10wine Privacy Policy

This Privacy Policy ("Policy") sets out the data protection practices of 10wine ("10wine", "we", "us", "the Platform"), the online casino and sports betting platform operated at 10wine.app and accessible to registered players in Pakistan and other permitted jurisdictions.

This Policy explains what personal data we collect from you when you visit or use the 10wine platform, the purposes for which that data is processed, the legal basis on which we rely, how long we retain it, who we share it with, and the rights available to you in relation to your personal data.

By registering an account on 10wine, depositing funds, or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not register or continue to use the 10wine platform.

This Policy should be read alongside the 10wine Terms & Conditions and Responsible Gaming Policy, which together govern your use of the platform.

10wine collects personal data from you directly, automatically through your use of the platform, and in limited cases from third-party verification providers. The categories of personal data we collect are set out below.

2.1 Registration Data

When you create a 10wine account, we collect the following information which you provide directly:

• Full legal name (as it appears on your government-issued identity document)
• Date of birth (for age verification — all players must be 21 or older)
• Residential address, including city (Karachi, Lahore, Islamabad, Faisalabad, or other)
• Email address
• Mobile phone number (used for account security and payment method verification)
• Preferred currency (Pakistani Rupees / PKR)
• Username and encrypted password credentials

2.2 KYC and Identity Verification Data

As required by our international gaming licence, 10wine must conduct Know Your Customer (KYC) verification on all registered accounts before processing withdrawals and at other points in the account lifecycle. KYC data collected may include:

• Scanned or photographed copy of your National Identity Card (CNIC) or valid passport
• Proof of residential address (utility bill, bank statement, or equivalent document)
• Proof of payment method ownership (screenshot of JazzCash, EasyPaisa, or bank account)
• In higher-risk cases, source of funds documentation

2.3 Transaction and Financial Data

10wine records all financial transactions associated with your account, including:

• Deposit amounts, dates, and payment method used (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, bank transfer)
• Withdrawal requests, amounts, and disbursement method
• Bonus credits awarded and wagering requirement progress
• Transaction reference numbers provided by payment processors

2.4 Gaming and Betting Activity Data

We maintain a complete record of your gambling activity on the platform, including:

• All wagers placed on sportsbook markets (cricket, PSL, UFC, and other available markets)
• All casino game sessions, including game title, stake, outcome, and session duration
• Instant game activity (Mines Gold, crash games, and similar titles)
• Bonus usage and any applicable wagering requirement calculations

2.5 Technical and Device Data

When you access the 10wine platform, our systems automatically collect certain technical data, including:

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser version
• Session timestamps, page visit logs, and navigation patterns
• Cookie identifiers (see Section 6 for full cookie details)

2.6 Customer Support Data

When you contact 10wine's 24/7 customer support team by email or live chat, we retain records of those communications, including the content of messages exchanged, the nature of the query or complaint, and any resolution reached.

10wine processes your personal data for the following specific purposes. We do not use your data for any purpose not listed below without first obtaining your explicit consent or where otherwise required by law.

10wine relies on one or more of the following legal bases when processing your personal data, depending on the specific processing activity involved:

• Contractual necessity: Processing is necessary for the performance of the contract between you and 10wine (i.e., the Terms and Conditions you accepted at registration), including account management, gaming service delivery, and payment processing.
• Legal obligation: Processing is required for 10wine to comply with its international gaming licence obligations, including mandatory KYC, AML monitoring, and regulatory record-keeping requirements.
• Legitimate interests: Processing is necessary for the legitimate interests of 10wine, including fraud prevention, platform security, abuse detection, and responsible gaming monitoring — provided those interests are not overridden by your rights and freedoms.
• Consent: Where processing is not otherwise justified by the above bases, 10wine will seek your explicit consent prior to processing, such as for optional marketing communications.

10wine does not sell, rent, or disclose your personal data to third parties for their own commercial purposes. We share your personal data only in the following limited circumstances, and only to the extent necessary for the relevant purpose:

5.1 Payment Processors

To process PKR deposits and withdrawals, 10wine shares the minimum necessary transactional and identity data with licensed payment service providers, including operators of JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and standard bank transfer networks. These processors are contractually bound to use your data solely for payment processing and are prohibited from retaining or using it for any other purpose.

5.2 KYC Verification Providers

10wine uses third-party identity verification services to assist with the KYC process. Your identity documents and related data are shared with these providers solely for the purpose of completing identity verification checks. These providers operate under binding data processing agreements with 10wine.

5.3 Game Software Providers

The casino games and sportsbook software on 10wine are powered by licensed third-party providers. These providers may receive limited session and game data necessary for game delivery and outcome verification. They do not receive your identity or financial data unless separately required for their own regulatory compliance.

5.4 Regulatory and Law Enforcement Authorities

10wine may be required by its international gaming licence, applicable law, or a valid court order to disclose player data to regulatory bodies, law enforcement agencies, or other competent authorities. 10wine will comply with such lawful requirements and, where permitted by law, will notify affected players of such disclosure.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 10wine's business, player data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and of any material changes to this Privacy Policy that result from it.

10wine uses cookies and similar tracking technologies on the platform website to support core functionality, improve user experience, and assist with security monitoring. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function correctly. These include session authentication cookies that keep you logged in to your 10wine account during an active session, and security tokens that prevent cross-site request forgery. These cookies cannot be disabled without impairing core platform functionality.
• Functional Cookies: Store your preferences, such as preferred language and display settings, to improve your experience on return visits to 10wine.
• Analytics Cookies: Used in anonymised and aggregated form to understand how players navigate the platform, which game categories receive the most engagement, and where technical errors occur. 10wine uses this data solely for internal platform improvement and does not share analytics data in identifiable form with third parties.
• Security and Fraud Detection Cookies: Assist in identifying unusual session patterns, detecting automated bot activity, and protecting the integrity of the 10wine platform against fraud and abuse.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in to or using the 10wine platform. 10wine does not use third-party advertising or behavioural tracking cookies.

10wine retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by our international gaming licence and applicable legal obligations. The following retention periods apply:

• Active account data: Retained for the full duration of your registered account on 10wine, including all registration, KYC, transaction, and gaming activity records.
• Post-closure data: Following account closure (whether voluntary or by 10wine), we are required by our gaming licence to retain KYC documents, transaction records, and betting history for a minimum period of five years from the date of account closure, for AML, regulatory, and dispute resolution purposes.
• Customer support records: Retained for three years from the date of the last communication, unless the record relates to an ongoing dispute or regulatory matter.
• Technical and device logs: Retained for up to 12 months from the date of collection, after which they are anonymised or deleted.
• Marketing consent records: Where you have given consent to receive promotional communications, a record of that consent is retained for as long as the consent remains active and for two years thereafter.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with 10wine's internal data disposal procedures.

As a registered 10wine player, you have the following rights in relation to your personal data. These rights are subject to applicable legal and regulatory limitations, including the mandatory retention obligations described in Section 7.

• Right of Access: You have the right to request a copy of the personal data held about you by 10wine. We will respond to verified access requests within 30 days.
• Right to Rectification: If any personal data held by 10wine is inaccurate or incomplete, you have the right to request that it be corrected. Please note that corrections to KYC identity data require re-submission of updated documentation.
• Right to Erasure: In certain circumstances, you may request the deletion of your personal data. This right does not apply where 10wine is required to retain data by law or under its gaming licence obligations.
• Right to Restrict Processing: You may request that 10wine restrict the processing of your data in certain circumstances, such as where the accuracy of the data is contested, pending verification.
• Right to Object: Where processing is based on legitimate interests, you have the right to object to that processing. 10wine will cease the relevant processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

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

• SSL/TLS Encryption: All data transmitted between your device and the 10wine platform is encrypted using industry-standard SSL/TLS protocols. This applies to all login sessions, payment transactions, and personal data submissions.
• Encrypted Data Storage: Personal data, KYC documents, and financial records stored on 10wine's servers are encrypted at rest using AES-256 or equivalent encryption standards.
• Access Controls: Access to systems containing personal data is restricted to authorised 10wine personnel on a strict need-to-know basis. All staff with data access receive data protection training.
• Two-Factor Authentication: 10wine supports two-factor authentication on player accounts to reduce the risk of unauthorised account access resulting from compromised credentials.
• Intrusion Detection: 10wine's infrastructure is monitored continuously for anomalous access patterns, denial-of-service attempts, and other security threats.
• Data Breach Response: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 10wine will notify affected players without undue delay and take immediate remedial action.

Despite these measures, no internet-connected system can guarantee absolute security. Players are encouraged to use strong, unique passwords for their 10wine accounts and to enable two-factor authentication to maximise account security.

The 10wine platform is strictly intended for individuals aged 21 years and above. 10wine does not knowingly collect, process, or retain personal data from any person under the age of 21.

If 10wine becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, all associated data will be deleted, and any deposited funds will be returned to the original payment method to the extent technically possible.

Parents or guardians who believe that their child may have registered on the 10wine platform should contact us immediately at [email protected] so that the account can be closed and data deleted without delay.

The 10wine platform may contain links to third-party websites or services, including payment provider portals and game software interfaces operated by licensed providers. This Privacy Policy applies solely to personal data collected and processed by 10wine directly.

10wine is not responsible for the privacy practices of third-party websites or services accessible via links from the platform. Players are encouraged to review the privacy policies of any third-party services they access in connection with their use of 10wine.

10wine reserves the right to update or amend this Privacy Policy at any time. Material changes to data processing practices will be communicated to registered players via the email address associated with their account at least seven days prior to the changes taking effect, where reasonably practicable.

The most current version of this Privacy Policy will always be available at this URL. The "Last Updated" date at the top of this page will reflect the date of the most recent revision. Continued use of the 10wine platform following the effective date of any amendment constitutes acceptance of the updated Privacy Policy.

If you disagree with any amendment, you may request account closure by contacting our support team prior to the effective date of the change. Your personal data will continue to be retained for the mandatory periods described in Section 7 regardless of account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 10wine processes your personal data, please contact our support team through the following channel:

When contacting us regarding a data rights request, please include your registered 10wine account email address and a description of your request. We may require identity verification before processing certain requests to protect the security of your account.