Privacy Policy — How 10wine Protects Your Data

1Introduction

10wine ("we", "us", "our", "Platform") operates the website at https://10wine.cam and all associated digital services. We are committed to protecting the personal data of every user who accesses, registers on or interacts with our Platform ("User", "you", "your").

This Privacy Policy describes how 10wine collects, processes, stores, transfers and protects personal data in connection with the provision of our online sports betting and live casino information services, primarily targeting users in Pakistan. It has been drafted in plain-language legal English to ensure that all users — wherever they are located — can clearly understand how their data is handled.

By creating an account or using the 10wine Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. Where consent is required and you decline to provide it, certain features of the Platform may not be accessible to you.

2Definitions

The following defined terms apply throughout this Privacy Policy:

3Data Controller

10wine operates as the Data Controller for all personal data collected through the Platform at https://10wine.cam. As Data Controller, 10wine determines the purposes for which personal data is collected and the manner in which it is processed.

Where third-party Data Processors are engaged (for example, KYC verification providers, cloud infrastructure providers or payment gateway operators), 10wine ensures that appropriate data processing agreements are in place requiring those processors to protect personal data to an equivalent standard and to process data only on 10wine's documented instructions.

For all data-related enquiries, requests to exercise data rights, or complaints relating to data processing, please contact us at the details provided in Section 16 of this Policy.

4Data We Collect

10wine collects personal data from the following categories, depending on the nature of your interaction with the Platform:

4.1 Registration & Account Data

• Full legal name, date of birth, gender (where required for age verification).
• Residential address, including city and country of residence.
• Email address and mobile telephone number.
• Username and encrypted password credentials.
• Account preference settings and communication opt-in status.

4.2 Identity Verification (KYC) Data

• Scanned or photographed copies of valid identity documents — for Pakistani users, this typically means a CNIC (Computerised National Identity Card) or valid passport.
• Proof of residential address documentation (utility bills, bank statements, government correspondence), where required.
• Selfie photographs or liveness verification data submitted through the official KYC portal.
• Source-of-funds documentation where applicable under AML procedures.

4.3 Financial & Transaction Data

• Deposit and withdrawal records including amounts, timestamps and payment method references.
• Wagering history and game play records.
• Payment method identifiers (e.g., masked mobile wallet numbers or bank account references) — full card or account numbers are never stored on 10wine systems.

4.4 Device, Session & Technical Data

• IP address, browser type and version, operating system and device type.
• Session timestamps, login history and page interaction data.
• Cookie identifiers and similar tracking technologies as described in Section 11.

4.5 Communications Data

• Records of support enquiries submitted via live chat, email or in-platform messaging.
• Complaint records and dispute correspondence.
• Responses to surveys or feedback requests where you choose to participate.

5Legal Basis for Processing

10wine processes personal data on one or more of the following legal bases depending on the category of data and the purpose of processing:

6How We Use Your Data

10wine uses personal data for the following purposes:

• Account management: Creating, maintaining and securing your registered account.
• Service delivery: Processing deposits, executing wagers, settling bets and processing withdrawal requests.
• KYC & compliance: Verifying your identity, age and, where applicable, source of funds in accordance with AML obligations.
• Fraud prevention & security: Detecting and preventing fraudulent activity, unauthorised account access, money laundering and other prohibited conduct.
• Responsible gambling: Monitoring usage patterns to identify indicators of problem gambling and, where appropriate, applying protective interventions such as mandatory cooling-off or escalation to responsible gambling support.
• Customer support: Responding to enquiries, resolving disputes and administering complaints.
• Platform improvement: Analysing aggregated usage data to identify technical issues, improve user experience and develop new features.
• Legal compliance: Fulfilling obligations under applicable laws and cooperating with regulatory or law enforcement authorities where lawfully required.
• Marketing communications: Sending promotional offers, bonus notifications and platform updates to users who have opted in to receive such communications. You may unsubscribe at any time.

7Data Sharing & Disclosure

10wine does not sell, rent or trade your personal data to third parties. We may share personal data in the following limited circumstances:

• Authorised Data Processors: Third-party service providers acting as Data Processors under contract — including KYC verification providers, cloud infrastructure services, payment gateway operators and customer support platform providers. These processors are contractually required to protect your data and process it only on our instructions.
• Legal & Regulatory Disclosure: Where required by applicable law, court order or regulatory authority — including disclosure to financial intelligence units or law enforcement agencies under AML obligations. 10wine will, where legally permitted, notify affected users of such disclosure.
• Business Transfers: In the event of a merger, acquisition, asset sale or corporate restructuring, personal data may be transferred to the successor entity, subject to equivalent data protection obligations.
• Fraud Prevention Networks: Aggregated or anonymised fraud signals may be shared with industry fraud prevention networks. Individual personal data is not shared in this context.

Payment provider context: When you select a payment method at the cashier — such as mobile wallet services like Easypaisa or JazzCash, Raast transfers, or bank transfers via institutions such as HBL, UBL, Meezan Bank or Bank Alfalah — transaction data is exchanged with the relevant payment processor to execute the transaction. 10wine does not control the data practices of independent payment providers. These providers are independent entities operating under their own privacy policies and regulatory frameworks.

8International Data Transfers

10wine's infrastructure and certain Data Processors may be located outside Pakistan. Where personal data is transferred to countries that may not provide data protection standards equivalent to those applicable in the operator's licensing jurisdiction, 10wine ensures that appropriate safeguards are in place, which may include:

• Standard Contractual Clauses approved by applicable data protection authorities.
• Data processing agreements incorporating binding data protection obligations on the recipient.
• Transfers to jurisdictions formally recognised as providing adequate data protection.

By using the 10wine Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan for the purposes described in this Policy.

9Data Retention

10wine retains personal data only for as long as is necessary for the purposes for which it was collected or as required by applicable legal and regulatory obligations. The following retention principles apply:

• Active accounts: Personal data is retained for the duration of your active account relationship with 10wine.
• Closed accounts: Following account closure, personal data — including KYC documents, transaction records and account history — may be retained for a period of up to five (5) years or longer if required by applicable AML legislation, tax regulations or ongoing legal proceedings.
• Marketing data: Where consent was the basis for marketing communications, opt-in records are retained for the period during which you remain subscribed and for a reasonable period thereafter as evidence of lawful processing.
• Support communications: Retained for a period sufficient to resolve any ongoing disputes and for quality assurance purposes, subject to applicable legal minimum periods.

When data is no longer required, it is securely deleted or anonymised in accordance with our data destruction procedures.

10Security Measures

10wine implements a range of technical and organisational security measures to protect personal data against unauthorised access, loss, destruction, alteration or disclosure:

• TLS/SSL encryption for all data transmitted between your device and the 10wine Platform.
• Encryption at rest for sensitive personal data including identity documents and financial records.
• Role-based access controls restricting access to personal data to authorised personnel on a strict need-to-know basis.
• Two-factor authentication available for all user accounts and mandatory for administrative access.
• Regular security assessments and penetration testing of Platform infrastructure.
• Intrusion detection systems and automated monitoring for suspicious access patterns.
• Secure document portals for KYC submissions — identity documents must never be sent via unencrypted channels.

11Cookies & Tracking Technologies

10wine uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies may be used:

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will affect Platform functionality. 10wine does not use third-party advertising cookies to track your behaviour across external websites.

12Minors

The 10wine Platform is strictly for adults aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. We do not knowingly collect personal data from individuals under the applicable minimum age.

If we become aware that personal data has been collected from an individual below the applicable minimum age, that account will be closed immediately, all associated data will be deleted (subject to any legal retention requirements) and any balance will be handled in accordance with our responsible gambling policies. Parents or guardians who believe a minor has registered on the Platform should contact us immediately at [email protected].

Age verification through KYC is mandatory before withdrawal and may be triggered at any stage of account activity. 10wine employs automated detection measures to identify indicators of underage account usage.

13Your Data Rights

Subject to applicable law and any overriding legal obligations (such as AML record-keeping requirements), you hold the following rights with respect to your personal data held by 10wine:

To exercise any of the above rights, submit a written request to [email protected] clearly identifying the right you wish to exercise and providing sufficient information to verify your identity. We will respond within 30 calendar days and will not charge a fee for reasonable requests. Manifestly unfounded or excessive requests may be refused or subject to a reasonable administrative charge.

14Third-Party Links

The 10wine Platform may contain references or informational mentions of third-party payment services — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — for contextual and educational purposes relevant to Pakistani users. These references do not constitute endorsement of those providers, and 10wine has no control over the privacy practices, data policies or security measures of any independent third party.

Users who interact with third-party payment providers, financial institutions or any external service in connection with their use of 10wine do so subject to the privacy policies of those third parties. 10wine accepts no responsibility for data handling practices of independent third parties.

15Policy Amendments

10wine reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, data processing practices or Platform functionality. The "Last Reviewed" date at the top of this Policy will be updated whenever material changes are made.

Where changes are material — particularly those that affect your data rights or expand the categories of data collected — reasonable advance notice will be provided to registered users via email or on-Platform notification.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of and agreement to the revised terms. If you do not agree to any update, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

16Contact Us

For all privacy-related enquiries, requests to exercise data rights, consent withdrawals or complaints regarding data processing, please contact 10wine's data team using the details below:

The email address above is displayed as plain text only. Do not send sensitive identity documents or banking credentials by standard email — use only the secure HTTPS verification portal accessible from your logged-in account area.