Privacy Policy
Privacy Policy
| Who are we? |
| Our site www.truewin.ae (the “site”) is operated by Coin Technology Projects LLC (“we”, “us” or “our”), a limited liability company incorporated in accordance with the laws of the Emirate of Abu Dhabi, whose commercial licence number is CN-3762798 and the principal place of business is Twofour54, Yas Creative Hub, Abu Dhabi, United Arab Emirates. We use the terms “you” and “your” to mean any person accessing or using the site. The purpose of this Privacy Notice is to provide you with information about how we collect, generate, and process personal data (“Personal Data”) in connection with the site. This Privacy Notice should be read in conjunction with the TrueWin Terms and Conditions (the “TW Terms”). |
| Quick Guide to Contents |
| • What is Personal Data? • What Personal Data may we collect about you? • Do we collect Personal Data relating to minors? • How do we use your Personal Data? • How long do we keep your Personal Data for? • Whom do we share your Personal Data with? • What happens if you do not provide us with the Personal Data we request or ask that we stop processing your Personal Data? • Do we make automated decisions concerning you? • Do we use Cookies to collect Personal Data on you? • Do we transfer your Personal Data outside the UAE? • How we safeguard your Personal Data? • What are your rights? • Changes to this Privacy Notice • How will we contact you? • How can you contact us? |
| What is Personal Data? |
| Personal Data refers to any information from which it is practicable for the identity of an individual to be ascertained. |
| What Personal Data may we collect about you? |
| We collect and process your Personal Data in the following ways, depending on hwo you access or use our site and services: Personal Data you give us may include • Name • Date of birth • Photograph, facial scan or equivalent visual identification • Residential address • Email address • Passport or other government-issued identification document details, including document number and expiration date • Nationality • Telephone number • Bank account number and debit card number Personal Data we collect automatically • Any Personal Data you provide when interacting with us, including via our customer care team; • Transaction details, including a record of payments made by you and to you, details of games played by you and the outcomes of those games; • Personal Data about how you use our site and which websites you came to our site from; and • Technical data about your device or browser when you use our site, including geolocation data to determine where you access our site from, your IP address, device ID, browser type and version and time zone setting. Personal Data we receive from third parties • We may receive Personal Data about you from third parties in connection with your use of our site, participation in our games, or verification of your eligibility to play. This may include: o transaction information relating to your payments or purchases on our site; o gameplay information provided by our third-party vendors, including data on your activity and participation; o geolocation information obtained from our authorised geolocation service providers; and o identity verification and screening information obtained from third-party KYC and compliance providers. |
| Do we collect Personal Data relating to minors? |
| Protecting the safety and privacy of children is very important to us. In accordance with the TW Terms, all customers of our site must be over the age of 21. Therefore, we do not specifically request, nor should you provide, the Personal Data of minors in accordance with local legislation in force in connection with our site. |
| How do we use your Personal Data? |
| Registration • We use the Personal Data you provide to us to register you as a new player. • This is necessary for the performance of a contract with you, so that you can make deposits and we are able to pay out any winnings to you. Eligibility • We use technical Personal Data such as the location from which you access our site, the personal details you provide and any documents you have provided to check whether you are eligible to play our games. • This is necessary to comply with legal and regulatory obligations. Verification • We may require copies of documents to verify your identity or in order to comply with any request you may make regarding your account, including in relation to your claim for any winnings. • This is necessary to comply with legal and regulatory obligations, including Anti-Money Laundering and Countering the Financing of Terrorism laws. Playing our games • We use the Personal Data you provide, as well as Personal Data we collect automatically, to: o provide our games and other services to you; o manage your account; and/or o contact you to facilitate payment of your winnings. • This is necessary for the performance of a contract with you. Communicating with you • We use the Personal Data you provide, as well as Personal Data we collect automatically, to: o notify you about changes to the TW Terms and this Privacy Notice; and/or o respond to any query, request, complaint or dispute you may have. • This is necessary for the performance of a contract with you and also to comply with our legal and regulatory obligations. Marketing and analytics • We use Personal Data you provide, as well as Personal Data we collect automatically and from third parties to deliver relevant content to you, including information about games, competitions and other direct marketing to you via various mediums, such as video streaming and social media platforms. • We also use this information to optimise our services and improve our site, games, direct marketing, player relationships, behaviour profiling and experiences. • We will only send you direct marketing with your consent. Regulatory compliance • We may use Personal Data you provide, as well as Personal Data we collect automatically, to comply with our legal and regulatory obligations, which include providing a regulatory authority with standing with aggregated or individual-level data, implementing responsible gaming measures, detecting fraud, preventing unlawful activity, and to allow us to provide any information to a such authority as we are required to do. • This is necessary to comply with our legal and regulatory obligations. Responsible gaming • We may use information you provide to assess and identify any players that appear to be at risk of irresponsible gaming. We may also contact you about playing in a responsible way. • This is necessary to comply with our legal and regulatory obligations. Whenever we use Personal Data, we make sure that our usage complies with applicable laws. In particular, your Personal Data may be: • collected based on your consent; • required so that you can participate in our games in accordance with the TW Terms; • required to fulfil or comply with legal and regulatory requirements to which we are subject; • necessary for the performance of the contract incorporating the TW Terms; or • otherwise necessary for the purposes of our legitimate business interests, such as allowing us to effectively and efficiently manage and administer the operation of our site. |
| How long do we keep your Personal Data for? |
| How long we will hold your Personal Data for will vary and will be determined by the following cumulative criteria: • the purpose for which we are using it – we will need to keep your Personal Data for as long as is necessary for that purpose; and • legal obligations – applicable laws or regulations may set a minimum period for which we have to keep your Personal Data. In any case, your Personal Data will not be kept in a form that allows you to be identified for any longer than is necessary considered necessary by us. |
| Whom do we share your Personal Data with? |
| We may share your Personal Data with government regulatory authorities and entities with standing, in certain circumstances, from time to time. We have to do this by law to ensure that we adhere to our legal and regulatory obligations. We share your Personal Data with trusted third parties where we have retained them to provide services that you have requested, such as payment providers to facilitate your deposit of funds into your account. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality. We share your Personal Data with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function coordinators. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality. We share your Personal Data with our other group and affiliated entities and institutions, primarily for internal business and operational purposes, and also for marketing purposes where we have your consent. Where required we share your Personal Data with third parties to comply with legal and regulatory obligations; when an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our terms and conditions or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our site, our authorized retailers, our business or the public. |
| What happens if you do not provide us with the Data we request or ask that we stop processing your Data? |
| If you do not provide the Personal Data necessary, or withdraw your consent for the processing of your Personal Data, where this Personal Data is necessary for us to provide services or information to you, we will not be able to provide these services or information to you. |
| Do we make automated decisions concerning you? |
| We may make automated decisions in certain cases such as; • Your eligibility to open an account with us; • Your ongoing eligibility to play our games based on the information you provide to us; • Your online activities in line with Responsible Gaming; • Fraud Detection and Prevention; or • Profiling. This is necessary to comply with our legal and regulatory compliance obligations, and appropriate measures are taken to safeguard any information related to automated decisions. If you have any enquiries regarding this, you can contact us at: [email protected]. |
| Do we use Cookies to collect Personal Data on you? |
| To provide better service to you on our sites, we use cookies to collect your Personal Data when you browse. See our Cookie Policy for more details. |
| Do we transfer your Personal Data outside the UAE? |
| We are a global business and work with service providers located abroad. As a result, you acknowledge and agree that we may transfer your Personal Data to locations outside of the UAE or the country from which you access the site. Where we transfer Personal Data internationally, we will ensure that it is protected and transferred in a manner consistent with applicable legal and regulatory requirements. |
| How we safeguard your Personal Data? |
| We will take all reasonable and practicable technical and organizational measures to keep your Personal Data secure and confidential. |
| What are your rights? |
| In all the above cases in which we collect, use or store your Personal Data, you may have the following rights which you can exercise free of change. These rights include: |
| Rights | What does this mean? |
| 1. The right to be informed | You have the right to confirm that your Personal Data is being processed and to be provided with clear, transparent and easily understandable information about how we use your Personal Data and your rights. This is why we are providing you with the information in this Privacy Notice. |
| 2. The right of access | You have the right to ask us to confirm whether we process your Personal Data and obtain information regarding the processing of your Personal Data. |
| 3. The right to rectification | You are entitled to have your Personal Data corrected if it is inaccurate or incomplete. |
| 4. The right to erasure | This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. |
| 5. The right to restrict processing | You have rights to object to, or request that we restrict or suppress, use of your Personal Data including in respect of direct marketing. When processing is restricted, we can still store your Personal Data, but may not use it further. We keep lists of people who have asked for further use of their Personal Data to be ‘blocked’ to make sure the restriction is respected in future. There may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data, but we are legally entitled to refuse that request. |
| 6. The right to data portability | You have rights to obtain and reuse your Personal Data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your Personal Data which will be delivered to you in a structured, commonly used and machine-readable format. |
| 7. The right to lodge a complaint | You have the right to lodge a complaint about the way we handle or process your Personal Data with your national data protection regulator (where applicable). |
| 8. The right to withdraw consent | If you have given your consent to anything we do with your Personal Data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your Personal Data for marketing purposes. |
| Changes to this Privacy Notice | |
| We may update this Privacy Notice from time to time. Should we do so, the new terms will become effective from the moment they are uploaded onto the site. We will use reasonable efforts to notify you of any material changes to this Privacy Notice. However, you should check the Privacy Notice when you visit the site to confirm the most recent Privacy Notice that applies. | |
| How will we contact you? | |
| We may contact you by phone, email or social media. | |
| How can you contact us? | |
| If you have any enquiries about how your Personal Data is gathered, stored, shared or used or exercising any rights mentioned above, you can contact us at [email protected]. For all other enquiries, you can contact us at: [email protected]. | |
Cookies Policy
In order to make visiting our website attractive and to enable the use of certain functions, we use cookies in some areas.
What Are Cookies?
Cookies are text files containing small amounts of information, which are downloaded to your computer or mobile device by websites that you visit. They can improve your experience of using a website, for example, by remembering your preference settings and tracking your use of the website so that they can be improved to meet your needs. They can also help to ensure that adverts you see online are more relevant to you and your interests.
Categories of Cookies We Use
First Party Cookies
First-party cookies are cookies set directly by us on our website. These cookies are essential for the core functionality of our site and are also used to improve user experience, enable specific features, and analyze how users interact with our services.
First-party cookies are only accessible by us and cannot be read or used by external websites.
Third Party Cookies
Some cookies on our website are set by third parties to provide additional services (e.g., video playback or social media integration). These third parties may collect data about your browsing behavior across different websites. For example, to enable us to have YouTube videos played through our website, YouTube places cookies on our website.
Third-party cookies are controlled by the third parties that set them. You can find more about their practices by visiting their respective privacy and cookie policies.
Persistent Cookies
These remain on your device between browsing sessions. They are activated each time you visit the Website that created that particular cookie. For example, where a "persistent cookie" is used on a Website to remember your log-in details, you will not need to enter those details each time you visit that Website.
Session Cookies
These allow website operators to link the actions of a user during a browser session. A browser session starts when you open the browser window and finishes when you close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
The table below shows what cookies we use on our website, why we use them and the cookie type.
| Cookie Type | Cookies | Purpose | Persistent/ Session | Cookie Used |
| Strictly Necessary | session id, cookie_consent | Enables core functions such as page navigation, login and security. This covers login session and fraud prevention. | Persistent | First-party |
| Performance/ Analytics | ga,_gid,_gat | Collects anonymized statistics to help improve site performance. This covers page visits, error logs. | Persistent | First-party / Third-party (eg Google Analytics) |
| Functionality | lang_pref, remember_me | Remembers your preferences. This covers language, region and user settings. | Persistent | First-party |
| Targeting/ Advertising | _fbp,_gcl,_au,IDE | Tracks browsing behaviour to deliver relevant ads across websites. | Persistent | Third-party (eg Meta, Google Ads, You Tube) |
How to Manage Your Cookies
You can manage or delete these cookies except strictly necessary ones. You can do so at any time through adjusting your browser settings. Although, please remember that blocking some types of cookies may impact your experience on our website. For example, you will not be able to watch videos on our website or stay logged in.
Browser Controls
Each browser gives you tools to manage cookies. Use the links below for guidance:
• Google Chrome: https://support.google.com/chrome/answer/95647
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies
• Safari: https://support.apple.com/en-us/HT201265
• Microsoft Edge: https://support.microsoft.com/en-us/help/4027947
Updates to This Policy
We may update this Cookie Policy from time to time. Please revisit this page periodically to stay informed.
For more information about how we handle your personal data, please refer to our Privacy Notice.