barhawin Privacy Policy

1 Who We Are

barhawin ("we", "us", "our", "the Platform") is an international online gaming platform operating under a valid international gaming licence. Our platform is accessible at barhawin.net and is primarily designed to serve English-speaking users in Pakistan, including players in Karachi, Lahore, Faisalabad, Islamabad, and all other cities across the country.

For the purposes of this Privacy Policy, barhawin acts as the data controller — meaning we determine the purposes for which and the means by which your personal data is processed. Where we engage regulated third-party service providers (for example, payment processors or identity verification services), those providers act as data processors under our instruction and are bound by strict data protection agreements.

If you have any questions about this Privacy Policy or how we handle your data, you can reach our Data Protection team at [email protected]. We aim to respond to all privacy-related enquiries within 14 business days.

2 Data We Collect

barhawin collects personal data in two primary ways: information you provide to us directly, and information we collect automatically when you use the platform. The following table summarises the categories of data we collect and the context in which each category is gathered:

3 How We Use Your Data

barhawin uses the personal data we collect for the following specific purposes:

1. Account Management: To create, maintain, and secure your barhawin account, including verifying your identity, enabling login access, and managing your account settings and preferences.
2. Payment Processing: To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other supported payment methods in PKR. Financial data is also used for transaction reconciliation and dispute resolution.
3. Legal & Regulatory Compliance: To fulfil our obligations under applicable anti-money laundering (AML) laws, Know Your Customer (KYC) regulations, and the requirements of our international gaming licence. This includes transaction monitoring and reporting to relevant authorities where legally required.
4. Platform Operation & Improvement: To monitor platform performance, diagnose technical issues, understand how users interact with barhawin, and continuously improve the user experience across cricket betting, live casino, and slot features.
5. Responsible Gaming: To monitor gaming patterns that may indicate problem gambling behaviour, to administer self-imposed deposit limits, loss limits, cooling-off periods, and self-exclusion requests, and to deliver responsible gaming communications to users who request them.
6. Customer Support: To respond to enquiries, complaints, and support requests submitted via live chat or email, and to maintain records of these interactions for quality assurance and dispute resolution purposes.
7. Security & Fraud Prevention: To detect and investigate suspicious account activity, fraudulent transactions, bonus abuse, and potential violations of our Terms & Conditions. Technical and usage data play an important role in this process.
8. Marketing Communications: Where you have opted in, to send you promotional offers, bonus notifications, and platform updates via email or SMS. You may opt out of marketing communications at any time by contacting support or using the unsubscribe link in any marketing email.

4 Legal Basis for Processing

barhawin processes your personal data under the following legal bases, in accordance with internationally recognised data protection principles:

• Contractual Necessity: Processing your identity data, contact data, and financial data is necessary for barhawin to perform its obligations under the account agreement you enter into at registration — including managing your account, processing transactions, and providing gaming services.
• Legal Obligation: barhawin is legally required to collect and retain certain categories of personal data under AML regulations, gaming licence conditions, and international financial compliance standards. This processing is non-optional and cannot be limited by user consent preferences.
• Legitimate Interests: barhawin processes technical data, usage data, and communications data under its legitimate interest in operating a secure, functional, and fraud-free gaming platform. We have assessed that this processing does not override your fundamental rights and freedoms.
• Consent: Where barhawin relies on consent as a legal basis — specifically for marketing communications — you retain the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

5 Data Sharing & Third Parties

barhawin does not sell your personal data. We may share your data with the following categories of third parties, strictly for the purposes described in this Privacy Policy:

• Identity Verification Providers: Regulated KYC/AML service providers who assist with age and identity verification, document authentication, and sanctions screening. These providers access only the data necessary to complete the verification task.
• Payment Processors: Regulated payment infrastructure partners including JazzCash, EasyPaisa, and banking partners such as HBL, UBL, and Meezan Bank, who process deposit and withdrawal transactions on our behalf.
• Game Content Providers: Licensed third-party game studios and live casino operators who provide the gaming content available on the barhawin platform. These providers receive only the technical session data necessary to deliver gameplay.
• IT & Security Service Providers: Cloud infrastructure, cybersecurity, and data analytics providers who support the technical operation and security of the barhawin platform under strict data processing agreements.
• Regulatory & Law Enforcement Authorities: barhawin will disclose personal data to regulators, law enforcement agencies, or courts when required to do so by applicable law, court order, or where we believe disclosure is necessary to prevent imminent harm or financial crime.

6 Data Retention

barhawin retains personal data for no longer than is necessary for the purposes for which it was collected, subject to the following retention guidelines:

• Active Account Data: Personal and financial data associated with an active barhawin account is retained for the duration of the account relationship and remains accessible to you via your account dashboard.
• Closed Account Data: Following account closure, barhawin retains identity and transaction records for a minimum of five (5) years to comply with AML record-keeping obligations under our international gaming licence. This period may be extended where an account is subject to ongoing investigation or legal proceedings.
• Marketing Data: If you have opted in to marketing communications and subsequently opt out, your opt-out preference is recorded and retained indefinitely to ensure we do not contact you again without a fresh, valid consent.
• Support Records: Customer support communications are retained for three (3) years from the date of the interaction for quality assurance and dispute resolution purposes.
• Technical Logs: IP address logs and session data are retained for up to twelve (12) months for security monitoring and fraud investigation purposes, after which they are automatically purged.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be associated with you as an individual.

7 Cookies & Tracking Technologies

barhawin uses cookies and similar technologies to operate the platform, remember your preferences, maintain your session, and analyse how users interact with our services. The following categories of cookies are in use on barhawin:

• Strictly Necessary Cookies: These cookies are essential for the barhawin platform to function. They enable core functions such as user authentication, session management, and security. You cannot opt out of these cookies while using the platform.
• Functional Cookies: These cookies remember your preferences, such as your chosen language, display settings, and responsible gaming tool configurations, so you do not have to reset them on every visit.
• Analytical Cookies: barhawin uses privacy-preserving analytics tools to understand how users navigate the platform, which features are most used, and where technical issues may be occurring. This data is aggregated and does not identify individual users.

barhawin does not use cross-site advertising cookies or allow third-party advertisers to place tracking technologies on our platform. You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the platform.

8 Your Data Rights

As a barhawin user, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request – [Your Username]":

barhawin will respond to all verified data rights requests within thirty (30) calendar days. In complex cases, this period may be extended by a further two months, and we will notify you of any such extension within the initial 30-day window. There is no fee for exercising your rights, unless requests are manifestly unfounded or excessive.

9 Security Measures

barhawin implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Our security framework includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and barhawin's servers is protected with industry-standard SSL/TLS encryption. The padlock icon in your browser confirms this is active on every page of our platform.
• Encrypted Data Storage: Personal data held in barhawin's databases is encrypted at rest using AES-256. This means that even in the event of an unauthorised database access, the data would be unreadable without the encryption keys.
• Password Security: User passwords are never stored in plain text. barhawin uses a modern one-way hashing algorithm with a unique salt per user, making password recovery attacks computationally infeasible.
• Two-Factor Authentication (2FA): barhawin offers optional two-factor authentication for all registered accounts. We strongly encourage all Pakistani users to enable 2FA via their account security settings.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff with access to sensitive user data undergo security awareness training and are subject to confidentiality obligations.
• Penetration Testing: barhawin engages independent cybersecurity specialists to conduct regular penetration tests and vulnerability assessments of our platform infrastructure.
• Incident Response: In the event of a personal data breach that poses a risk to users, barhawin will notify affected users and relevant regulatory authorities within the timeframes required by applicable law, and no later than 72 hours after becoming aware of the breach.

While barhawin maintains robust security measures, no online platform can guarantee absolute security. Users are advised to use strong, unique passwords for their barhawin accounts and to enable 2FA wherever possible.

10 International Data Transfers

As an internationally licensed gaming platform serving users in Pakistan, barhawin may transfer personal data to and process it in countries outside Pakistan. This can occur when our cloud infrastructure, game content providers, or identity verification partners are based in other jurisdictions.

Where such transfers occur, barhawin ensures that adequate protections are in place by:

• Transferring data only to countries or organisations that provide an adequate level of data protection as assessed under internationally recognised standards
• Implementing appropriate contractual safeguards, including standard contractual clauses, in agreements with all international data processors
• Conducting data transfer impact assessments where required to evaluate the risk to users' rights and freedoms

You may request further information about the specific safeguards applied to international transfers of your personal data by contacting our Data Protection team at [email protected].

11 Children's Privacy

barhawin is strictly an adults-only platform. Access to and use of barhawin services is permitted only to individuals who are aged 21 years or above. This age restriction applies to all users regardless of location.

If you are a parent or guardian and believe that your child may have created a barhawin account, please contact us immediately at [email protected]. We will investigate and take appropriate action without delay.

12 Policy Updates

barhawin reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this policy, we will:

• Update the "Last Updated" date displayed at the top of this page
• Send a notification to your registered email address summarising the key changes
• Display a prominent in-platform notification for a period of at least 14 days following the update

Your continued use of the barhawin platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically so you are always aware of how your data is being handled.

13 Contact & Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or barhawin's data processing practices, you are welcome to contact our Data Protection team through the following channels:

• 📧 Email: [email protected] — use subject line "Privacy Enquiry" for fastest routing
• 💬 Live Chat: Available 24/7 directly within the barhawin platform after login
• 🕐 Response Time: We aim to acknowledge all privacy-related enquiries within 3 business days and resolve them within 30 calendar days

For formal data rights requests, please include your registered username and a description of the right you wish to exercise. We may need to verify your identity before processing the request to ensure your data is not disclosed to an unauthorised party.