PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy, last updated on 01/11/2024, describes the data processing activities carried out by ninewin.com. At ninewin.com, we aim to keep everything simple and convenient for our customers, including being clear, transparent, and open about what information we collect, as well as how and why we use it, so this page provides detailed explanations.
Our Policy outlines how we process your personal data, whether you are simply browsing, making a deposit, or playing any of our games. It also contains important details about your data protection rights, the situations in which we collect and share information about you, and how we use that information to tailor the marketing you receive, so we encourage you to read all sections carefully.
If we introduce any significant changes to this Policy, we will notify you accordingly.
Please be aware that all our employees regularly undergo training on Information Security and must comply with confidentiality obligations and internal policies and procedures whenever they process your information.
We hope this page will be useful to you, but if you have any questions or concerns regarding Data Protection, please do not hesitate to contact our Data Protection Officer at [email protected].

2. PRIVACY POLICY PROMISE

Ninewin consistently values and respects the privacy of every customer. Your privacy matters to both you and us, and we make the following commitment:
Ninewin is dedicated to safeguarding your privacy. We use your personal information to make our services easier and more convenient for you. Your personal data will always be kept secure. We will clearly explain why we collect your information and how it is used. Whenever you have rights or options, we will inform you about them and honor your decisions.
To request a withdrawal, a player must wager the active deposited amount at least once before submitting a withdrawal request. This requirement complies with anti-money laundering regulations.
The Company retains the right to apply additional procedures and methods to verify a client’s identity (Know Your Client) when processing account deposits. This may include, but is not limited to, providing a selfie with an identification document or another form of ID. To complete account verification, casino management may request documents (ID, payment method confirmation, utility bills etc) in the Latin or Cyrillic alphabet. If a player is unable to provide documents in these alphabets, the Casino reserves the right to require video verification during which the player presents their documents.
Players who deposit in CAD may withdraw funds only via EcoPayz, Interac, Instadebit, and iDebit. A minimum deposit using one of these payment methods is required to enable withdrawals through them.
The Company reserves the right to contact the phone number listed in the client’s account as part of the KYC procedure. No payouts will be processed until the account verification is successfully completed.

3. WHAT PERSONAL INFORMATION IS COLLECTED AND WHEN

When registering an account:
1. your personal information, including your name, email address, residential address, phone or mobile number, gender, and date of birth;
2. photo identification and proof of address documents (for due diligence purposes);
3. banking and financial information (to verify the source of funds when a transaction takes place);
4. your account access details, such as username and password.
When using our Services:
1. details about how you use and interact with our products;
2. information regarding your online browsing activity on the Website – please refer to our Cookies Policy for additional information;
3. data about the devices you use to access our Services (such as device model, operating system, IP address, browser type, and mobile device identifiers);
4. recordings of phone conversations – we may monitor or record calls with you to ensure your instructions are followed accurately, to address questions or concerns, to comply with regulatory obligations, to improve service quality, to train our employees, and to detect or prevent fraud or other unlawful activities;
5. information you voluntarily provide to us or make publicly available, such as through social media profiles.
Special categories of data
1. Personal data collected by ninewin.com may include so-called “special categories of data”, such as information related to health (for responsible gambling purposes) (see Section «Why do we collect your Personal Data and on what basis»).
2. We implement additional safeguards to ensure the protection and confidentiality of your sensitive personal data (see Section «Security of your data and confidentiality»).

4. WHY DO WE COLLECT YOUR PERSONAL DATA AND ON WHAT BASIS?

We value the trust and confidence our customers place in us as a service provider. In return, Ninewin is transparent about the reasons for collecting your data. Primarily, we gather your information to deliver the services and products you request. Additionally, your data helps us tailor and enhance your experience with our services and allows us to contact you periodically with important updates. In certain situations, we are required to collect and process your information to meet legal obligations. Under data protection legislation, we must also establish a lawful basis for processing your personal data. We rely on different legal grounds depending on the specific processing activity.
Under the contract – when processing is necessary for the performance of a contract to which you are a party. Our T&Cs, accepted by you during registration, outline the contractual terms and the services we agree to provide:
1. To provide our services to you under the terms of our contract
  1. to deliver gaming and betting services, activities, or online content, to supply related information, and to handle your requests and inquiries;
  2. for service administration purposes, such as sending password reminders, service notifications including site maintenance updates, changes to our Privacy and Cookies Policy or T&Cs, informing you if your Ninewin account becomes inactive, and asking whether you wish to reactivate it before closure;
  3. to carry out and manage your transactions;
Under legitimate interests – processing your data is necessary for the purposes described below, provided that our interests are not outweighed by your interests, rights, or freedoms. When determining whether we can rely on this basis, we consider several factors, including what you were informed about when providing your data, your reasonable expectations regarding its use, the type of data involved, and the potential impact of the processing on you.
1. To customize your experience
  1. to provide a more relevant and personalized service, for example, by using your gaming history to suggest suitable recommendations and products;
  2. If you are logged in or subscribed to our marketing communications, you will receive personalized services. If you prefer not to receive them, you may unsubscribe from marketing communications or disable personalization by contacting our Customer Service team or emailing our Data Protection Officer.
2. To enhance our services and products
  1. to ensure the most convenient and user-friendly online navigation experience;
  2. to conduct analysis and research in order to improve the services provided by Ninewin;
  3. to test new systems and evaluate upgrades to existing systems;
  4. to assess the effectiveness of marketing activities and carry out market research and staff training;
  5. to perform customer profiling, statistical evaluations, and trend analysis aimed at developing and improving our products and services.
3. To contact and communicate with you
  1. to reach you regarding our services, for example by phone, email, post, or social media;
  2. to administer promotions and competitions in which you choose to participate;
  3. to invite you to participate in and manage customer surveys, questionnaires, and other market research activities conducted by Ninewin or by third parties acting on our behalf (we carry out market research to improve our services. If we contact you for this purpose, participation is voluntary. If you inform us that you do not wish to be contacted for market research, we will respect your decision and this will not affect your ability to use our services);
  4. to respond to your questions and complaints.
4. To ensure your gaming experience is safer and more enjoyable
  1. to discourage, prevent, or detect the use of unauthorized third-party software in peer-to-peer gambling;
  2. to discourage, prevent, or identify activities that violate our T&Cs;
  3. to carry out affordability checks to confirm that you have adequate funds to use our Services.
Special categories of data
1. We will process such data only if:
  1. you have provided your explicit consent;
  2. the data concerns personal information that you have made publicly available;
  3. processing is necessary for the establishment, exercise, or defense of legal claims;
  4. processing is required for reasons of substantial public interest under European Union or Member State law.

5. WHEN DO WE SHARE YOUR PERSONAL INFORMATION?

As a general rule, we do not share your personal information with third parties outside the Company group for marketing purposes. However, there are situations where we may share your data with affiliated companies, with third-party service providers acting on our behalf, and with other third parties when required to meet our legal obligations.
We may disclose personal data to third parties in the following cases:
1. when required by a regulatory authority or under applicable legal provisions;
2. when we instruct and authorize the financial institution holding an Account Holder’s account to provide information requested by a regulator regarding that account;
3. to establish, exercise, or defend our legal rights;
4. for identity verification, affordability assessments, and fraud prevention purposes, which may involve transferring your personal data to third parties;
5. to service providers that support the delivery of our services, such as companies assisting with technology solutions, data storage and processing, payment processing, or online advertising related to our products and services;
6. to external auditors conducting independent reviews as part of our accreditation processes;
7. to any organization to which we sell, transfer, or negotiate the sale or transfer of any part of our business or any rights or obligations under agreements with you. If such a transaction occurs, the receiving organization may use your personal data in the same manner as we do;
8. to any legal successor of our business; or
9. to the relevant regulatory authority in matters related to self-exclusion;
10. in connection with a merger or business sale, where customer personal data may form part of the transferred assets. We will notify you before such a transfer takes place. In all cases, we ensure that your personal information is used only in accordance with this Privacy Policy.

6. HOW LONG WILL NINEWIN.COM KEEP MY DATA?

We retain your information only for as long as necessary to achieve the purposes for which it was collected.
While you remain a customer, we must keep your information to fulfill our legal and contractual obligations. After you stop using Ninewin Services, we will continue to store your personal data for a certain period. The reasons for retaining your information include:
1. to comply with legal requirements under EU or local laws, such as anti-money laundering or licensing regulations;
2. to establish, exercise, or defend legal claims, for example claims of negligence brought against us;
3. to meet our contractual rights and obligations related to the information concerned;
4. to pursue our legitimate interests where appropriate balancing tests have been conducted;
5. to comply with guidance issued by relevant data protection authorities.

7. YOUR RIGHTS & CHOICES OVER YOUR PERSONAL INFORMATION

We acknowledge that, in accordance with applicable laws and subject to certain conditions, you have several rights regarding the personal information we hold about you. To exercise any of these rights, please contact our Data Protection Officer at [email protected]. Your rights include access to, correction of, and deletion of your personal data, the right to object to processing, the right to withdraw consent, and the right to data portability. You also have the right to lodge a complaint with your data protection authority if you have concerns about how we handle your information. Additionally, you have specific rights related to automated decision-making and profiling.
The personal information requested during registration is mandatory unless clearly marked as optional. This information is required to process your registration, communicate with you, and comply with applicable gambling and financial regulations. If you choose not to provide the required personal data, you will not be able to use our services.
Right of access and correction. You are entitled to request a copy of the personal information we hold about you, commonly referred to as a data subject access request. You may also request that any inaccurate or outdated information be corrected or deleted. These requests are free of charge and may be submitted by emailing our Data Protection Officer or contacting Customer Services at [email protected].
Right to erasure. In certain circumstances, you may request that we delete the personal information we hold about you, also known as the right to be forgotten. This applies in situations where:
1. the information is no longer required for the purpose for which it was originally collected, as described in our privacy notice;
2. you previously provided consent for the use of your information but later withdraw that consent, and we cannot rely on another lawful basis under data protection law to continue processing;
3. we process your information based on our legitimate interests and cannot demonstrate compelling legitimate grounds to continue such processing;
4. we do not have a valid legal basis under data protection law to process your information;
5. the data must be erased in order to comply with a legal obligation;
This right is subject to mandatory retention periods under EU or local laws.
Right to restrict processing. You have the right to request that we restrict, block, or suppress the processing of your personal information. When processing is restricted, we may continue to store your data but will not use it for other purposes. We maintain records of individuals who have requested restrictions to ensure their preferences are respected in the future. This right applies in the following situations:
1. you contest the accuracy of the personal information, while we verify its correctness;
2. the processing is unlawful and you oppose the deletion of the data, requesting restriction instead;
3. we no longer require the data for our purposes, but you need it to establish, exercise, or defend a legal claim; and
4. we process your information based on our legitimate business interests and you object, while we assess whether we have overriding grounds to continue processing.
Right to Data Portability. You have the right to receive the personal information you have provided to us in a commonly used, machine-readable format. This enables you to obtain and reuse your data for your own purposes across different services. For example, if you choose to switch to another provider, you may move, copy, or transfer your information securely between our IT systems and theirs without affecting its usability. This right is not absolute and applies only where the processing of your information is:
1. based on your consent or where processing is necessary for the performance of a contract; and
2. carried out solely by automated means.
Right to object. Depending on your specific circumstances, you have the right to object to the processing of your personal information where it is:
1. based on our legitimate business interests, including profiling; or
2. carried out for research or statistical purposes.
You also have the right to object to the processing of your personal data for direct marketing purposes, including profiling.
Right to withdraw consent. Where we rely on your consent to process your personal information, for example for sales and marketing communications, you may withdraw your consent at any time. We aim to make this simple by including an unsubscribe option in every communication we send. If this is not available, please contact our Data Protection Officer at [email protected], and we will address the issue promptly.
Rights related to automated decision-making, including profiling. We may use automated systems to make decisions based on your personal information. This allows us to ensure that decisions are made efficiently, consistently, and accurately using the data available to us. Such automated decisions may influence the products, services, or features offered to you now or in the future, as well as your ability to access our services.

We may apply automated decision-making in the following cases:

tailoring products and services – we may place you into groups with similar customers to analyze preferences and needs, allowing us to provide a more personalized experience;
fraud detection – we use your personal information to assess and identify whether your account may be involved in fraud or money laundering. If a risk is identified, we may block or suspend the account;
account opening – when you create an account, we verify whether the product or service is suitable for you based on the information available to us. We also confirm that you meet the necessary requirements, such as age, residency, nationality, or financial status;
risk assessment related to your bets.

Data protection laws are designed to protect individuals from potential harm resulting from decision-making, including profiling, carried out without human involvement. You have the right not to be subject to a decision, including profiling, based solely on automated processing of your personal data where it produces legal effects or similarly significant effects on you.

Please note that this right does not apply where the processing is:

necessary for entering into or performing a contract with you; or
authorized by applicable law; or
based on your explicit consent.

Any requests related to this Section should be directed to our Data Protection Officer at [email protected].

We will respond to requests under this Section without undue delay and within one month of receiving the request. If necessary, this period may be extended by an additional one month, taking into account the complexity of the request and the number of pending requests. If we refuse your request, we will provide a clear explanation of the reasons.

If your request does not comply with data protection law requirements, we reserve the right to either: (a) charge a reasonable fee reflecting the administrative costs of providing the information or taking the requested action; or (b) decline the request.

8. SECURITY OF YOUR DATA AND CONFIDENTIALITY

We are dedicated to safeguarding the personal information you provide to us. We take all reasonable measures to ensure that any data collected through Ninewin is handled securely and in accordance with this Privacy Policy and strict data protection standards. To achieve this, we have implemented strong procedures and advanced technologies to protect your information from unauthorized access and misuse.
Our payment providers use encryption to protect your credit card details. To maintain the highest level of confidentiality, we cooperate only with trusted and reputable payment providers.
Our systems and applications undergo security testing multiple times each year by independent third-party security specialists. In addition, we operate an Intrusion Detection System that continuously monitors network traffic 24/7 to identify potential attacks or unauthorized access attempts.
We maintain a dedicated fraud prevention team and use advanced monitoring systems to detect and prevent suspicious activities, ensuring that Ninewin remains a secure environment for all players.
Any account suspected of suspicious activity will be temporarily suspended and thoroughly investigated. If you notice any unusual activity on your account, such as unrecognized transactions or unexpected balance changes, please contact us immediately.
ninewin.com uses SSL encryption to ensure the secure transmission of your data. We do not collect, store, or transfer your card details under any circumstances. All payment transactions are processed exclusively through the secure servers of our payment gateway providers.

9. COMPLAINTS

If you wish to submit a complaint regarding how we have handled your personal data, you may contact us for investigation by emailing our Data Protection Officer at [email protected].
If you are not satisfied with our response, or if you believe that your personal data is being processed unlawfully, you may file a complaint with your national data protection authority.

10. CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our operations or regulatory requirements, therefore you are encouraged to review it whenever you provide personal information to us. The date of the latest revision will be indicated on this page. If you do not agree with the updated terms, you should stop submitting personal information to ninewin.com and discontinue using our Services. By continuing to use our Services after changes take effect, you are considered to have accepted the updated Privacy Policy. You may delete your Ninewin account at any time. If significant changes are introduced, particularly those affecting how we use your personal data, we will provide a more prominent notice, which may include email notification. In such cases, you may be required to explicitly accept the changes before continuing to use the Services, and the changes will apply immediately upon your acceptance.

11. YOUR OBLIGATIONS

By using ninewin.com and providing your personal data, you confirm that all information supplied to Ninewin is true, accurate, and complete as requested. You are also responsible for notifying us of any changes to your personal information to ensure it remains current and accurate.
If you breach your obligations, or if we reasonably suspect that the information provided is false, incomplete, or otherwise inconsistent with Data Protection Law or this Privacy Policy, we reserve the right to refuse your registration, or to suspend or terminate your account immediately without prior notice. In such circumstances, you will not be entitled to any compensation resulting from the rejection, suspension, or termination.