Privacy Policy

Introduction

This Privacy Policy ("Policy") is published by w665 ("w665", "we", "us", "our"), the operator of the online gaming information platform accessible at https://w665.cam ("Platform", "Website"). This Policy applies to all Users who access or interact with the Platform, whether from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar or anywhere else in the world.

We are committed to protecting the privacy and personal data of everyone who uses w665. This Policy describes the categories of personal data we collect, the purposes for which that data is processed, the legal bases on which we rely, the parties with whom we may share data, and the rights that Users hold in respect of their personal information.

This Policy must be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference. By using the w665 Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you should discontinue use of the Platform immediately.

Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — Any information that directly or indirectly identifies a living individual, including name, email address, phone number, device identifiers, IP address, CNIC number and payment account references.
• "Processing" — Any operation or set of operations performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transmission, deletion or destruction.
• "Data Controller" — The entity that determines the purposes and means by which Personal Data is processed. For this Platform, the Data Controller is w665.
• "Data Processor" — A third party that processes Personal Data on behalf of w665, subject to our written instructions and obligations.
• "User" / "you" — Any individual who accesses, browses or registers on the w665 Platform.
• "Consent" — A freely given, specific, informed and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• "KYC" — Know Your Customer: the identity and document verification process applied to registered Users before certain account features are activated.
• "Cookie" — A small text file placed on your device by the Platform to store session or preference information, as further described in Section 5 of this Policy.
• "Third Party" — Any person or entity that is not w665 or the User, including payment processors, analytics providers, fraud-prevention services and regulatory authorities.
• "Sensitive Data" — A subset of Personal Data warranting higher protection, including financial account details, government-issued identity document numbers (e.g., CNIC, passport) and health-related information submitted in connection with responsible gambling self-exclusion requests.

Data We Collect

w665 collects Personal Data through a variety of means: directly from you when you register or interact with the Platform, automatically through your use of the website, and occasionally from third-party sources such as payment processors or fraud-prevention partners. The categories of data we collect are as follows:

3.1 Data You Provide Directly

• Registration Data: Full name, date of birth, residential address (including city and country), email address, phone number and chosen username and password.
• Identity Verification (KYC) Data: Copies or images of government-issued identity documents such as your National Identity Card (CNIC), passport or driving licence; proof of residential address; and, where required, selfie or biometric verification images.
• Payment Data: Payment method details necessary to process deposits and withdrawals. This may include mobile wallet account references (for services such as Easypaisa or JazzCash — noted as familiar Pakistani payment options for context only), bank account identifiers (for HBL, UBL, Meezan Bank, Bank Alfalah or Raast transfers) and card details where applicable. Full card numbers are not stored by w665; they are processed by our regulated payment processor.
• Communications Data: The content of messages, support tickets, live chat transcripts, emails and feedback submissions you send to w665.
• Responsible Gambling Data: Information you provide when setting deposit limits, loss limits, time limits or self-exclusion requests, including any health or personal context you voluntarily share in that process.

3.2 Data Collected Automatically

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, time zone and language settings.
• Usage Data: Pages visited, features accessed, time spent on pages, click patterns, search queries entered within the Platform, and game or betting activity logs.
• Session Data: Login timestamps, session duration, logout events and authentication status.
• Cookie & Tracking Data: Information collected via cookies, web beacons and similar tracking technologies as described in Section 5.

3.3 Data Received from Third Parties

• Fraud & Risk Data: Risk scores, fraud flags or identity verification outcomes provided by third-party KYC and anti-fraud service providers.
• Payment Processor Data: Transaction confirmations, payment status updates and chargeback notifications from our regulated payment processing partners.
• Responsible Gambling Databases: Where permitted by applicable law and within the scope of our licence obligations, information confirming whether a User appears on a self-exclusion register or responsible gambling restriction list.

Data Processing & Legal Basis

w665 processes your Personal Data only where a valid legal basis exists for doing so. The following table sets out the primary purposes for which we process data and the legal basis on which each processing activity rests:

Where we rely on legitimate interests as our legal basis, we have assessed that our interests do not override your fundamental privacy rights, taking into account the nature of the data processed and the reasonable expectations of Users. Where we rely on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Cookies & Tracking Technologies

w665 uses cookies and similar tracking technologies to operate the Platform effectively, recognise returning Users, maintain session state and gather analytics data that helps us improve the user experience. A cookie is a small text file stored on your device by your web browser when you visit the Platform.

We use the following categories of cookies:

• Essential Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens, security cookies and load-balancing cookies. They cannot be disabled without breaking core Platform functionality.
• Analytics Performance & Analytics Cookies: Used to measure how Users interact with the Platform — which pages are visited most, where Users drop off in a journey, and how long sessions last. Data collected through these cookies is aggregated and anonymised wherever possible. These cookies are set only with your consent where required by applicable law.
• Functional Functional Cookies: Store your preferences such as language settings, display preferences and responsible gambling limit reminders, so these do not need to be re-entered on every visit.
• Optional Marketing Cookies: Used to track interactions with promotional content and, where applicable, to personalise bonus and promotional offers shown to you. These cookies are set only with your explicit consent.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling essential cookies may affect the availability of certain Platform features. Clearing all cookies will log you out of any active session.

Data Sharing & Disclosure

w665 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. We may share your data only in the circumstances described below, and only to the extent necessary for the stated purpose:

• Service Providers & Data Processors: We engage carefully selected third-party vendors to support Platform operations, including payment processors, KYC/identity verification providers, fraud detection services, cloud hosting providers, customer support software providers and analytics platforms. These vendors act as Data Processors and are contractually bound to process your data only on our instructions, to maintain appropriate security measures, and not to use your data for any independent purpose.
• Regulatory & Law Enforcement Authorities: We may be required to disclose Personal Data to our licensing authority, regulatory bodies, financial intelligence units or law enforcement agencies in response to lawful requests, court orders or legal proceedings. Such disclosures are made only to the extent required by applicable law.
• Anti-Money Laundering (AML) & Fraud Prevention Partners: Where required by our licence obligations, we may share transaction and identity data with regulated AML screening services and fraud prevention networks. This is a legal obligation and cannot be opted out of.
• Responsible Gambling Networks: Where applicable and permitted by law, we may share limited data with responsible gambling self-exclusion schemes to enforce exclusion orders and protect vulnerable players.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of the w665 business, your Personal Data may be transferred to the successor entity. You will be notified of any such transfer and your rights will be preserved.
• With Your Explicit Consent: We may share your data with any third party where you have given us your clear, informed and specific consent to do so.

International Data Transfers

The w665 Platform and its associated infrastructure may be operated from, or make use of servers and service providers located in, jurisdictions outside Pakistan. As a result, your Personal Data may be transferred to and processed in countries whose data protection laws differ from those in your country of residence.

Where such transfers occur, w665 ensures that appropriate safeguards are in place to protect your Personal Data, including:

• Standard contractual clauses or data processing agreements with receiving entities that impose equivalent data protection obligations.
• Transfer to jurisdictions that have received an adequacy determination from relevant data protection authorities, where applicable.
• Application of binding corporate rules where transfers occur within the w665 corporate group, where applicable.

By using the w665 Platform, you acknowledge that your data may be processed internationally in accordance with this Section. If you have concerns about cross-border data transfers, please contact us using the details in Section 14.

Data Retention

w665 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or our licence obligations. The following general retention periods apply:

• Account and Registration Data: Retained for the duration of your account relationship with w665 and for a minimum of five (5) years following account closure, in line with standard anti-money laundering and regulatory record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later, as required by AML legislation and gaming licence conditions.
• Transaction Records: All financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Communications Data: Customer support communications and live chat logs are retained for a period of two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Responsible Gambling Records: Self-exclusion records and responsible gambling limit histories are retained for a minimum of five (5) years to protect Users and comply with licence obligations.
• Analytics and Usage Data: Aggregated, anonymised analytics data may be retained indefinitely. Individual-level usage data is retained for no longer than thirteen (13) months.
• Marketing Preferences: Consent records for marketing communications are retained for the duration of your account and for three (3) years after account closure, as evidence of consent.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents identification of the individual. Where deletion is not immediately possible (for example, due to backup storage cycles), the data is isolated and protected from further active processing until it can be deleted.

User Rights

Subject to applicable law and certain legitimate restrictions (such as where exercising a right would conflict with a legal obligation), Users of the w665 Platform hold the following rights in respect of their Personal Data:

To exercise any of the rights listed above, please contact us using the details in Section 14. We will respond to valid requests within thirty (30) days. We may ask you to verify your identity before actioning a request to protect against unauthorised access. Some requests may be subject to a reasonable fee if they are manifestly unfounded or excessive.

Children's Privacy

The w665 Platform is strictly intended for adults. We do not knowingly collect Personal Data from individuals under the age of 18, or the higher minimum age required by the applicable licence jurisdiction. Access to the Platform by minors is expressly prohibited under our Terms & Conditions.

If we become aware that Personal Data has been collected from a person under the applicable minimum age without appropriate parental or guardian consent, we will take immediate steps to delete that data from our systems and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately using the details in Section 14 so that we can investigate and act promptly.

Data Security

w665 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. Our security practices include, but are not limited to:

• Encryption: All data transmitted between your device and the w665 Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including KYC documents and payment references, is stored in encrypted form.
• Access Controls: Access to Personal Data within w665's internal systems is restricted on a strict need-to-know basis. Staff with access to sensitive data undergo background checks and regular data protection training.
• Intrusion Detection: Our infrastructure is monitored around the clock for unusual activity, and automated systems flag potential security incidents for immediate review.
• Payment Card Security: w665 does not store full card numbers. Payment card processing is handled exclusively by PCI-DSS-compliant payment processors. w665 receives only tokenised payment references.
• Incident Response: In the event of a Personal Data breach that is likely to result in a risk to Users' rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, and will communicate directly with affected Users where required.

While we take every reasonable measure to secure your data, no online platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect unauthorised access to your account.

Pakistan-Specific Context

w665 serves a significant number of users in Pakistan, including players from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We recognise that Pakistan's regulatory environment — including with respect to data protection, financial transactions and online gambling — is distinct, and we address several Pakistan-specific considerations below:

• Data Protection Legislation: Pakistan is in the process of developing comprehensive data protection legislation. In the absence of a fully enacted federal framework, w665 applies the data protection principles set out in this Policy as a minimum standard for all Pakistani Users. We keep abreast of legislative developments and will update this Policy as required.
• Payment Data: References to payment services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on this Platform are for informational context only. These institutions are not affiliated with w665 and have not endorsed or approved the Platform. Any transaction data shared with payment processors is governed by their own privacy policies in addition to our data processing agreements.
• Gambling Restrictions: Pakistan's Prevention of Gambling Act, 1977 places restrictions on gambling activity. w665 does not hold a licence issued by any Pakistani governmental authority, and this Platform does not constitute a claim of legality in Pakistan. Users are solely responsible for determining whether their use of the Platform is lawful in their jurisdiction. This Privacy Policy does not constitute legal advice.
• Telecommunications Considerations: The Pakistan Telecommunication Authority (PTA) may restrict access to certain online services. w665 does not make any representation regarding the accessibility of the Platform within Pakistan at any given time.

Policy Amendments

w665 reserves the right to update, modify or replace this Privacy Policy at any time. When material changes are made — for example, changes to the categories of data collected, the legal bases relied upon, or the parties with whom data is shared — we will notify registered Users by email and/or by posting a prominent notice on the Platform. The "Last Updated" date at the top of this Policy will be revised to reflect the date of the most recent changes.

Your continued use of the w665 Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with a revised Policy, you must stop using the Platform and close your account in accordance with our Terms & Conditions.

We recommend that you review this Privacy Policy periodically to remain informed about how w665 is protecting your information. Archived versions of this Policy are available on request.

Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data by w665, please contact our Data Protection team through the following channels:

Please note that all contact details on this Platform are displayed as plain text for reference. Email addresses are not clickable links. When submitting a data subject rights request, please include your registered email address and a brief description of your request so we can respond efficiently and verify your identity.