Privacy Policy – shbwr Data Protection and User Privacy

1 Information We Collect

When you register for and use a shbwr account, we collect personal information that is necessary to operate your account, verify your identity, process payments and provide you with a safe gaming experience. The categories of data we collect include:

We do not collect sensitive data such as biometrics, religious beliefs or political opinions. CNIC information is collected solely for the purpose of identity verification as required by our anti-fraud and responsible gaming processes.

You may also provide data to us indirectly — for example, if you contact support through a third-party chat tool, that communication will be logged and stored as part of your account record.

2 How We Use Your Data

shbwr uses the personal data we collect for the following defined purposes. We do not use your data for any purpose not listed here without obtaining your explicit consent first:

• Account operation: To create, maintain and manage your shbwr account, including login authentication, account balance management and transaction history.
• Identity verification: To verify your age (18+) and confirm your identity in line with our responsible gaming and anti-fraud obligations. This is a one-time process that may be triggered again if your account details change.
• Payment processing: To process your deposits and withdrawals via JazzCash, Easypaisa, Raast, bank transfer and other supported PKR payment methods.
• Customer support: To respond to your queries, resolve disputes related to bets or transactions, and provide technical assistance when you contact us.
• Fraud and security monitoring: To detect, prevent and investigate suspicious activity, unauthorised account access, bonus abuse and other security threats to the platform and to individual accounts.
• Responsible gaming: To monitor for patterns that may indicate problem gaming behaviour, such as extended sessions or rapid escalation in bet sizes, and to apply tools like deposit limits or self-exclusion when requested.
• Marketing communications: To send you relevant promotions, bonus offers and platform updates — but only if you have opted in to receive marketing. You can opt out at any time from your account settings.
• Platform improvement: To analyse aggregated, anonymised usage data to improve the performance, design and content of the shbwr platform over time.

3 Payment Data

All deposits and withdrawals on shbwr are processed in Pakistani Rupees (PKR). When you make a payment transaction, the following data handling applies:

• shbwr does not store full debit or credit card numbers on our servers. Card transactions are handled directly by our payment gateway partner, which is PCI-DSS compliant.
• For mobile wallet transactions via JazzCash or Easypaisa, we record the transaction reference number, amount and timestamp — but never your mobile wallet PIN or full account credentials.
• Raast and bank transfer transactions are recorded with the reference ID and account title for reconciliation purposes. Full bank account numbers are not stored beyond what is strictly required for processing.
• Transaction records are retained for a minimum of five years for financial record-keeping and dispute resolution purposes.
• If a transaction is disputed or a chargeback is initiated, the relevant transaction data will be shared with the payment provider involved in order to resolve the matter.

All payment data is encrypted at rest and in transit. Access to payment records is restricted to authorised shbwr staff with a legitimate operational need, and all access is logged.

4 Cookies and Tracking

shbwr uses cookies and similar tracking technologies to deliver and improve your experience on the platform. Here is a straightforward breakdown of what we use and why:

• Essential cookies: These are necessary for the platform to function. They maintain your login session, remember your language preferences and ensure your account balance is displayed correctly. You cannot opt out of essential cookies without affecting the platform's core functionality.
• Analytics cookies: We use anonymised analytics to understand how users navigate the platform — which pages are visited most, where users drop off and how long sessions typically last. This data is aggregated and cannot be used to identify individual users.
• Preference cookies: These remember your display preferences, such as your preferred sports categories (for example, Cricket or Football) and your default game lobby view.
• Security cookies: Used to detect and prevent fraudulent login attempts and to protect against cross-site request forgery attacks.

You can manage your cookie preferences from your browser settings. Please note that disabling certain cookies may affect how parts of the shbwr platform function for you. We do not use cookies to track your activity across unrelated third-party websites.

5 Data Sharing and Third Parties

shbwr does not sell or share your personal data with third parties for their own commercial purposes. However, we do share data with a limited set of service providers who help us operate the platform. In every case, these providers are bound by strict data processing agreements and are only permitted to use your data for the specific purpose for which it was shared.

• Payment providers: JazzCash, Easypaisa, Raast and our bank transfer partners receive the minimum transaction data required to process your deposits and withdrawals.
• Identity verification services: When we need to verify your identity or age, your submitted documents may be processed by a third-party verification service. These services are bound by confidentiality obligations and do not retain your data beyond the verification process.
• Game studio providers: When you play a Casino game, Slot or Live Casino table provided by a third-party studio, that studio's game server records the outcome of your session. The studio receives only a session identifier — not your full account details.
• Cloud and hosting infrastructure: shbwr uses secure cloud hosting services to store account data and platform content. These providers operate under strict data security obligations.
• Legal and regulatory requirements: shbwr may disclose your data to law enforcement or relevant authorities if required to do so under applicable law, or to protect the rights, safety and property of shbwr, its users or the public.

We will never share your data with an advertiser, data broker or any party whose primary interest is in using your information for commercial profiling or targeting purposes.

6 Data Security

shbwr takes data security seriously. We have implemented technical and organisational measures designed to protect your personal data against unauthorised access, accidental loss, alteration or disclosure. Key security measures in place include:

• SSL/TLS encryption for all data in transit between your browser or app and our servers.
• Encryption at rest for sensitive account and payment records stored on our infrastructure.
• Role-based access controls that ensure only authorised staff members can access specific categories of user data.
• Regular security reviews and vulnerability assessments of the platform infrastructure.
• Two-factor authentication options available for your shbwr account to add an extra layer of login security.
• Automated monitoring for suspicious login activity, including logins from unusual locations or devices.

While we do everything reasonably possible to secure your data, no online system can guarantee absolute security. If you suspect that your shbwr account has been accessed without your authorisation, contact our support team immediately. You are responsible for keeping your login credentials confidential and for logging out of shared devices after each session.

7 Data Retention

shbwr retains your personal data only for as long as is necessary for the purposes described in this policy, or as required by applicable record-keeping obligations. The general retention periods we follow are:

• Account data: Retained for the duration of your account and for a minimum of two years after account closure, to allow for dispute resolution and audit purposes.
• Transaction and payment records: Retained for a minimum of five years from the date of the transaction.
• Identity verification documents: Retained for as long as your account is active and for a period after closure as required by anti-fraud obligations. Copies are deleted once they are no longer required.
• Gaming activity records: Bet history and game session data are retained for a minimum of two years for dispute resolution and responsible gaming monitoring purposes.
• Support communications: Retained for one year from the date of the conversation unless the matter relates to an ongoing dispute, in which case records are retained until the dispute is fully resolved.
• Marketing opt-in records: Retained for as long as you have an active marketing preference on your account. If you opt out, we retain a record of your opt-out for suppression purposes.

When data is no longer required under our retention schedule, it is securely deleted or anonymised. Anonymised data — which cannot be linked back to you — may be retained indefinitely for aggregated platform analytics.

8 Your Rights

As a shbwr user, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team with your request. We aim to respond within a reasonable timeframe:

• Right to access: You can request a copy of the personal data we hold about you at any time. We will provide this in a clear, readable format.
• Right to correction: If any data we hold about you is inaccurate or out of date, you can ask us to correct it. For example, if your contact number has changed, you can update it directly from your account settings or by contacting support.
• Right to deletion: You can request deletion of your personal data. Please note that certain data categories — such as transaction records — may be retained for legal and operational reasons even after an account closure request, as described in Section 7.
• Right to object to marketing: You can opt out of receiving promotional emails and SMS messages from shbwr at any time. Simply update your notification preferences in your account settings or contact support.
• Right to data portability: You can request your data in a structured, machine-readable format where this is technically feasible for the category of data requested.
• Right to restrict processing: In specific circumstances — for example, if you have contested the accuracy of your data — you can ask us to pause processing of that data while we investigate.

9 Minors and Age Verification

shbwr's platform is strictly for users who are 18 years of age or older. We take the protection of minors very seriously and have processes in place to prevent underage use of the platform.

• Date of birth is collected at registration and must be accurate. Providing a false date of birth to circumvent the age requirement is a breach of our Terms and Conditions and will result in account closure.
• Where we have reason to suspect that a registered user may be under 18, the account will be suspended immediately pending age verification. Any deposits made during the suspension period will be returned once identity is confirmed.
• shbwr does not knowingly collect or retain personal data belonging to anyone under the age of 18. If we discover that data has been collected from a minor, it will be deleted promptly and the account will be permanently closed.
• Parents and guardians are encouraged to use parental control tools to restrict access to online gaming platforms on shared devices. shbwr is not responsible for minors accessing the platform via a registered adult's account.

If you believe that a minor has registered on shbwr using false information, please contact our support team immediately so we can investigate and take the appropriate action.

10 Updates to This Privacy Policy

shbwr may update this Privacy Policy from time to time to reflect changes in how we operate, changes in applicable data protection standards or other relevant developments. When we make material changes to this policy, we will:

• Update the "Last Updated" date at the top of this page.
• Notify registered users via email or via a notification displayed on the platform.
• Where required, ask for your renewed consent if the change affects how we use your data in a way that goes beyond what you originally agreed to.

Your continued use of the shbwr platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with an update, you should discontinue use and contact support to request account closure.

We recommend bookmarking this page and reviewing it periodically. The most current version will always be available at shbwr.win/privacy-policy.