jjqin Privacy Policy — How We Handle Your Data

1 Introduction

jjqin operates an online casino and sports betting platform accessible at jjqin.net, designed primarily for English-speaking Pakistani players. In the course of operating this platform, jjqin necessarily collects and processes certain personal data relating to registered players and visitors to the website.

jjqin takes the privacy and security of that personal data seriously. This Privacy Policy is intended to give every player complete transparency about what personal data jjqin holds, the purposes for which it is processed, the safeguards in place to protect it, and the rights available to each player in respect of their own data.

This Privacy Policy should be read alongside jjqin's Terms and Conditions, which govern the contractual relationship between jjqin and each registered player, and the Responsible Gaming policy, which addresses how jjqin handles sensitive data related to gambling behaviour and player protection.

2 Data Controller

For the purposes of applicable data protection law, jjqin acts as the data controller in respect of personal data collected directly from players through the jjqin platform. As data controller, jjqin determines the purposes for which personal data is processed and the manner in which such processing takes place.

Where jjqin engages third-party service providers — such as payment processors, game studios, or identity verification services — who process personal data on jjqin's behalf, those parties act as data processors under contract with jjqin. jjqin remains responsible for ensuring that such processors handle your personal data in accordance with this Privacy Policy and applicable data protection standards.

All data protection enquiries and subject access requests should be directed to jjqin's support team using the contact details provided in Section 15 of this Policy.

3 Personal Data We Collect

jjqin collects personal data from players through several channels. The categories of data collected, and the circumstances in which each category is collected, are set out below.

3.1 Registration Data

When a player creates a jjqin account, jjqin collects the information provided during the registration process, which typically includes:

• Full legal name as it appears on your CNIC or other government-issued identification
• Date of birth (used to confirm the player meets jjqin's 21+ age requirement)
• Pakistani mobile phone number used for account authentication and OTP delivery
• Email address, where provided
• Residential city or region (e.g. Karachi, Lahore, Islamabad, Faisalabad)
• Chosen username and securely hashed account password

3.2 Identity Verification (KYC) Data

To comply with jjqin's operating licence conditions and anti-money-laundering obligations, jjqin may request the following documentation when a player's account reaches certain thresholds or when jjqin has grounds to conduct enhanced due diligence:

• Copy of Pakistani CNIC (front and back) or other government-issued photo identification
• Selfie photograph for biometric comparison with identity document
• Proof of address (utility bill, bank statement, or equivalent document)
• Proof of payment method ownership (e.g. screenshot of JazzCash or EasyPaisa registered account)

3.3 Transaction and Financial Data

jjqin processes transactional data necessary to record, reconcile, and report on deposits, wagers, wins, losses, and withdrawals conducted through the platform. This includes payment method type and reference identifiers (but not full card or bank account numbers), transaction timestamps, PKR amounts, and balance history.

3.4 Technical and Device Data

jjqin's platform automatically collects certain technical data when a player's device connects to the platform, including IP address, device type and operating system, browser type and version, session timestamps, and in-app navigation behaviour. This data is used for fraud detection, platform security, and performance optimisation.

3.5 Gaming and Betting Activity Data

jjqin records a complete history of each player's gaming and betting activity on the platform, including games played, markets wagered on, stake amounts, outcomes, and bonus usage. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory reporting purposes.

4 How jjqin Uses Your Personal Data

jjqin uses the personal data collected from players for the following specific purposes:

• Account management: Creating, maintaining, and administering your jjqin account, including authentication, password resets, and account preferences.
• Payment processing: Processing PKR deposits and withdrawals through JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20, and reconciling transaction records.
• Identity verification: Confirming that registered players meet jjqin's 21+ age requirement and conducting KYC checks as required by jjqin's operating licence conditions.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, and money laundering through behavioural and technical analysis of account data.
• Responsible gaming: Monitoring gaming patterns that may indicate problem gambling behaviour, delivering responsible gaming alerts, and administering player-requested tools such as deposit limits, cooling-off periods, and self-exclusion.
• Customer support: Responding to player enquiries, handling complaints, and resolving disputes relating to games, payments, or account settings.
• Legal and regulatory compliance: Meeting jjqin's obligations under its operating licence, anti-money-laundering regulations, and any applicable data protection laws, including responding to lawful requests from regulatory or law enforcement authorities.
• Platform improvement: Analysing aggregated, anonymised data to improve the performance, design, and functionality of the jjqin platform for all Pakistani players.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have not opted out of marketing communications, subject to the preferences described in Section 13.

5 Legal Basis for Processing

jjqin processes personal data on one or more of the following legal bases, depending on the nature of the processing activity:

• Contractual necessity: Processing that is necessary to fulfil jjqin's contractual obligations to a registered player, including account administration, payment processing, and game provision.
• Legal obligation: Processing required to comply with jjqin's legal and regulatory obligations, including KYC verification, anti-money-laundering reporting, and responses to lawful regulatory authority requests.
• Legitimate interests: Processing that serves jjqin's legitimate business interests — such as fraud prevention, platform security, and responsible gaming monitoring — where those interests are not overridden by the rights and interests of players.
• Consent: Where jjqin relies on consent as the basis for processing — most notably for marketing communications — players may withdraw that consent at any time by following the opt-out instructions described in Section 13.

6 Data Sharing and Third Parties

6.1 Payment Processors

jjqin shares necessary transaction data with payment service providers — including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 processors — to the extent required to process deposits and withdrawals. These providers operate under their own privacy policies and applicable Pakistani financial regulation.

6.2 Identity Verification Services

jjqin may engage third-party KYC and identity verification service providers to assist with the verification of CNIC documents and player identity. Such providers process personal data under contractual data processing agreements with jjqin and are not permitted to use that data for any purpose beyond the specific verification service.

6.3 Game Studios and Platform Providers

Game studios supplying content to jjqin — such as live casino and slot providers — may receive minimal technical data (such as anonymised session identifiers) necessary to deliver their games within the jjqin environment. Certified providers are contractually prohibited from using such data for purposes outside the game delivery service.

6.4 Regulatory and Law Enforcement Authorities

jjqin may disclose personal data to its licensing authority, financial intelligence units, or law enforcement agencies where required to do so by law, court order, or legitimate regulatory demand. jjqin will not make such disclosures beyond what is strictly required by the applicable legal instrument.

7 Cookies and Tracking Technologies

jjqin uses cookies and similar tracking technologies on its platform for the following purposes:

• Essential cookies: Required for the platform to function correctly, including session management, login state, and security token validation. These cookies cannot be disabled without impairing platform functionality.
• Functional cookies: Store player preferences such as language, game lobby display settings, and last-viewed sections to improve the platform experience on return visits.
• Analytics cookies: jjqin uses first-party analytics to measure aggregate platform usage patterns — such as most-visited game categories, session durations, and deposit funnel completion rates — to guide product improvements. This data is anonymised and not linked to individual player profiles.
• Security cookies: Used by jjqin's fraud prevention systems to detect anomalous access patterns and bot traffic, protecting both jjqin and individual players from fraudulent activity.

jjqin does not deploy third-party advertising or retargeting cookies on its platform. Players who wish to manage cookie preferences may do so through their browser settings. Note that disabling essential cookies will prevent normal platform access.

8 Data Security

jjqin implements a range of technical and organisational security measures to protect personal data from unauthorised access, disclosure, alteration, or destruction. These measures include, without limitation:

• TLS encryption on all data in transit between player devices and jjqin's servers
• AES-256 encryption for sensitive data at rest, including KYC document storage
• One-way cryptographic hashing for account passwords — jjqin staff cannot see player passwords in plaintext
• Mobile OTP secondary authentication for account login and withdrawal authorisation
• Role-based access controls ensuring that jjqin staff can only access player data relevant to their specific operational role
• Real-time anomaly detection for unusual login locations, device changes, or withdrawal patterns
• Regular third-party security assessments of jjqin's infrastructure and application layer

9 Data Retention

jjqin retains personal data for the minimum period necessary to fulfil the purposes described in this Privacy Policy, subject to the following considerations:

• Active accounts: Personal data is retained for the duration of a player's active relationship with jjqin, including any self-exclusion period where the player has requested temporary account suspension.
• Closed accounts: Following account closure, jjqin retains transaction records, KYC documentation, and gaming history for a period of five years, as required by jjqin's operating licence conditions and applicable anti-money-laundering regulations.
• Dispute-related data: Where a player has raised a formal dispute or complaint, relevant data will be retained until the dispute is fully resolved and any applicable appeal or regulatory review period has expired.
• Marketing data: Player contact details used for marketing communications will be retained only until the player opts out or requests deletion. Opt-out records themselves are retained to prevent inadvertent re-contact.

Upon expiry of the applicable retention period, jjqin will securely delete or irreversibly anonymise the personal data in question.

10 Your Data Rights

jjqin recognises and respects the data rights of all players. The following rights are available to every registered jjqin player in respect of their personal data:

To exercise any of the above rights, contact jjqin's support team at [email protected], providing your registered mobile number and a description of your request. jjqin will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days. In complex cases, this period may be extended by a further 60 days, in which case jjqin will notify you of the extension and the reasons for it.

11 Children's Privacy and the 21+ Requirement

jjqin's platform and Services are exclusively intended for adults aged 21 years and above. jjqin does not knowingly collect personal data from individuals under the age of 21. The registration process includes age confirmation steps, and KYC verification is used to confirm age compliance where required.

If jjqin becomes aware that personal data has been collected from an individual who is under 21 years of age — whether through a report, system alert, or KYC review — jjqin will immediately suspend the associated account, refrain from processing any further activity on that account, and take steps to delete the personal data in question to the extent permitted by applicable legal obligations.

12 International Data Transfers

jjqin operates under an international gaming licence and may use service providers — including cloud infrastructure, game studios, and KYC verification platforms — whose technical infrastructure is located outside Pakistan. Where personal data of Pakistani players is transferred to servers or processors in other jurisdictions, jjqin takes steps to ensure that appropriate safeguards are in place, including:

• Contractual data processing agreements incorporating internationally recognised data protection standards
• Due diligence reviews of third-party processor security and privacy practices prior to engagement
• Preference for data processors located in jurisdictions with adequate data protection frameworks

By using the jjqin platform and accepting this Privacy Policy, Pakistani players acknowledge that their personal data may be processed in jurisdictions outside Pakistan as part of the delivery of jjqin's Services.

13 Marketing Communications

With the player's consent, jjqin may send promotional communications via SMS to the registered Pakistani mobile number, covering matters such as: deposit bonus offers, PSL cricket betting promotions, new game launches, slot tournaments, and platform feature updates.

Players may withdraw consent for marketing communications at any time by:

• Replying STOP to any jjqin marketing SMS
• Adjusting communication preferences within their jjqin account settings
• Contacting jjqin support at [email protected] and requesting removal from all marketing lists

Marketing opt-outs are processed immediately. Players who opt out of marketing will continue to receive essential transactional communications relating to their account, such as deposit confirmations, withdrawal notifications, and security alerts, as these are necessary for account operation and cannot be disabled.

14 Changes to This Privacy Policy

jjqin reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, platform functionality, or data processing practices. When material changes are made — those that meaningfully affect how jjqin collects, uses, or shares personal data — jjqin will notify registered players by SMS or by displaying a prominent notice on the platform at the player's next login, with a minimum of 7 days' notice before the revised Policy takes effect.

For minor or non-material amendments, such as typographical corrections or clarifications that do not alter the substance of jjqin's data processing practices, the revised Privacy Policy will be published on this page with an updated version number and review date. Continued use of the jjqin platform after any amendment constitutes acceptance of the revised Privacy Policy.

jjqin recommends that all players periodically review this Privacy Policy to remain informed of how their personal data is being handled. The version number and effective date displayed in the version bar at the top of this document will always reflect the most current published version.

15 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jjqin, please contact the jjqin data protection team using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly within the jjqin platform
• Response Commitment: jjqin will acknowledge all data-related enquiries within 5 business days and provide a full response within 30 calendar days

When contacting jjqin about a data matter, please include your registered mobile number, the nature of your request, and any relevant account details to help jjqin locate and respond to your enquiry promptly. jjqin may need to verify your identity before fulfilling certain data rights requests to ensure the security of your personal data.