crwin Privacy Policy

crwin collects personal data from players through multiple channels in the ordinary course of operating a safe and compliant online gaming platform. The categories of data we collect are set out below.

Registration Data: When you create a crwin account, we collect the information you provide directly, including your full name, date of birth, email address, mobile phone number, and residential address in Bangladesh (city, district, and postal area). This information is required to verify your identity, confirm your age eligibility, and maintain your account in accordance with our Terms & Conditions.

Payment Data: When you make a deposit or request a withdrawal, we collect transaction-related information including your chosen payment method (bKash, Nagad, Rocket, Upay, DBBL, Visa, or Mastercard), mobile wallet number or masked card number, transaction reference identifiers, and transaction amounts in Bangladeshi Taka (৳ BDT). crwin does not store full card numbers, CVV codes, or mobile wallet PINs at any stage of the transaction process.

Identity Verification Data: As part of our Know Your Customer (KYC) process, we may collect copies of government-issued identification documents such as your National Identity Card (NID), passport, or driving licence, as well as supporting proof-of-address documentation. This data is collected and stored solely for the purpose of verifying your identity and preventing fraud.

Usage and Behavioural Data: crwin automatically collects data about how you interact with the platform, including pages visited, games played, bet amounts and frequencies, session duration, search queries within the platform, and feature usage patterns. This data is used in aggregate and individually to improve the platform experience and to fulfil responsible gaming obligations.

Technical Data: We collect standard technical information when you access the crwin platform, including your IP address, browser type and version, device type, operating system, screen resolution, time zone setting (Bangladesh Standard Time, UTC+6), and referring URL. This data helps us maintain platform security and optimise performance across devices.

crwin uses the personal data we collect for the following specific and lawful purposes:

crwin will not use your personal data for any purpose that is incompatible with the purposes listed above without first notifying you and, where required, obtaining your explicit consent. Where we rely on legitimate interests as a legal basis, we carry out a balancing assessment to ensure our interests do not override your fundamental privacy rights.

crwin uses cookies and similar tracking technologies to operate the platform, maintain your session when you are logged in, and gather anonymised analytics about how players use our services. A cookie is a small text file that is placed on your device when you visit a website. Cookies set by crwin do not contain personally identifiable information in isolation.

We use the following categories of cookies on the crwin platform:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They manage your login session, maintain your account security state, store your language and currency preferences, and facilitate the flow of deposit and withdrawal requests. Without these cookies, core platform features cannot operate. You cannot opt out of strictly necessary cookies while using the platform.
• Analytical / Performance Cookies: These cookies collect anonymised data about how players navigate and interact with the crwin platform — for example, which pages are visited most frequently, how long sessions typically last, and which features are most commonly used. We use this data to improve the platform and to identify technical issues. This data is aggregated and cannot be used to identify individual players.
• Functional Cookies: These cookies remember choices you have made — such as your preferred deposit method or notification settings — to provide you with a more personalised platform experience on return visits.

crwin does not currently use third-party advertising cookies or behavioural tracking cookies that build profiles for external advertising networks. If this changes in the future, this Privacy Policy will be updated accordingly and you will be notified.

You may manage or delete cookies through your browser settings at any time. Note that disabling strictly necessary cookies will impair your ability to log in and use the crwin platform. For guidance on managing cookies in popular browsers, refer to your browser's help documentation.

crwin does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may, however, share your data with the following categories of recipients where strictly necessary and under appropriate safeguards:

• Payment Service Providers: When you make a deposit or withdrawal via bKash, Nagad, Rocket, Upay, DBBL, Visa, or Mastercard, we share the minimum necessary transaction data with the relevant payment processor to complete the transaction securely. These providers operate under their own privacy policies and data security standards.
• Identity Verification Services: crwin works with third-party KYC and identity verification service providers to validate the identity documents submitted by players during account registration or during enhanced verification checks. These providers process identity data solely on our behalf and under strict contractual data protection obligations.
• Fraud Prevention & Security Partners: We share technical and behavioural data with security technology providers to detect and prevent fraud, money laundering, and other prohibited activities on the platform. This sharing is conducted on the basis of our legitimate interests in maintaining a safe and compliant platform.
• Regulatory and Law Enforcement Authorities: crwin is legally obligated to disclose player data to competent authorities when required by applicable law, court order, or regulatory directive. We will only provide the minimum data required to satisfy such requests and will notify affected players where we are legally permitted to do so.
• Platform Technology Providers: Core platform infrastructure, game software providers, and cloud hosting services may process player data as part of delivering the crwin service. All such providers are bound by data processing agreements that prohibit them from using player data for any purpose other than delivering services to crwin.

crwin retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The general retention periods we apply are as follows:

• Active Account Data: Personal data associated with an active player account is retained for the duration of the account's active status and for a period of five (5) years following account closure, in accordance with standard financial record-keeping requirements.
• Transaction Records: Records of all deposits, withdrawals, and betting transactions are retained for a minimum of five (5) years from the date of the transaction to satisfy applicable anti-money laundering and financial compliance requirements.
• Identity Verification Documents: KYC documents submitted by players are retained for five (5) years following account closure, or longer if required by law.
• Support Communications: Records of customer support interactions, including emails and chat logs, are retained for up to three (3) years from the date of the interaction to allow for dispute resolution and service quality review.
• Anonymised Analytics Data: Usage and behavioural data that has been fully anonymised is not subject to a fixed retention period, as it cannot be used to identify any individual player.

Upon expiry of the applicable retention period, crwin will securely delete or irreversibly anonymise your personal data. Where deletion is not immediately technically feasible (for example, where data is stored in backup archives), crwin will isolate the data from active processing until deletion is possible.

As a player on the crwin platform, you hold the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact us at [email protected] with a clear description of your request. We will respond within a reasonable timeframe.

• Right of Access: You have the right to request a copy of the personal data crwin holds about you, along with information about how it is being used and with whom it has been shared.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure: Subject to legal and regulatory retention obligations, you may request that crwin delete the personal data we hold about you. Note that certain data must be retained for the periods described in Section 5 regardless of an erasure request.
• Right to Restriction of Processing: You may request that we restrict the processing of your personal data in certain circumstances — for example, if you contest the accuracy of the data while we carry out a verification check.
• Right to Data Portability: Where technically feasible and legally applicable, you may request that we provide your personal data in a structured, machine-readable format so that it can be transferred to another service provider of your choosing.
• Right to Object: You have the right to object to the processing of your personal data where we rely on legitimate interests as the legal basis for that processing, unless our legitimate interests are demonstrably compelling and override your privacy rights.
• Right to Withdraw Consent: Where processing is based on your consent (for example, receiving marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

crwin implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS Encryption: All data in transit between your device and crwin servers is encrypted using industry-standard SSL/TLS protocols, preventing interception by third parties.
• Encryption at Rest: Sensitive personal and financial data stored on crwin infrastructure is encrypted at rest using AES-256 or equivalent encryption standards.
• Access Controls: Access to personal data within the crwin organisation is strictly limited to personnel who require it to perform their job functions. All staff with access to personal data are subject to confidentiality obligations.
• Regular Security Audits: crwin conducts periodic security reviews and vulnerability assessments to identify and address potential weaknesses in the platform's technical infrastructure.
• Incident Response: In the event of a data security incident that is likely to result in a risk to the rights and freedoms of players, crwin will take immediate containment measures and will notify affected players and relevant authorities in accordance with applicable legal requirements.

While crwin takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is entirely secure. We encourage you to take steps to protect your own account security, including using a strong unique password and never sharing your login credentials with third parties.

crwin reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the features and services offered on the platform. When we make material changes to this policy, we will notify registered players by posting a prominent notice on the crwin platform and, where appropriate, by sending a notification to the email address or mobile number registered on your account.

The "Last updated" date at the top of this document will always reflect the date on which the most recent revision came into effect. We encourage you to review this Privacy Policy periodically to stay informed about how crwin collects, uses, and protects your data.

Your continued use of the crwin platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you should discontinue your use of the platform and contact our support team to request account closure and the deletion of your personal data, subject to the retention obligations described in Section 5.

For any questions, concerns, or requests relating to this Privacy Policy or the personal data crwin holds about you, please contact our support team at [email protected]. We are available 24/7 and aim to respond to all privacy-related inquiries within 48 hours (Bangladesh Standard Time).