Privacy Policy – milvin

1. Data Controller

1.1 milvin is the data controller responsible for the personal data you provide when registering and using the milvin Platform. For any data-related enquiries, contact milvin's support team at: [email protected]

1.2 milvin processes personal data in accordance with applicable international data protection standards and its obligations under applicable regulations relevant to online gaming platforms operating in the markets it serves.

2. Data We Collect

2.1 Registration Data. When you create a milvin Account, we collect: full legal name, email address, date of birth, Pakistani mobile number, and a password (stored as a one-way cryptographic hash — never in plaintext).

2.2 Identity Verification (KYC) Data. To comply with anti-money laundering (AML) obligations and to verify your age and identity, milvin collects copies of your Computerised National Identity Card (CNIC) — front and back. This data is used exclusively for verification purposes.

2.3 Financial Data. milvin records details of deposits, withdrawals, and transaction history associated with your Account. We collect the payment method type (e.g., JazzCash, Easypaisa, HBL) and transaction reference numbers. milvin does not store full bank account numbers or mobile wallet PINs.

2.4 Usage Data. milvin automatically collects technical data about your use of the Platform, including: IP address, browser type and version, device type and operating system, session timestamps, pages visited, game sessions played, and betting history. This data is used for fraud detection, platform improvement, and responsible gaming monitoring.

2.5 Communications Data. Records of communications between you and milvin's support team — whether by live chat or email — are retained for quality assurance, dispute resolution, and regulatory compliance purposes.

2.6 Cookie Data. milvin uses session cookies and persistent cookies as described in Section 8 of this Policy.

3. How We Use Your Data

milvin uses your personal data for the following purposes:

• Creating, maintaining, and securing your milvin Account;
• Processing deposits, withdrawals, and refunds in PKR;
• Verifying your identity and age in compliance with KYC and AML requirements;
• Detecting, investigating, and preventing fraud, money laundering, and Prohibited Activities as defined in the Terms & Conditions;
• Monitoring your usage for responsible gaming purposes and applying account protections where necessary;
• Providing customer support and resolving disputes;
• Sending transactional communications (deposit confirmations, withdrawal notifications, security alerts) — these are not optional and are sent regardless of marketing preferences;
• Sending promotional communications where you have opted in;
• Improving the milvin Platform through analysis of aggregated, anonymised usage data;
• Complying with legal and regulatory obligations applicable to milvin.

4. Legal Basis for Processing

4.1 Contractual necessity: Processing of registration data, financial data, and KYC data is necessary to fulfil milvin's obligations under the Account agreement with you.

4.2 Legal obligation: Processing of KYC and AML-related data is required to comply with applicable anti-money laundering regulations and age verification obligations.

4.3 Legitimate interests: Processing of usage data for fraud detection, platform security, and responsible gaming monitoring is conducted on the basis of milvin's legitimate interest in operating a safe and compliant platform.

4.4 Consent: Processing of personal data for marketing communications is conducted on the basis of your opt-in consent, which may be withdrawn at any time.

5. Data Sharing and Third Parties

5.1 milvin does not sell, rent, or trade your personal data to any third party for commercial purposes.

5.2 milvin shares personal data with the following categories of third parties solely as necessary to operate the Platform:

• Payment processors: JazzCash, Easypaisa, and banking partners receive the minimum data necessary to process your transactions (name, account reference, and transaction amount).
• KYC verification providers: Identity document data may be processed by milvin's KYC technology partners under strict confidentiality obligations.
• Game content providers: Game studios receive anonymised session data (player ID, bet amount, game outcome) necessary for game functionality and dispute resolution. They do not receive your personal identity information.
• Cloud hosting and infrastructure providers: milvin's Platform is hosted on secure cloud infrastructure. Hosting providers have contractual obligations to maintain data security.
• Regulatory and law enforcement authorities: milvin will disclose personal data when required to do so by law, court order, or regulatory authority.

5.3 All third-party data processors engaged by milvin are bound by contractual data processing agreements that require them to process your data only on milvin's documented instructions and to maintain appropriate security measures.

6. Data Retention

6.1 milvin retains your personal data for as long as your Account is active and for a minimum period of five (5) years following Account closure, in accordance with standard AML record-keeping obligations applicable to online gaming operators.

6.2 KYC documentation (CNIC copies) is retained for a minimum of five (5) years following the last transaction on your Account, in compliance with anti-money laundering record-keeping requirements.

6.3 Communications data (support chat and email records) is retained for three (3) years for quality assurance and dispute resolution purposes.

6.4 Where you request deletion of your personal data, milvin will delete or anonymise all data not subject to a mandatory retention obligation within thirty (30) days of receiving a verified deletion request.

7. Your Data Rights

You have the following rights regarding your personal data held by milvin:

• Right of access: You may request a copy of the personal data milvin holds about you.
• Right of rectification: You may request correction of inaccurate or incomplete personal data.
• Right of erasure: You may request deletion of your personal data, subject to mandatory retention obligations.
• Right to restrict processing: You may request that milvin restricts processing of your data in certain circumstances.
• Right to data portability: You may request your personal data in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact milvin at: [email protected]. milvin will respond within 30 days of receiving a verified request.

8. Cookies

8.1 milvin uses cookies and similar tracking technologies to operate the Platform, maintain your session, and improve user experience. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled without impairing Platform functionality.
• Functional cookies: Store your preferences (e.g., language, display settings) to improve your experience on return visits.
• Analytics cookies: Collect anonymised usage data to help milvin understand how the Platform is used and where improvements can be made. No personally identifiable information is included in analytics data.

8.2 You may control cookie settings through your browser settings. Disabling strictly necessary cookies will impair your ability to use the milvin Platform, including login functionality.

9. Data Security

9.1 milvin implements technical and organisational security measures proportionate to the risk posed by its data processing activities. These include: TLS encryption for all data in transit; encryption at rest for sensitive data fields; access controls limiting data access to authorised personnel on a need-to-know basis; and security monitoring to detect anomalous access patterns.

9.2 In the event of a data breach that is likely to result in risk to your rights and freedoms, milvin will notify you without undue delay and take all reasonable steps to mitigate the impact of the breach.

9.3 You are responsible for maintaining the security of your milvin Account credentials. milvin strongly recommends enabling two-factor authentication and using a unique, strong password not used on other platforms. If you suspect unauthorised access to your Account, contact milvin support immediately at: [email protected]

10. Children's Privacy

10.1 The milvin Platform is strictly for adults aged 18 and over. milvin does not knowingly collect personal data from individuals under the age of 18. If milvin discovers that a minor has registered an Account, that Account will be immediately closed and all associated data will be deleted, subject to any mandatory record-keeping obligations related to the underage access incident.

10.2 If you believe a minor has registered at milvin, please contact support at: [email protected] immediately.

11. Changes to This Policy

11.1 milvin may update this Privacy Policy from time to time to reflect changes in its data processing practices, legal obligations, or Platform features. Material changes will be communicated to you via your registered email address at least 7 days before the revised Policy takes effect.

11.2 The current version of the Privacy Policy is always available at milvin.app/privacy-policy. The "Last updated" date at the top of this page indicates when the Policy was most recently revised.

12. Contact

For any privacy-related questions, data access requests, or complaints regarding milvin's handling of your personal data, please contact: [email protected]

milvin endeavours to resolve all privacy enquiries within 14 business days of receipt.