jtwin Privacy Policy — How We Handle Your Data

1. INFORMATION WE COLLECT

When you register and use the jtwin platform, we collect several categories of personal information. We only collect information that is necessary to provide you with a safe, functional, and personalised gaming experience. The categories of data we collect are as follows:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, or data concerning health or sexual orientation, except where such data is provided voluntarily by you in the context of a responsible gaming or self-exclusion request.

2. HOW WE USE YOUR INFORMATION

jtwin processes your personal data for the following specific purposes. We do not use your data in any manner that is incompatible with the purposes described below:

• Account Management: To register your account, verify your identity, maintain your player profile, and administer your account settings and preferences.
• Service Delivery: To process deposits and withdrawals via bKash, Nagad, Rocket, and other supported payment methods; to settle bets and winnings; to apply bonuses to your account.
• Legal Compliance: To comply with KYC, anti-money laundering, and responsible gaming obligations; to respond to regulatory requests; to maintain legally required transaction records.
• Fraud Prevention: To detect and prevent fraudulent activity, multi-accounting, bonus abuse, and money laundering. Usage and financial data are analysed to identify suspicious patterns.
• Customer Support: To respond to your support queries, manage complaints, and maintain records of communications for quality assurance and dispute resolution purposes.
• Marketing: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive marketing communications. You may withdraw this consent at any time via your account settings or by contacting support.

3. LEGAL BASIS FOR PROCESSING

jtwin processes your personal data on the following legal bases:

• Contractual necessity — processing required to perform the contract between you and jtwin (i.e., to operate your player account and provide the gaming services you requested).
• Legal obligation — processing required to comply with applicable laws and regulations, including KYC, anti-money laundering, responsible gaming requirements, and responses to lawful authority requests.
• Legitimate interests — processing carried out to protect the platform and its players from fraud, to improve the platform's performance, and to manage responsible gaming risks, where such interests are not overridden by your fundamental rights.
• Consent — where we send you marketing communications or use non-essential cookies, we do so only on the basis of your freely given, specific, and informed consent, which you may withdraw at any time.

4. DATA SHARING & DISCLOSURE

jtwin does not sell your personal data to third parties. We may share your data with the following categories of recipient, strictly on a need-to-know basis and under appropriate data processing agreements:

• Payment Processors: bKash, Nagad, Rocket, Upay, and our banking partners receive the minimum financial data necessary to process your transactions. These partners are contractually bound to process your data only for payment settlement purposes.
• Game Providers: Technology providers such as Pragmatic Play, Evolution Gaming, and Spribe receive a pseudonymous player identifier and session data necessary to operate the games you play. They do not receive your full name, payment details, or contact information.
• Regulatory Authorities: We may disclose personal data to competent regulatory, law enforcement, or government bodies where required by applicable law, court order, or binding regulatory direction.
• Fraud Prevention Services: We may share transactional and behavioural data with specialist fraud detection partners for the purpose of identifying and preventing financial crime. Any such sharing is governed by strict confidentiality obligations.

5. COOKIES & TRACKING TECHNOLOGIES

The jtwin platform uses cookies and similar tracking technologies to operate certain platform functions, measure performance, and improve your experience. We use three categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in, security tokens, and load-balancing cookies. These cannot be disabled without breaking core functionality.
• Performance Cookies: Help us understand how players use the platform by collecting aggregated, anonymised data on page visits, game load times, and error frequency. Used solely to improve platform reliability and speed.
• Preference Cookies: Remember your settings such as language preference, display preferences, and notification choices so you do not need to re-enter them on each visit.

You can manage your cookie preferences through your device's browser settings. Please note that disabling certain cookies may impair some platform features. jtwin does not use advertising or tracking cookies that follow you across third-party websites.

6. DATA RETENTION

jtwin retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following general retention periods apply: account data and transaction records are retained for a minimum of five years from the date of account closure to comply with anti-money laundering record-keeping requirements; KYC documentation is retained for a minimum of five years following the completion of the verification process; communication records (support tickets, chat logs, email correspondence) are retained for two years from the date of the last interaction.

When your data is no longer required, jtwin will either securely delete it or anonymise it so that it can no longer be attributed to you. If you submit a data deletion request, we will process it within 30 days, subject to any legal retention requirements that prevent immediate deletion.

7. DATA SECURITY

jtwin implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include industry-standard SSL/TLS encryption for all data transmitted between your device and the platform; secure server infrastructure with access controls and activity logging; role-based access restrictions ensuring that only authorised jtwin personnel can access player data, and only to the extent required by their role; and regular security reviews of platform infrastructure and third-party integrations.

Despite these measures, no online platform can guarantee absolute security. In the event of a data security incident that is likely to result in a risk to your rights and freedoms, jtwin will notify you without undue delay using the contact details registered to your account. You should also maintain the security of your own login credentials and device to protect your account from unauthorised access.

8. YOUR DATA RIGHTS

As a registered jtwin player, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact our support team using the email address in the footer of this page.

To exercise any of the rights listed above, please contact our support team using the email address shown in the footer of this page. We will verify your identity before processing your request and will respond within 30 days. There is no charge for exercising your rights, though we reserve the right to charge a reasonable fee for manifestly unfounded or excessive requests.

9. CHILDREN'S PRIVACY

The jtwin platform is strictly for adults aged 21 and above. We do not knowingly collect, process, or store personal data relating to any person under the age of 21. Our registration process includes age verification steps, and we conduct periodic reviews of registered accounts to identify any that may have been created by underage individuals.

10. THIRD-PARTY LINKS

The jtwin platform may contain references to third-party services such as payment providers. These third-party services have their own independent privacy policies, and jtwin is not responsible for their privacy practices or the content of their policies. We encourage you to review the privacy policy of any third-party service before providing them with your personal data. jtwin's Privacy Policy applies solely to data collected by the jtwin platform itself.

11. CHANGES TO THIS PRIVACY POLICY

jtwin may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or platform functionality. When we make material changes, we will update the "Last Updated" date at the top of this page and, where the changes are significant, we will notify you by email to your registered address or by displaying a prominent notice on the platform.

Your continued use of the jtwin platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the revised policy, you must cease using the platform and may request account closure by contacting our support team.

12. CONTACT & DATA QUERIES

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data jtwin holds about you, please contact our support team using the email address displayed in the footer of this page. All data rights requests must be submitted in writing to that address. We aim to acknowledge all privacy-related communications within two business days and to resolve them within 30 calendar days of receipt.