10wen
Privacy Policy

This Privacy Policy ("Policy") is published by 10wen ("10wen", "we", "us", "our"), the operator of the online gaming platform accessible at 10wen.org and all associated subdomains, mobile interfaces, and digital touchpoints (collectively, the "Platform"). This Policy governs the collection, use, disclosure, retention, and protection of personal data relating to all users of the Platform ("User", "you", "your").

This Policy applies to all personal data processed by 10wen in connection with your use of the Platform, regardless of how you access it — whether via desktop browser, mobile browser, or any other interface. It applies to registered account holders, guest visitors, and any individual whose data 10wen processes in the course of operating the Platform.

This Policy was last updated on 1 January 2026. 10wen reviews this Policy periodically and will update it to reflect changes in data practices, regulatory requirements, or platform features.

For the purposes of this Privacy Policy, the data controller responsible for your personal data is 10wen, the licensed operator of the Platform. As data controller, 10wen determines the purposes for which and the manner in which personal data is processed.

All data protection enquiries, rights requests, and privacy complaints should be addressed to the 10wen Data Protection contact as set out in Section 16 of this Policy. 10wen is committed to responding to all legitimate data enquiries promptly and in accordance with applicable data protection obligations.

10wen collects the following categories of personal data in connection with the operation of the Platform. The specific data collected may vary depending on the products and features you use:

10wen does not collect special categories of sensitive personal data — such as health information, religious beliefs, or biometric data — except where a liveness selfie is required for KYC fraud prevention purposes. Such data is processed by our certified KYC partner and is not retained beyond the verification process.

10wen collects personal data through the following channels and mechanisms:

• Direct submission: Data you actively provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or filling in any form on the Platform.
• Automated technical collection: Data gathered automatically when you visit the Platform — including your IP address, device identifiers, browser type, operating system, referral URL, and page interaction data — via server logs, cookies, and tracking technologies.
• Payment processor data: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment providers when you make deposits or withdrawals.
• KYC verification partners: Identity verification results, document authenticity scores, and liveness check outcomes received from our certified third-party KYC service providers.
• Fraud prevention services: Risk scores and device reputation signals received from third-party fraud prevention services used to protect the integrity of the Platform.
• Responsible gaming data: Data generated when you interact with responsible gaming tools — including limit-setting events, self-exclusion requests, and session time configurations.

10wen processes your personal data on the following legal bases:

• Contract performance: Processing necessary to fulfil our obligations to you under the Terms & Conditions — including account creation, payment processing, game provision, and withdrawal facilitation.
• Legal obligation: Processing required to comply with applicable laws and regulations — including Anti-Money Laundering (AML) compliance, KYC identity verification requirements, tax reporting obligations, and responses to lawful regulatory or law enforcement requests.
• Legitimate interests: Processing necessary for 10wen's legitimate business interests — including fraud detection and prevention, platform security, responsible gaming monitoring, customer support quality improvement, and internal analytics — provided such interests are not overridden by your privacy rights.
• Consent: Processing for which you have given us your explicit, freely given, and withdrawable consent — including the sending of marketing communications and the use of non-essential cookies. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

10wen uses the personal data it collects for the following specific purposes, all of which are necessary for the operation of a responsible, licensed online gaming platform serving Pakistani users:

• Account creation and management: Establishing, maintaining, and administering your 10wen account, including password recovery, session management, and account preference storage.
• Identity verification (KYC): Verifying your identity using CNIC documentation and, where required, liveness checks, to comply with our licensing obligations and prevent underage gambling and fraud.
• Payment processing: Processing your JazzCash, EasyPaisa, or bank transfer deposits and withdrawals, maintaining transaction records, and resolving payment disputes.
• Gaming operations: Delivering casino games, sports betting markets, jackpot products (including Ultra Treasure), and live dealer services to your account, and maintaining your game and transaction history.
• Fraud detection and prevention: Identifying and investigating fraudulent activity, multiple account creation, money laundering indicators, bonus abuse, and any other conduct prohibited under our Terms & Conditions.
• Responsible gaming: Monitoring gaming patterns for indicators of problem gambling, enforcing self-exclusions and deposit limits, sending responsible gaming alerts, and maintaining cooling-off periods.
• Regulatory compliance: Maintaining records required by our gaming licence, responding to requests from competent regulatory and law enforcement authorities, and fulfilling AML reporting obligations.
• Customer support: Responding to your enquiries, resolving disputes, providing technical assistance, and maintaining records of support interactions for quality and training purposes.
• Platform improvement: Analysing aggregated, anonymised usage data to identify technical issues, improve user experience, optimise performance on Pakistani mobile networks, and develop new product features.
• Marketing communications: Sending you promotional offers, bonus notifications, and news about 10wen — subject to your consent and in accordance with Section 14 of this Policy.

10wen does not sell your personal data to third parties. We share personal data only with the following carefully selected third-party categories, and only to the extent necessary for the stated purpose:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment infrastructure providers receive transaction data necessary to process your deposits and withdrawals.
• KYC verification providers: Our certified identity verification partner receives your CNIC images and, where applicable, liveness selfie data to complete the KYC process. This partner is contractually bound to handle your data securely and exclusively for verification purposes.
• Game software providers: The 50+ licensed game providers whose titles appear on the 10wen Platform may receive your account identifier and session data necessary to deliver gameplay. Individual player identity is not shared with game providers beyond what is operationally required.
• Fraud and security services: Third-party fraud detection and device reputation services receive anonymised or pseudonymised technical data to generate risk assessments that protect the Platform and its users.
• Regulatory and law enforcement authorities: Where required by our gaming licence or compelled by applicable law, 10wen discloses personal data to regulatory bodies, law enforcement agencies, financial intelligence units, and courts of competent jurisdiction.
• IT and cloud infrastructure providers: Our hosting, database, and IT security service providers process data on our behalf under strict data processing agreements requiring them to maintain confidentiality and implement appropriate security measures.

10wen uses cookies and similar tracking technologies (collectively, "Cookies") on the Platform. Cookies are small text files placed on your device when you visit the Platform. They serve a range of purposes — from making the Platform function correctly to helping us understand how it is used.

The following categories of Cookies are used on the 10wen Platform:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged into your 10wen account, security cookies that prevent CSRF attacks, and cookies that remember your language and display preferences. These cannot be disabled without breaking core Platform functionality.
• Performance and Analytics Cookies: Collect anonymised data about how users navigate the Platform — which pages are visited most, where users encounter errors, and how sessions flow. This data is used exclusively for Platform improvement. These Cookies are activated only with your consent.
• Fraud Prevention Cookies: Device fingerprinting and session consistency cookies used to detect multiple accounts, bot activity, and fraudulent login attempts. These serve a legitimate security function and are considered necessary under our AML obligations.
• Marketing Cookies: Used to identify you across sessions and, where applicable, across partner platforms, for the purpose of delivering relevant promotional communications about 10wen. Activated only with your explicit consent. You may withdraw consent at any time via your account settings.

You can control Cookie preferences through your browser settings. Note that disabling certain Cookies — particularly strictly necessary ones — may impair your ability to use the Platform correctly, including logging in to your 10wen account.

10wen implements and maintains a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• Encryption at rest: All personal data stored in 10wen databases is encrypted using AES-256 symmetric encryption. Encryption keys are stored separately from encrypted data and are rotated on a regular schedule.
• Encryption in transit: All data transmitted between your device and the 10wen Platform is protected by TLS 1.3. HTTP connections are automatically redirected to HTTPS. Our SSL certificate chain is maintained with a current, valid certificate from a trusted Certificate Authority.
• Access controls: Role-based access control (RBAC) restricts employee access to personal data based on job function. All access is logged and audited. Access privileges are reviewed quarterly. Departing employees have their access revoked within 24 hours.
• Penetration testing: The Platform undergoes regular independent penetration testing by certified cybersecurity professionals. Identified vulnerabilities are remediated within defined SLAs based on severity classification.
• Incident response: 10wen maintains a documented Data Breach Response Plan. In the event of a personal data breach meeting the notification threshold, affected users and relevant regulatory authorities will be notified within the legally required timeframe.
• Two-factor authentication: 10wen offers and strongly encourages 2FA on all user accounts as an additional layer of protection for your personal data and your PKR wallet balance.

10wen retains personal data only for as long as is necessary for the purposes for which it was collected and to comply with applicable legal obligations. The following general retention periods apply:

Upon the expiry of the applicable retention period, personal data is permanently deleted from all 10wen production systems and backup stores. Where data cannot be immediately deleted due to technical constraints in backup systems, it is isolated, access-restricted, and scheduled for deletion at the next available backup cycle.

You hold the following rights in relation to your personal data held by 10wen. All rights can be exercised by contacting us at the details provided in Section 16. We will respond to all valid rights requests within 30 days:

The 10wen Platform is strictly intended for adults aged 18 years and above. 10wen does not knowingly collect personal data from any individual under the age of 18. If we become aware that we have collected personal data from an individual under 18 — whether through a registration attempt, a payment, or any other means — we will immediately suspend the associated account, delete all personal data relating to the underage individual, and return any deposited funds in accordance with our safeguarding obligations.

The 10wen Platform primarily serves users in Pakistan. However, some of the third-party service providers used by 10wen — including cloud infrastructure providers, KYC verification services, and game software providers — may be located in, or process data in, jurisdictions outside Pakistan.

Where personal data is transferred to a third country, 10wen ensures that appropriate safeguards are in place to protect it, including:

• Contractual protections via Data Processing Agreements that impose data protection obligations equivalent to those applied by 10wen.
• Transfer to jurisdictions that provide an adequate level of data protection as recognised by relevant regulatory standards.
• Implementation of technical safeguards — including end-to-end encryption — that protect data during international transit.

With your consent, 10wen may send you promotional communications via email and SMS, including information about bonuses, promotions, new game launches, PSL betting offers, jackpot events, and other 10wen Platform features. Marketing communications will only be sent where you have given explicit consent during registration or at a subsequent point.

You may withdraw your consent to receive marketing communications at any time:

• Via your 10wen account settings — Communication Preferences panel.
• By clicking the unsubscribe link in any marketing email from 10wen.
• By contacting our support team at [email protected] with the subject line "Marketing Opt-Out".

Withdrawal of marketing consent will take effect within 5 business days. Note that withdrawal of marketing consent does not affect your receipt of transactional or account-related communications — including deposit confirmations, withdrawal notifications, responsible gaming alerts, and security notifications — which are sent on the basis of contract performance or legal obligation and cannot be opted out of while you hold an active account.

10wen reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, Platform features, legal obligations, or regulatory requirements. The date of the most recent revision is always displayed at the top of this Policy.

Where material changes are made to this Policy — particularly changes that affect the rights of registered users or the categories of data collected — 10wen will provide advance notice via email or an in-Platform notification at least 14 days before the revised Policy takes effect. Your continued use of the Platform following the effective date of a revised Policy constitutes your acceptance of the updated terms.

We recommend that you review this Privacy Policy periodically. Previous versions of this Policy are available on request by contacting our support team.

For any questions about this Privacy Policy, to exercise any of your data rights, or to raise a concern about 10wen's data practices, please contact our Data Protection team:

If you are not satisfied with 10wen's response to a privacy complaint, you have the right to escalate the matter to the data protection supervisory authority in the applicable jurisdiction, or to the regulatory body under which 10wen holds its gaming licence. Details of the applicable authority are available upon request from the contact above.

This Privacy Policy was last reviewed and updated on 1 January 2026. All prior versions are superseded by this document. 10wen reserves all rights not expressly granted herein.