milvin Privacy Policy

Introduction & Scope

This Privacy Policy ("Policy") is issued by milvin and applies to all personal data collected from individuals who access, register with, or use any service provided through the milvin Platform, accessible at milvin.asia ("the Platform"). This Policy governs our data practices regardless of how you access the Platform — whether via a mobile browser, desktop browser, or any application milvin may make available.

milvin is committed to protecting your privacy and handling your personal data in a transparent, lawful, and respectful manner. This Policy describes in detail what personal data we collect, the purposes for which it is processed, the legal basis upon which processing occurs, how long it is retained, with whom it is shared, and what rights you have over your own data.

By registering a milvin account, making a deposit, placing a bet, or otherwise using the Platform, you acknowledge that you have read, understood, and accepted the practices described in this Privacy Policy. This Policy should be read together with milvin's Terms & Conditions, which are available at /terms-conditions.

Data Controller Information

For the purposes of this Privacy Policy, milvin acts as the data controller in respect of the personal data of its registered players and Platform visitors. As data controller, milvin determines the purposes for which personal data is collected and the means by which it is processed.

milvin operates the Platform under an international gaming license. Our data protection practices are designed to be consistent with the requirements of our licensing jurisdiction's applicable data protection frameworks, as well as with internationally recognised privacy best practices.

All data-related queries, requests, and complaints should be directed to milvin's support team using the contact details provided in Section 15 of this Policy. milvin is committed to responding to all legitimate data-related inquiries within a reasonable timeframe and, where a formal request is lodged, within the timeframes prescribed by applicable law.

Data We Collect

milvin collects personal data from you through several channels — directly when you provide it to us during registration or support interactions, automatically as you use the Platform, and in limited cases from third parties involved in identity verification or payment processing. The categories of personal data we collect are described below.

How We Use Your Data

milvin uses the personal data it collects strictly for the purposes set out below. We do not use your data for any purpose not described in this Policy without first obtaining your explicit consent or establishing a fresh legal basis for the new processing activity.

• Account Creation and Management: To register your milvin account, verify your identity, maintain your account profile, and communicate important account-related information to you.
• Identity Verification (KYC): To verify that you meet the minimum age requirement of 21 years, confirm that your account is registered under your true legal identity, and comply with milvin's licensing authority's KYC obligations.
• Payment Processing: To process deposits from and withdrawals to your nominated PKR payment methods including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20.
• Gameplay and Platform Delivery: To provide you with access to milvin's casino games, sports betting markets, live dealer tables, and all other Platform features you have registered to use.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, bonus abuse, money laundering, and unauthorized account access. Gaming and transaction data is analysed using automated systems to identify anomalous patterns.
• Regulatory and Legal Compliance: To fulfil milvin's obligations under its international gaming license, including AML reporting, responsible gaming monitoring, and cooperation with licensing authority audits.
• Customer Support: To respond to your queries, complaints, and requests submitted through milvin's live chat, email, or any other support channel.
• Responsible Gaming Monitoring: To identify early indicators of problem gambling behaviour and, where appropriate, to reach out to affected players to offer access to milvin's responsible gaming tools.
• Service Improvement: To analyse aggregated usage patterns and improve the Platform's features, navigation, game offering, and payment experience. This analysis uses anonymised or pseudonymised data where possible.
• Promotional Communications: Where you have opted in to receive marketing communications, to send you information about milvin's promotions, bonus offers, and new game launches. You may opt out of promotional communications at any time.

Legal Basis for Processing

milvin processes your personal data on one or more of the following legal bases, depending on the specific processing activity involved:

• Contractual Necessity: Processing that is necessary to perform the contract between you and milvin — i.e., to provide you with access to the Platform, process your deposits and withdrawals, and operate your account. Without this processing, milvin cannot fulfil its obligations to you as a registered player.
• Legal Obligation: Processing required to comply with milvin's legal and regulatory obligations under its international gaming license, including KYC verification, AML monitoring, responsible gaming provisions, and record-keeping requirements imposed by our licensing authority.
• Legitimate Interests: Processing necessary for milvin's legitimate business interests, including fraud detection, platform security, service improvement, and internal analytics — provided these interests are not overridden by your privacy rights.
• Consent: Where milvin relies on consent as a legal basis — primarily for optional promotional communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Cookies & Tracking Technologies

milvin uses cookies and similar tracking technologies on the Platform to ensure its proper functionality, improve your user experience, and support our security and analytical operations. A "cookie" is a small text file placed on your device when you visit the Platform.

The types of cookies milvin uses include:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable you to navigate the site, maintain your login session, and access secure areas. These cookies cannot be disabled without materially affecting Platform functionality.
• Performance and Analytics Cookies: These cookies collect information about how players use the Platform — which pages are visited most frequently, how long sessions last, and where errors occur. This data is used in aggregated, anonymised form to improve the Platform.
• Functionality Cookies: These cookies remember your preferences — such as your selected language, display settings, or last-visited game category — to provide you with a more personalised experience on return visits.
• Security Cookies: These cookies support milvin's fraud detection and account security systems, helping to identify unusual login behaviour, suspicious transaction patterns, and other security-relevant signals.

You may manage cookie preferences through your browser settings. Note that disabling certain categories of cookies — particularly strictly necessary cookies — may impair your ability to use core Platform features including login and gameplay.

Third-Party Data Sharing

milvin shares your personal data with third parties only to the extent strictly necessary for the operational, legal, and compliance purposes described in this Policy. milvin does not engage in the sale, rental, or commercial transfer of personal data to any third party for their independent marketing or business purposes.

The categories of third parties with whom milvin may share your personal data, and the basis for such sharing, are as follows:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and cryptocurrency processing services receive your payment details solely to execute the financial transactions you initiate through milvin's cashier. These parties are subject to their own privacy and data protection obligations.
• KYC Verification Partners: milvin uses third-party identity verification services to assist with CNIC verification and document authentication as part of the KYC process mandated by our licensing authority. These providers process your identity data on milvin's behalf under strict data processing agreements.
• Game Software Providers: The third-party game studios and live casino operators whose games are hosted on the milvin Platform may receive your player ID and gameplay data to the extent necessary to deliver and support their games. These providers do not receive your identity or financial data.
• Licensing and Regulatory Authorities: milvin's international gaming licensing authority may receive compliance reports, AML disclosures, and other regulatory data as required by the terms of milvin's license. Such sharing is mandatory and non-discretionary.
• Law Enforcement and Legal Authorities: Where milvin is legally compelled to do so — by court order, regulatory mandate, or applicable law — we may disclose your personal data to law enforcement agencies or legal authorities. milvin will notify you of such disclosure where legally permitted to do so.
• Professional Advisers: milvin's legal, financial, and compliance advisers may access personal data in the course of providing professional services to milvin, subject to applicable professional confidentiality obligations.

International Data Transfers

As an internationally licensed online gaming platform serving players in Pakistan, milvin may store and process your personal data on servers located outside of Pakistan. This occurs where our infrastructure providers, game software partners, or third-party service providers operate from jurisdictions other than Pakistan.

Where personal data is transferred internationally, milvin takes steps to ensure that appropriate safeguards are in place to protect your data to a standard that is consistent with this Policy. Such safeguards may include contractual data protection clauses, processing agreements, or reliance on adequacy determinations applicable in our licensing jurisdiction.

By using the milvin Platform and providing us with your personal data, you acknowledge and consent to the transfer, storage, and processing of your data in jurisdictions outside Pakistan where this is necessary to deliver milvin's services to you. milvin will not transfer your data internationally beyond what is required for operational, legal, and compliance purposes.

Data Security

milvin implements a multi-layered approach to data security, combining technical, organisational, and procedural controls to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security framework includes the following measures:

• Encryption in Transit: All data transmitted between your device and milvin's servers is protected using Transport Layer Security (TLS) encryption. This applies to all Platform pages, the cashier, and the live chat interface.
• Encryption at Rest: Sensitive personal data — including identity information and financial records — is stored in encrypted form on milvin's servers using industry-standard encryption algorithms.
• Access Controls: Access to player personal data within milvin's organisation is restricted to personnel who require it to perform their specific job functions. Role-based access controls are enforced and access logs are maintained and reviewed regularly.
• Two-Factor Authentication: milvin's internal administrative systems require multi-factor authentication for all personnel accessing player data environments. We also offer — and strongly recommend — OTP-based verification for player account logins.
• Regular Security Testing: milvin conducts regular security assessments, including vulnerability scans and penetration testing, to identify and remediate potential security weaknesses in the Platform.
• Incident Response: milvin maintains a documented data breach response procedure. In the event of a data breach that is likely to result in risk to affected individuals, milvin will notify impacted players and relevant authorities as required by our licensing obligations.

While milvin employs robust security measures, no internet-based system can guarantee absolute security. You play an important role in protecting your own account by maintaining a strong password, enabling OTP verification, and not sharing your credentials with anyone.

Data Retention

milvin retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to the retention periods required or permitted by milvin's licensing authority and applicable legal obligations. The following retention framework applies:

• Active Account Data: Personal data associated with an active milvin account is retained for the duration of your account's active status and for a minimum period of five (5) years following account closure, in accordance with standard gaming industry AML record-keeping requirements.
• Transaction and Financial Records: Deposit, withdrawal, and betting transaction records are retained for a minimum of five (5) years from the date of the transaction to comply with AML and licensing obligations.
• KYC Documents: Identity verification documents submitted during the KYC process are retained for the duration of your active account relationship and for the minimum post-closure period required by our licensing authority.
• Support Communications: Live chat transcripts and email correspondence are retained for a minimum of two (2) years from the date of the interaction to support complaint resolution and service quality monitoring.
• Technical and Log Data: Server logs and technical data are typically retained for between ninety (90) days and twelve (12) months, depending on the category of data and its relevance to security monitoring.
• Marketing Preferences: Records of your marketing consent status are retained for the duration of your account relationship and for a sufficient period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, milvin securely deletes or anonymises your personal data such that it can no longer be linked to you as an individual.

Your Data Rights

milvin recognises and respects the rights you hold over your personal data. The following rights are available to you as a milvin player:

Children & Minors

milvin's Platform and all associated services are strictly restricted to individuals who are 21 years of age or older. milvin does not knowingly collect, store, or process personal data from any individual under the age of 21. This restriction is enforced through milvin's mandatory KYC verification process, which requires confirmation of date of birth via a government-issued identity document.

If milvin becomes aware that personal data has been collected from an individual under the age of 21 — whether through a false declaration at registration or through other means — milvin will take immediate steps to suspend the relevant account, delete or anonymise the collected personal data to the extent permitted by our legal obligations, and return any deposited funds to the originating payment method after confirming the individual's identity.

If you are a parent or guardian and you believe that a minor in your household may have registered a milvin account or otherwise provided their personal data to milvin, please contact our support team immediately. milvin will treat such reports with the highest priority.

Responsible Gaming & Data

milvin's responsible gaming programme involves the collection and monitoring of certain categories of gaming behaviour data. This processing is a mandatory component of milvin's licensing obligations and reflects our genuine commitment to player wellbeing. The responsible gaming data milvin processes includes:

• Session durations, frequency of visits, and time-of-day gambling patterns.
• Deposit frequency, deposit amounts, and changes in deposit behaviour over time.
• Loss patterns and evidence of loss-chasing behaviour.
• Self-reported responsible gaming settings including deposit limits, loss limits, and cool-off periods.
• Self-exclusion status and exclusion duration records.
• Internal flags raised by milvin's responsible gaming monitoring systems or by support team members who identify a player who may be experiencing difficulties.

This data is processed on the legal basis of legitimate interests (protecting player welfare) and legal obligation (compliance with our licensing authority's responsible gaming requirements). It is not shared with third parties except where required for regulatory reporting. For more information about milvin's responsible gaming tools, please visit our Responsible Gaming page.

Changes to This Privacy Policy

milvin reviews and updates this Privacy Policy periodically to reflect changes in our data practices, our Platform's features, applicable legal requirements, and our licensing obligations. The effective date at the top of this Policy is updated each time a revision is made.

Where changes to this Policy are material — meaning they significantly affect the way your personal data is processed or your rights in relation to that data — milvin will provide you with notice of the change via the Platform or through communication to your registered mobile number or email address, and will allow a reasonable period for you to review the updated Policy before it takes effect.

Continued use of the milvin Platform following the publication of a revised Privacy Policy constitutes your acknowledgment of and agreement to the updated terms. milvin recommends reviewing this page periodically to remain informed of how your personal data is being handled.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or milvin's data practices, please contact our support team through any of the following channels. milvin's support team is available 24 hours a day, seven days a week, in both English and Urdu, and will ensure your data-related inquiry reaches the appropriate person within our organisation.

• Live Chat: Available directly on the milvin Platform. This is the fastest channel for urgent data-related queries, with typical first response times under two minutes during standard hours.
• Email: For formal written data requests — including subject access requests, erasure requests, and formal complaints — please write to: [email protected]. Please include your registered mobile number and a description of your request to allow us to assist you efficiently.

milvin is committed to resolving all privacy-related inquiries promptly and fairly. Formal data rights requests will be acknowledged within five (5) business days of receipt and responded to substantively within thirty (30) days unless the complexity of the request requires an extension, in which case you will be notified.