1wine Privacy Policy

1. Data We Collect

1wine collects personal data that is necessary for the provision of a safe, compliant, and functional online gaming service. We do not collect personal data beyond what is required for these purposes. The categories of data we collect are set out below.

1.1 Registration Data

When you create a 1wine account, we collect the information you provide during the registration process. This includes your full legal name, date of birth, email address, mobile phone number, and the username and password you choose. This data is mandatory — without it, we are unable to create or maintain your account.

1.2 Identity Verification Data

As part of our Know Your Customer (KYC) and anti-money laundering (AML) obligations, we may request copies of government-issued identification documents such as your National Identity Card (NID), passport, or birth certificate. Where proof of address is required, we may also request a recent utility bill, bank statement, or other document bearing your name and residential address. These documents are processed securely and retained only for the period required by our compliance obligations.

1.3 Financial Transaction Data

We collect records of all financial transactions conducted through your 1wine account, including deposits and withdrawals. This includes the payment method used (e.g., bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank), the transaction amount in Bangladeshi Taka (৳), the timestamp, and a transaction reference number. We do not store full payment card numbers on our servers — card data is handled exclusively by our certified payment gateway partners.

1.4 Gaming Activity Data

We record your gaming activity on the 1wine platform, including the games you play, the bets you place, the outcomes of those bets, bonus usage history, and session duration. This data is used for account integrity, responsible gaming monitoring, dispute resolution, and regulatory reporting where required.

1.5 Technical and Device Data

When you access the 1wine platform, our servers automatically collect certain technical information. This includes your IP address, browser type and version, operating system, device type, screen resolution, referring URL, and pages visited within the platform. This data helps us detect fraud, ensure platform security, and improve the user experience.

1.6 Communications Data

If you contact our support team by email or live chat, we retain a record of that correspondence, including the content of your messages and any attachments. This data is used to resolve your query, improve our support processes, and maintain an audit trail for compliance purposes.

2. How We Use Your Data

1wine uses the personal data it collects for clearly defined, lawful purposes. We do not sell your personal data to third parties, and we do not use it for purposes unrelated to the delivery and improvement of our gaming service. The table below summarises our primary data processing activities and the legal basis for each.

Where we rely on your consent as the legal basis for processing — most notably for direct marketing communications — you retain the right to withdraw that consent at any time by contacting us at [email protected] or by using the unsubscribe link in any marketing email we send. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

3. Data Sharing & Disclosure

1wine does not sell, rent, or trade your personal data with any third party for commercial gain. We do, however, share certain categories of personal data with trusted third-party service providers and, where legally required, with regulatory or law enforcement bodies. All third parties with whom we share data are bound by contractual confidentiality obligations.

3.1 Payment Service Providers

To process your deposits and withdrawals, we share necessary transaction data with our payment partners, which include mobile financial service providers (bKash, Nagad, Rocket, Upay) and card networks (Visa, Mastercard) operating through certified payment gateways. These providers receive only the data required to execute the specific transaction and are prohibited from using it for any other purpose.

3.2 Identity Verification Partners

We may engage specialist third-party KYC and AML service providers to assist with identity verification. These providers process your submitted documents in a secure environment and return a verification result to 1wine. They do not retain your documents beyond the period required to complete the verification check, in accordance with their own privacy obligations.

3.3 Technology and Infrastructure Providers

1wine uses third-party cloud infrastructure, data hosting, and cybersecurity service providers to operate the platform. These providers may process your data solely in the course of delivering the contracted services to 1wine and are not permitted to access or use your data for independent purposes.

3.4 Legal and Regulatory Disclosure

We may be required to disclose your personal data to government authorities, law enforcement agencies, or regulatory bodies when required to do so by applicable law, court order, or regulatory directive. In such circumstances, we will disclose only the minimum data necessary to fulfil the legal obligation. Where permitted by law, we will attempt to notify you of any such disclosure in advance.

4. Cookies & Tracking Technologies

The 1wine platform uses cookies and similar tracking technologies to deliver a functional, secure, and personalised user experience. A cookie is a small text file placed on your device by the platform when you visit. Cookies cannot execute code or carry viruses; they are used solely for the purposes described below.

4.1 Types of Cookies We Use

• Strictly necessary cookies: These are essential for the platform to function. They manage your login session, maintain your account state across pages, and support security features such as CSRF protection. These cookies cannot be disabled without breaking core platform functionality.
• Functional cookies: These remember your preferences — such as your preferred language or display settings — to provide a consistent experience across sessions. They do not track you across other websites.
• Analytics cookies: These help us understand how users navigate the platform, which pages are most visited, and where errors or drop-off points occur. Analytics data is processed in aggregated, anonymised form and is used solely to improve the platform.
• Security cookies: These are used to detect suspicious login attempts, enforce rate-limiting on sensitive actions, and support our fraud prevention systems. They operate in the background and are not used to profile users for marketing purposes.

4.2 Managing Your Cookie Preferences

You may configure your browser to refuse non-essential cookies or to alert you before a cookie is set. The method for managing cookies varies by browser; consult your browser's help documentation for specific instructions. Please note that disabling strictly necessary cookies will prevent you from logging in to your 1wine account and using core platform features. 1wine does not use third-party advertising or retargeting cookies.

5. Data Retention

1wine retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to any longer retention requirements imposed by applicable law or regulation. The following retention periods apply as a general guide:

• Account and registration data: Retained for the lifetime of the account and for a period of 5 years following permanent account closure, to support compliance with anti-money laundering and financial crime prevention obligations.
• Identity verification documents: Retained for 5 years from the date of submission or from the date of account closure, whichever is later.
• Financial transaction records: Retained for 5 years from the date of each transaction in accordance with financial record-keeping requirements.
• Gaming activity logs: Retained for 3 years from the date of activity. Aggregated, anonymised gaming data may be retained indefinitely for analytics and responsible gaming research purposes.
• Customer support correspondence: Retained for 2 years from the date of the last message in each support thread, unless the correspondence forms part of a dispute or legal proceeding — in which case it is retained until final resolution.
• Marketing consent records: Retained for as long as you remain an opted-in marketing recipient, plus 1 year following opt-out to provide an audit trail of your consent preferences.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data lifecycle management procedures. Where anonymisation is used rather than deletion, the resulting data cannot reasonably be re-linked to any individual and is no longer considered personal data for the purposes of this policy.

6. Your Privacy Rights

As a user of the 1wine platform, you hold a number of rights with respect to your personal data. We are committed to honouring these rights promptly and without unnecessary complexity. The following rights are available to all 1wine users:

• Right of access: You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used format within 30 days of receiving a valid 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 it. Where the data in question affects your account status or verification, we may require supporting documentation before making changes.
• Right to erasure: 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 withdraw consent, or where you object to processing. This right is subject to override by legal retention obligations — we cannot erase data that we are legally required to retain.
• Right to restrict processing: You may request that we pause processing of your data in certain circumstances — for example, while a rectification request is being investigated.
• Right to data portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request that we provide your data in a machine-readable format suitable for transfer to another service provider.
• Right to object: Where we process your data on the basis of legitimate interest — such as for analytics or fraud prevention — you have the right to object. We will honour your objection unless we can demonstrate a compelling legitimate ground that overrides your interest.
• Right to withdraw marketing consent: You may opt out of receiving marketing communications from 1wine at any time by contacting [email protected]. Opt-out requests are processed within 5 business days.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Privacy Rights Request". We will acknowledge receipt within 2 business days and aim to fulfil the request within 30 days. For complex or high-volume requests, we may extend this period by a further 30 days and will notify you of any such extension in advance.

7. Data Security

1wine employs a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include, but are not limited to, the following:

• Transport layer encryption: All data transmitted between your browser or app and our servers is protected by 256-bit TLS/SSL encryption. You can verify this by the padlock icon and "https://" prefix in your browser's address bar when visiting 1wine.app.
• Data encryption at rest: Sensitive personal data stored in our databases — including identity documents and financial records — is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to personal data within our internal systems is restricted on a strict need-to-know basis. Staff members are granted the minimum level of access required to perform their job function. All access events are logged and audited regularly.
• Password hashing: Account passwords are never stored in plain text. They are processed through a one-way cryptographic hash function before storage, meaning that even in the event of a data breach, passwords cannot be recovered in their original form.
• Intrusion detection: Our infrastructure is monitored continuously for signs of unauthorised access, unusual traffic patterns, or other indicators of compromise. Automated alerts and a trained security response team are in place to respond to any detected threats.
• Penetration testing: We commission independent security assessments of our platform on a regular basis to identify and address vulnerabilities before they can be exploited.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. If you have reason to believe that your account has been compromised or that your data has been accessed without your authorisation, please contact us immediately at [email protected] so that we can take prompt remedial action.

8. Policy Updates & Contact

1wine reserves the right to update or revise this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable law, or enhancements to our platform. When material changes are made, we will notify registered users by email and by an in-platform notification displayed at next login. The effective date at the top of this document will be updated to reflect the date of the most recent revision.

We encourage you to review this Privacy Policy periodically. Your continued use of the 1wine platform following notification of any changes constitutes your acceptance of the updated policy. If you do not agree with the changes, you should contact us to discuss your options, which may include requesting account closure.

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, please contact the 1wine data team using the details below. We take all privacy-related correspondence seriously and commit to providing a substantive response within 5 business days.