winpbu Privacy Policy

This Privacy Policy ("Policy") describes how winpbu ("we", "us", "our", or the "Operator") collects, uses, stores, discloses, and protects the personal information of users ("you", "your", or the "Player") who register for or access the winpbu online gaming platform, available at winpbu.app (the "Platform").

winpbu is committed to safeguarding the privacy of all players, with particular care given to the expectations and legal context applicable to users based in Bangladesh. Our Platform serves players across Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, Cox's Bazar, and all other cities and regions throughout Bangladesh.

By creating an account or otherwise using the Platform, you confirm that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with the terms of this Policy, you must cease using the Platform and contact us to arrange account closure.

This Policy applies to all data processing activities carried out in connection with the Platform, including account registration, identity verification (KYC), deposits and withdrawals, gameplay, customer support communications, and marketing (where applicable and consented to).

winpbu collects personal data through several channels: directly from you when you register or interact with the Platform, automatically through technical systems as you use the Platform, and from trusted third-party identity and payment verification services. The categories of data we collect are described below.

2.1 Account Registration Data

When you create a winpbu account, we collect the following information:

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify you are 18 years of age or older)
• Email address (used as your primary account identifier and for communications)
• Mobile phone number (used for account verification and security alerts)
• Residential address in Bangladesh
• Username and encrypted password

2.2 KYC Verification Data

As part of our mandatory Know Your Customer (KYC) process, we collect copies of the following documents:

• Government-issued photo identification (National Identity Card, passport, or driving licence)
• Proof of address (recent utility bill, bank statement, or official correspondence)
• Proof of payment method ownership (e.g., confirmation that a bKash, Nagad, Rocket, or Upay account is registered in your name)

2.3 Financial Transaction Data

We record details of all deposits and withdrawals processed through your winpbu account, including transaction amounts in Bangladeshi Taka (৳), timestamps, payment method references (partial account numbers or mobile numbers — never full card numbers), and transaction status records.

2.4 Gameplay and Betting Data

We maintain records of your gaming activity on the Platform, including game sessions, bet amounts, outcomes, bonus usage, and wagering history. This data is used for account management, dispute resolution, responsible gaming monitoring, and fraud detection.

2.5 Technical and Device Data

Our systems automatically collect certain technical data when you access the Platform:

2.6 Customer Support Communications

When you contact winpbu via email at [email protected], we retain the content of those communications, including any attachments, together with your email address, the date and time of contact, and the nature of the enquiry. These records are kept for quality assurance and dispute resolution purposes.

winpbu uses the personal data it collects for the following specific and legitimate purposes:

• Account Management: To create, maintain, and administer your winpbu account, including processing your registration, verifying your identity, and managing account security settings.
• Transaction Processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, and supported local banks, and to maintain accurate financial records associated with your account.
• KYC Compliance: To verify your identity and age in accordance with our responsible gaming obligations. This includes matching the information you provide during registration against KYC documentation.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorised account access, and other security threats. This includes cross-referencing your data against risk indicators and watchlists where applicable.
• Responsible Gaming: To monitor your gameplay activity for signs of problem gambling behaviour and to administer self-exclusion, deposit limits, and cool-off requests that you initiate through the Platform's responsible gaming tools.
• Customer Support: To respond to your enquiries, process complaints, and provide technical assistance via our support team at [email protected].
• Platform Improvement: To analyse aggregated, anonymised usage data that helps us improve the Platform's functionality, game selection, payment flows, and user experience.
• Legal Compliance: To comply with applicable laws, respond to lawful requests from authorities, and enforce our Terms & Conditions and other contractual obligations.
• Promotional Communications: Where you have opted in to marketing communications, to send you information about new games, promotions, seasonal offers (such as Eid or Pohela Boishakh specials), and other Platform updates. You may opt out of marketing at any time by contacting [email protected].

winpbu processes your personal data on the following legal grounds, depending on the nature of the processing activity:

Where winpbu relies on legitimate interests as a legal basis, we have conducted a balancing assessment and are satisfied that our interests do not override your fundamental privacy rights. You retain the right to object to processing carried out on the legitimate interests basis at any time — see Section 9 for details.

winpbu does not share your personal data with third parties except in the following limited and controlled circumstances:

• Payment Processors: We share the minimum necessary transaction data with payment service providers (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank) to facilitate deposits and withdrawals. These providers process your data as independent data controllers under their own privacy policies and are subject to their own regulatory obligations.
• Game Technology Providers: Our Platform is powered by internationally certified game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers may process technical session data (such as game round identifiers and bet records) as part of their game delivery infrastructure. They do not receive your full name, address, or financial data.
• KYC Verification Services: Where we use third-party identity verification technology to assist with document review, the minimum required data is shared under strict data processing agreements that prohibit any secondary use.
• Legal and Regulatory Authorities: winpbu will disclose personal data to law enforcement agencies, courts, or regulatory bodies if required to do so by applicable law, court order, or in connection with the investigation of suspected criminal activity including fraud or money laundering. We will notify you of such disclosures where we are legally permitted to do so.
• Business Transfers: In the event that winpbu undergoes a corporate restructuring, merger, or acquisition, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any material changes to this Policy that may result.

No cross-border transfer of your personal data to countries outside of your region will take place without appropriate safeguards being in place, such as standard contractual clauses or equivalent data protection measures.

winpbu uses cookies and similar tracking technologies to ensure the Platform functions correctly, to maintain your session while you are logged in, and to improve the overall user experience. The following types of cookies are used on the Platform:

winpbu does not use third-party advertising cookies or behavioural tracking technologies that build profiles for external ad-targeting purposes.

Most web browsers allow you to manage your cookie settings through the browser's privacy or settings menu. Please note that disabling strictly necessary or security cookies may prevent you from accessing certain features of the Platform, including your account dashboard and payment pages.

winpbu 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 law. The following general retention periods apply:

• Active Account Data: All account registration data, KYC documents, transaction records, and gameplay history are retained for the full duration that your account remains active on the Platform.
• Post-Closure Retention: Following the closure of your account — whether initiated by you or by winpbu — we retain your personal data for a minimum period of five (5) years. This is necessary to meet our legal obligations relating to financial record-keeping, fraud investigation, and potential dispute resolution.
• KYC Documents: Identity and address verification documents are retained in accordance with applicable anti-money laundering requirements, which typically mandate a minimum retention period of five (5) years from the date of the last transaction or the closure of the account, whichever is later.
• Customer Support Records: Communications with our support team are retained for three (3) years from the date of the last interaction, to enable context for any follow-up enquiries or disputes.
• Marketing Consent Records: If you opted in to marketing communications, a record of that consent is retained for as long as we send you marketing material and for a reasonable period thereafter as evidence of lawful processing.

When the applicable retention period expires, your personal data is securely deleted or anonymised in a manner that prevents re-identification. Anonymised, aggregated analytics data that no longer identifies any individual may be retained indefinitely for Platform improvement purposes.

winpbu implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security architecture includes:

• SSL/TLS Encryption: All data transmitted between your device and the winpbu Platform is encrypted using TLS 1.2 or higher. This protects your login credentials, payment details, and personal information during transit.
• Encryption at Rest: Sensitive data fields stored in our databases — including passwords (stored as one-way hashes), KYC document images, and payment references — are encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to systems that hold personal data is restricted to authorised winpbu personnel on a strict need-to-know basis. All internal access is logged and subject to regular audit.
• Two-Factor Authentication (2FA): Internal administrative systems that handle player data are protected by multi-factor authentication, reducing the risk of unauthorised access resulting from compromised credentials.
• Penetration Testing: winpbu commissions regular security assessments of its Platform infrastructure to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: We maintain a documented data breach response plan. In the event of a security incident that puts your personal data at risk, winpbu will assess the impact and notify affected players as quickly as practicable, in accordance with applicable legal obligations.

While we take all reasonable precautions to protect your data, no digital platform can guarantee absolute security against all threats. You also play an important role in keeping your account secure by choosing a strong, unique password and by never sharing your login credentials with any other person.

As a player on the winpbu Platform, you have the following rights with respect to the personal data we hold about you. To exercise any of these rights, please submit a written request from your registered email address to [email protected]. winpbu will acknowledge your request within five (5) business days and aim to fulfil it within thirty (30) days.

• Right of Access: You have the right to request a copy of all personal data that winpbu holds about you, along with information about how it is used and shared (a "Subject Access Request").
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it promptly.
• Right to Erasure ("Right to Be Forgotten"): You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where you believe processing is unlawful. Note that we may be required by law to retain certain data even following a deletion request — we will inform you clearly of any such limitations.
• Right to Restriction: You may ask us to pause our processing of your data while a complaint or accuracy dispute is being resolved, or where you have objected to processing and we are assessing whether our legitimate interests override your rights.
• Right to Data Portability: Where processing is based on your consent or on a contract with you, you have the right to receive a copy of your data in a structured, commonly used, machine-readable format (such as CSV or JSON), and to have it transmitted directly to another data controller where technically feasible.
• Right to Object: You may object at any time to processing that is based on legitimate interests (including profiling for fraud prevention), and to the use of your data for direct marketing purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where we process your data based on your consent (e.g., for marketing communications), you may withdraw that consent at any time with immediate effect. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.

winpbu is strictly an adult gaming platform. We do not knowingly collect, process, or retain any personal data from individuals under the age of 18. Our registration process requires all applicants to confirm they are 18 years of age or older, and our KYC verification programme is designed to detect and prevent underage registration.

If winpbu becomes aware at any point that an account has been created by or on behalf of a person under the age of 18, that account will be immediately and permanently closed, all associated funds will be returned to the original payment source, and all collected personal data will be deleted as promptly as technically feasible in accordance with our data retention obligations.

We encourage parents and guardians to use available parental control tools on shared devices to prevent minors from accessing online gaming platforms. winpbu supports the use of third-party parental control software as a complementary measure to our own age verification procedures.

The winpbu Platform may from time to time contain references or contextual links to third-party services, including payment providers and game studios whose products are embedded within the Platform. This Privacy Policy applies solely to personal data processed by winpbu in connection with the Platform.

When you interact with a third-party payment provider (such as bKash or Nagad) to process a deposit or withdrawal, you will be doing so under that provider's own terms of service and privacy policy. winpbu encourages you to review those policies before submitting financial information directly to any third-party payment interface.

Similarly, certain games on the Platform are delivered by third-party game providers whose technology may process technical session data on their own infrastructure. winpbu selects only internationally certified providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — and maintains data processing agreements with each of them to ensure your data is handled appropriately.

winpbu is not responsible for the privacy practices or content of third-party services. If you have concerns about how a specific game provider or payment processor handles your data, please refer directly to that provider's published privacy documentation.

winpbu reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to the Platform. When material changes are made to this Policy, we will notify registered players by email to the address on file and by displaying a prominent notice on the Platform.

For material changes — those that meaningfully affect how we collect, use, or share your personal data — we will provide a minimum of fourteen (14) days' notice before the changes take effect, giving you the opportunity to review the updated Policy and, if you do not agree, to close your account before the changes apply to you.

For minor or administrative changes (such as correcting a typographical error, updating contact details, or clarifying existing language without altering the substance of the Policy), we may update the Policy immediately and will note the revised "Last updated" date at the top of this page.

Your continued use of the Platform after any update to this Privacy Policy constitutes your acceptance of the revised terms. We recommend bookmarking this page and reviewing it periodically to stay informed of how winpbu protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way winpbu handles your personal data, you are encouraged to contact our Data Protection Officer (DPO) directly. All privacy-related correspondence will be treated confidentially and responded to within five (5) business days.

You may reach the winpbu Data Protection Officer by email at:

winpbu is committed to resolving all privacy concerns internally in the first instance. If, however, you feel that your concern has not been addressed adequately, you have the right to escalate the matter to the appropriate data protection authority or consumer protection body in your jurisdiction.

For players based in Bangladesh, we encourage you to contact our support team in the first instance. winpbu will always cooperate fully with any lawful enquiry from a regulatory or law enforcement authority regarding the protection of your personal data.