content viewed, pages visited, links followed, session timing, and similar activity, gathered partly through cookies and comparable technologies.
• Location information: general or inferred location data based on your use of our services.

Data received from other sources

• Publicly available sources, including government databases, public records, and social media.
• Commercial databases and third parties such as financial institutions and fraud prevention agencies, used to verify your information and investigate suspicious activity.
• Inferences drawn from the data described above, such as likely game preferences based on browsing activity.
• Information you have made public yourself, including through linked social accounts or public profiles.

Why We Collect Your Data

Personal data is used to:

• provide and operate our services;
• respond to questions or requests;
• test, analyse, and improve our products;
• detect and prevent fraud, illegal activity, and harmful behaviour;
• send marketing communications and personalise offers;
• resolve disputes, including those involving regulators or law enforcement;
• meet regulatory and legal obligations;
• maintain the security and technical functioning of the Website.

Lawful Basis for Processing

Contract: processing necessary to open, maintain, and support your account, and to meet obligations under these Terms.

Legal obligation: processing required to meet legal duties, including:

• verifying age and identity for KYC/AML purposes;
• determining applicable legal requirements based on your location;
• managing risk and supporting responsible gambling measures;
• maintaining network and information security;
• complying with legal processes such as court orders;
• preventing money laundering, fraud, and terrorist financing;
• meeting regulatory reporting obligations;
• responding to requests to exercise your data protection rights.

Legitimate interest: processing that supports a legitimate business or third-party interest, provided it does not override your own rights, including:

• pursuing or defending legal claims;
• IT security, fraud prevention, and asset protection;
• managing and improving our services;
• analytics, aggregated research, and service development;
• risk-based customer segmentation and identification of potentially harmful behaviour;
• using behavioural analysis to recommend relevant games and features;
• detecting activity that compromises service integrity, such as fraud or unauthorised tools.

Consent: where you have given consent, we may:

• send direct marketing via email, SMS, phone, or app notification;
• personalise offers based on your gaming history;
• use browsing data to display targeted advertising;
• assess and refine marketing effectiveness;
• administer your participation in competitions, tournaments, and loyalty programmes.

How We Share Your Personal Data

Personal data may be shared with:

• authorised staff, affiliated brands, contractors, and companies within our corporate group;
• payment providers and financial institutions, limited to details necessary to process transactions and meet their own compliance obligations, including relevant KYC documentation;
• third-party service providers supporting customer support, communications, hosting, or technology infrastructure;
• marketing partners;
• fraud prevention agencies;
• parties involved in a corporate transaction such as a merger, acquisition, or sale of assets;
• game providers;
• analytics and data aggregation providers, for research and service improvement;
• law enforcement, regulatory, and licensing authorities.

Where you raise a complaint, review, or query with an external platform such as a dispute resolution body or review site, we may respond directly to that platform to clarify or resolve the matter, sharing only what is necessary to identify your account and address the issue raised. Such disclosures are made on the basis of our legitimate interest in resolving disputes accurately and are limited to what is proportionate to that purpose.

How Long We Keep Your Data

Data is retained for as long as your account remains active and for as long as needed to fulfil the purposes described in this Policy. Where legal obligations require it, such as anti-money-laundering rules, data may be retained for longer. Once there is no ongoing legal or business need, your data will be deleted or anonymised.

Your Rights

Depending on applicable law, you have the right to:

• access the personal data held about you and understand how it is processed;
• correct inaccurate or incomplete data;
• request deletion where there is no compelling reason for continued processing;
• restrict processing in certain circumstances;
• receive your data in a structured, portable format;
• object to processing based on legitimate interest or direct marketing;
• withdraw consent at any time, without affecting past processing carried out under that consent;
• lodge a complaint with a supervisory authority in your place of residence, workplace, or where an alleged breach occurred.

Requests to exercise these rights can be made through our customer support channels or our Data Protection Officer.

Cookies and Tracking Technologies

We use cookies, pixels, tags, and similar technologies to support and improve your experience on the Website. Consent is requested before non-essential cookies are set; strictly necessary cookies do not require consent. Full detail is available in the Cookie Policy.

Data Security

We apply administrative, technical, and physical safeguards to protect personal data against unauthorised access, loss, or misuse. While we continually assess and strengthen our security practices, no system connected to the internet can guarantee absolute protection, and we cannot promise complete security of data in transit or storage.

Change in Ownership or Control

Should the Company undergo a sale, merger, or other change of ownership, personal data may be disclosed as part of that process. Any new owner will continue to handle your data under the terms of this Policy unless you separately consent to different treatment.

Transfer of Data Outside the EU/EEA

Personal data may be processed in countries outside the EU/EEA. Where this occurs, appropriate safeguards are applied, such as transferring data only to jurisdictions recognised as offering adequate protection, using approved standard contractual clauses, or applying other legally recognised protective measures.