Privacy Policy — How jtwin Handles Your Data

1. Introduction

jtwin is an internationally licensed online betting and casino platform that serves the Bangladesh market. We are committed to handling the personal data of our players, visitors, and prospective customers with care, transparency, and integrity. This Privacy Policy is intended to give you a clear and complete picture of our data practices so that you can make informed decisions about your use of the Platform.

This Policy applies to all personal data processed by jtwin in connection with:

• Your registration and use of a jtwin account;
• Your visits to the jtwin website at https://jtwin.io, including any mobile-optimised version;
• Any communications you have with our customer support team;
• Your participation in promotions, tournaments, or surveys hosted by jtwin;
• Your use of payment services connected to the jtwin Platform.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are available on this website. In the event of any conflict between this Privacy Policy and another document on the Platform, this Privacy Policy shall prevail with respect to the processing of personal data.

2. Personal Data We Collect

The categories of personal data that jtwin may collect about you include, but are not limited to, the following:

2.1 Identity Data

Your full legal name, date of birth, gender, nationality, and a copy of your government-issued identification document (National Identity Card, passport, or driving licence). This data is collected to fulfil our Know Your Customer (KYC) obligations and to verify that you meet the minimum age requirement of 21 years.

2.2 Contact Data

Your email address, mobile phone number, and residential address. This data is used to communicate with you about your account, process transactions, and deliver promotional communications where you have consented to receive them.

2.3 Financial Data

Details of the payment methods you use to deposit and withdraw funds, including your bKash, Nagad, Rocket, or Upay account number or mobile number (as applicable). We do not store full card numbers or banking PINs. Payment processing is handled by certified third-party payment processors who operate under their own privacy policies.

2.4 Transaction Data

Records of all deposits, withdrawals, bonuses claimed, bets placed, games played, and winnings received on your jtwin account, including timestamps and amounts in Bangladeshi Taka (৳).

2.5 Technical Data

Your IP address, device type, operating system, browser type and version, screen resolution, time zone, and connection type. This data is collected automatically when you access the Platform and is used for security monitoring, fraud detection, and platform optimisation.

2.6 Usage Data

Information about how you navigate and interact with the Platform, including pages visited, session duration, click patterns, game preferences, search queries made within the Platform, and features used. This data is analysed in aggregate to improve the Platform's user experience.

2.7 Communications Data

Records of your correspondence with our customer support team, including live chat transcripts, emails, and any attachments or screenshots you submit as part of a support request or dispute.

2.8 Responsible Gaming Data

Records of any responsible gaming tools you have activated on your account, including deposit limits, cooling-off periods, session time settings, and self-exclusion requests. This data is retained to ensure that your chosen restrictions remain enforced even if you contact us to request their modification.

3. How We Collect Your Data

jtwin collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in a promotion, or update your account profile;
• Automatically: Through cookies, web beacons, server logs, and other tracking technologies when you access or use the Platform (see Section 8);
• From third parties: From KYC verification service providers, payment processors (bKash, Nagad, Rocket, Upay), fraud prevention services, and, where applicable, publicly available sources such as sanctions lists and politically exposed persons (PEP) databases.

4. Purpose and Legal Basis for Processing

The table below summarises the main purposes for which jtwin processes your personal data, together with the legal basis on which that processing rests:

5. Data Sharing and Disclosure

jtwin does not sell, rent, or commercially exploit your personal data. We share your data only in the following limited circumstances:

5.1 Service Providers

We engage carefully selected third-party service providers to assist in delivering the jtwin Platform. These include KYC verification partners, payment processors (bKash, Nagad, Rocket, Upay), IT infrastructure and cloud hosting providers, customer support platform vendors, and fraud detection services. All such providers are bound by contractual data processing agreements that restrict them to processing your data only on jtwin's documented instructions and only for the purposes we specify.

5.2 Game Content Providers

The casino and sports games available on the jtwin Platform are supplied by third-party game studios including Pragmatic Play, Evolution Gaming, Spribe, Ezugi, Microgaming, and NetEnt. These providers may receive limited technical data (such as a pseudonymous player session token) in order to deliver game content. They do not receive your full name, contact details, or payment information.

5.3 Legal and Regulatory Disclosure

We may disclose your personal data to law enforcement agencies, regulatory authorities, courts, or other government bodies where we are required to do so by applicable law, a court order, or to defend jtwin's legal rights. In such cases, we will disclose only the minimum data necessary to satisfy the legal requirement.

5.4 Business Transfers

In the event that jtwin undergoes a merger, acquisition, restructuring, or sale of all or part of its business assets, your personal data may be transferred to the relevant acquiring entity as part of that transaction. You will be notified by email if such a transfer affects the processing of your data in a material way.

6. International Data Transfers

jtwin operates as an internationally licensed platform, and some of our service providers and infrastructure may be located outside Bangladesh. As a result, your personal data may be transferred to and processed in countries other than the country in which you are resident.

Where such transfers occur, jtwin takes steps to ensure that your data receives an equivalent level of protection to that which applies under applicable data protection standards. These steps may include entering into contractual clauses with the relevant service provider that require them to protect your data to the same standard we apply, or relying on the service provider's certification under an internationally recognised data protection framework.

7. Data Retention

jtwin retains your personal data 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:

• Account and KYC data: Retained for a minimum of five (5) years following account closure to satisfy financial record-keeping and anti-money laundering obligations;
• Transaction records: Retained for a minimum of five (5) years following the date of the transaction;
• Customer support records: Retained for three (3) years following the closure of the relevant support ticket or dispute;
• Marketing consent records: Retained for the duration of your account plus three (3) years following account closure, to demonstrate proof of consent in the event of a regulatory inquiry;
• Technical and usage data (logs): Retained for up to twelve (12) months, after which they are deleted or anonymised;
• Self-exclusion records: Retained indefinitely to ensure that self-exclusion decisions remain enforceable and are not inadvertently overridden.

When the applicable retention period expires, personal data is either securely deleted from our systems or anonymised so that it can no longer be linked to any identifiable individual. Anonymised, aggregate data may be retained indefinitely for statistical and analytical purposes.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They allow the website to recognise your device on subsequent visits, remember your preferences, and collect information about how you use the site. The jtwin Platform uses cookies and similar technologies including web beacons and local storage objects.

8.2 Types of Cookies We Use

• Essential Cookies: These are strictly necessary for the Platform to function. They maintain your login session, remember your language and currency preferences, and protect against cross-site request forgery (CSRF) attacks. You cannot opt out of essential cookies without also being unable to use the Platform.
• Analytical Cookies: These cookies collect anonymous, aggregate information about how visitors use the Platform — such as which pages are visited most frequently and whether users encounter error messages. This data is used solely to improve the Platform's performance and usability.
• Functional Cookies: These cookies allow the Platform to remember choices you have made (such as your preferred game lobby layout or notification settings) and provide enhanced, more personalised features.

jtwin does not use third-party advertising cookies, retargeting cookies, or any tracking technology that follows your activity outside of the jtwin Platform.

8.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can typically choose to block all cookies, accept only certain types of cookies, or delete cookies that have already been set. Please note that blocking essential cookies will prevent you from logging in to your jtwin account. Instructions for managing cookies in the most common browsers are available on the browser developer's support pages.

9. Security Measures

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

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records;
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent required by their role;
• Regular penetration testing and vulnerability assessments conducted by independent security specialists;
• Multi-factor authentication requirements for all staff with access to systems containing personal data;
• Automated fraud detection and anomaly monitoring systems that flag unusual account activity in real time;
• Comprehensive data breach response procedures, including notification protocols.

While we take every reasonable precaution to protect your data, no internet-based system can be guaranteed to be completely secure. You are responsible for keeping your jtwin login credentials confidential and for ensuring that your own device and network are adequately secured.

10. Your Data Rights

Subject to applicable data protection law, you may have the following rights in relation to the personal data jtwin holds about you:

• Right of Access: You may request a copy of the personal data we hold about you at any time. We will respond to verified access requests within 30 days.
• 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. You may update certain profile information directly within your account settings without contacting us.
• Right to Erasure: In certain circumstances — for example, where we no longer need your data for the purpose it was collected and no legal retention obligation applies — you may request that we delete your personal data. Please note that we cannot delete data we are legally required to retain (e.g., financial transaction records).
• Right to Restrict Processing: You may request that we temporarily stop processing your data while a rectification or objection request is being assessed.
• Right to Data Portability: Where processing is based on your consent or on a contract, you may request that we provide your personal data in a structured, machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including profiling for marketing purposes. If you object to marketing communications, we will stop sending them immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request" and provide sufficient information to verify your identity. We will respond within 30 calendar days. We do not charge a fee for processing legitimate data rights requests.

11. Children and Minors

The jtwin Platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from any individual under the age of 21. If we become aware that we have inadvertently collected data from a person under 21, we will immediately close the relevant account, void any transactions associated with it, and delete the data from our systems.

If you are a parent or guardian and believe that a person under 21 in your care has registered a jtwin account, please contact us immediately at [email protected]. We will treat such reports as urgent and investigate within 24 hours of receipt.

12. Third-Party Links

The jtwin Platform may from time to time contain references to third-party services such as payment providers (bKash, Nagad, Rocket, Upay). If you follow a link to a third-party website or application, please note that those platforms have their own privacy policies, which govern how they handle your data. jtwin accepts no responsibility for the privacy practices of third-party platforms and recommends that you review the relevant privacy policy before providing any personal data to a third-party service.

13. Updates to This Privacy Policy

jtwin reserves the right to update or revise this Privacy Policy at any time in response to changes in applicable law, our data processing practices, or the services we offer. When a material change is made, we will notify registered players by email at the address on file at least 7 days before the updated policy takes effect.

The date of the most recent update to this Privacy Policy is shown at the top of this page. We encourage you to review this page periodically. Your continued use of the Platform after any update takes effect constitutes your acceptance of the revised Privacy Policy.

14. Contact and Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way jtwin handles your personal data, please contact our Data Privacy team using the following details:

• Email: [email protected]
• Subject Line: Privacy Policy Enquiry
• Response Time: We aim to respond to all privacy-related enquiries within 5 business days (Bangladesh Standard Time, UTC+6)

If you are not satisfied with our response to your complaint, you have the right to escalate your concern to the relevant data protection authority in your jurisdiction. We will cooperate fully with any such authority in the investigation of a complaint.