Data & Privacy

funcwin Privacy Policy — How We Handle Your Personal Data

At funcwin, we treat the privacy of every Bangladesh player with the utmost seriousness. This Privacy Policy explains in plain, formal English exactly what personal data we collect, why we collect it, how we use and protect it, and what rights you have over that data at every stage of your relationship with the Platform.

Effective: January 2026 SSL Encrypted Bangladesh Market English Language

Last Updated: 1 January 2026 | Version: 2.4 | This Policy is reviewed and updated at least once every 12 months, or earlier if required by changes to applicable law or Platform operations.

This Privacy Policy ("Policy") describes how funcwin ("Platform", "we", "us", "our") collects, processes, stores, and shares personal data relating to individuals who access or use the funcwin website, mobile platform, and all associated services (collectively, the "Services"). This Policy applies to all registered account holders and to any person who visits or interacts with the Platform regardless of whether they have created an account.

By using the Services, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must cease using the Platform immediately. Where your consent is required for a specific processing activity beyond the scope of legitimate interest or contractual necessity, we will seek that consent separately and explicitly before proceeding.

                Data Controller: funcwin acts as the data controller in respect of all personal data collected directly from users of the Platform. Questions, data access requests, and concerns relating to this Policy should be directed in writing to support@funcwin. We aim to respond to all privacy-related queries within 10 business days.
              

Privacy Principles at a Glance

The following cards outline our core privacy commitments. They are a summary only — the full policy text in each section below takes legal precedence.

Minimum Necessary Data

funcwin applies a data minimisation principle: we collect only the personal data that is strictly necessary for the specific purpose for which it is collected. We do not gather data for speculative future use. Every data field we request from you has a clearly defined and documented purpose.

Encryption & Secure Storage

All personal data held by funcwin is stored in encrypted form at rest using industry-standard AES-256 encryption. All data transmitted between your device and our servers is protected by TLS 1.2 or higher. Payment data (card numbers, bKash PINs) is never stored on our servers — processing is handled entirely by our certified payment partners.

No Selling of Personal Data

funcwin does not, and will never, sell your personal data to third- party marketers, data brokers, advertising networks, or any other commercial entity for monetary compensation. Your personal data is used solely to deliver, improve, and protect the Services you have chosen to use on funcwin.

Defined Retention Periods

We do not keep your personal data indefinitely. Each category of data is held for a defined retention period based on its purpose and applicable legal obligations. Once that period expires, data is securely deleted or anonymised. You may also request early deletion of your data subject to legal constraints.

Your Right to Control

You retain meaningful rights over your personal data at all times: the right to access, rectify, restrict processing, object to processing, and request deletion. These rights are exercisable free of charge by contacting us at support@funcwin. We will respond to all verified requests within the timeframes set out in this Policy.

Transparent Cookie Use

funcwin uses cookies and similar technologies solely for session management, platform performance, fraud prevention, and analytics. We do not deploy third-party advertising cookies or cross-site tracking pixels. Full details of cookie categories and their purposes are provided in the Cookies section of this Policy.

1. Information We Collect

funcwin collects personal data from you through several channels: directly when you register an account and use the Platform, automatically as you interact with our services, and in limited cases from verified third-party sources for identity and fraud-prevention purposes. The categories of data we collect are described below.

1.1 Registration and Account Data

When you create an account on funcwin, we collect the following information:

Full legal name — used for identity verification and account ownership.
Date of birth — used to verify that you meet the minimum age requirement of 18 years.
Email address — used for account communications, transaction receipts, and support correspondence.
Mobile phone number — used for two-factor authentication, payment method linkage (bKash, Nagad, Rocket, Upay), and security alerts.
Residential address — used for identity verification and regulatory compliance purposes.
Username and password (hashed) — used for account access. Your password is stored only in irreversibly hashed form; we cannot retrieve it in plain text.

1.2 Identity Verification (KYC) Documents

To comply with our Know Your Customer obligations and to process withdrawal requests, we may collect and temporarily store copies of the following documents:

Government-issued photo identification: National Identity Card (NID), passport, or driving licence.
Proof of residential address: a utility bill, bank statement, or official government correspondence dated within the last three months.
Payment method ownership evidence: screenshots or confirmation of the mobile financial service account registered in your name.

KYC documents are stored in encrypted form and are accessible only to authorised compliance personnel. They are deleted in accordance with the retention schedule in Section 5 of this Policy.

1.3 Financial Transaction Data

We record the details of all deposits and withdrawals made through your funcwin account, including the transaction amount in Bangladeshi Taka (৳), the date and time of the transaction, the payment method used (bKash, Nagad, Rocket, Upay, Visa, Mastercard), the transaction reference number, and the transaction status. We do not store full card numbers, CVV codes, or mobile banking PINs — these are processed exclusively by our PCI-DSS-compliant payment partners.

1.4 Gameplay and Betting Activity Data

We record your gameplay history on funcwin, including games played, bet amounts, win and loss records, session duration, and bonus usage history. This data is used to calculate account balances accurately, to detect problem gambling patterns, to support responsible gaming tools, and to investigate any disputes raised.

1.5 Technical and Device Data

When you access the Platform, our servers automatically record certain technical information, including:

IP address and approximate geographic location derived from IP.
Browser type, version, and operating system.
Device type (mobile, tablet, desktop) and device identifiers.
Pages visited, time spent on each page, and referring URL.
Session start and end times.

This technical data is used for platform security, fraud detection, performance optimisation, and aggregate analytics. It is not used to build personal advertising profiles.

1.6 Customer Support Communications

When you contact our support team by email or live chat, we retain a record of the correspondence including your name, contact details, the content of your message, and any resolution notes. These records are kept for quality assurance, training, and dispute resolution purposes.

Special Category Data: funcwin does not intentionally collect special category personal data (such as health information, racial or ethnic origin, religious beliefs, or political opinions) through the normal account registration process. If you voluntarily disclose such information — for example, in a responsible gaming self-exclusion request citing a specific health condition — that information will be treated with the highest level of confidentiality and will be used only for the specific purpose for which it was disclosed.

2. How We Use Your Data

funcwin processes your personal data only where a lawful basis for processing exists. The primary lawful bases we rely on are: performance of a contract (to provide the Services you have signed up for), compliance with a legal obligation (to meet KYC, AML, and age verification requirements), legitimate interests (to protect the Platform from fraud and to improve our services), and consent (for optional marketing communications, where you have explicitly opted in).

The following table summarises the principal purposes for which we use your personal data and the corresponding lawful basis:

Processing Purpose	Data Categories Used	Lawful Basis
Account creation and management	Registration data, device data	Performance of contract
Age and identity verification (KYC)	Registration data, KYC documents	Legal obligation
Processing deposits and withdrawals	Financial transaction data, registration data	Performance of contract
Fraud detection and AML monitoring	All data categories	Legal obligation / Legitimate interests
Responsible gaming monitoring	Gameplay data, registration data	Legal obligation / Legitimate interests
Customer support	Support communications, registration data	Performance of contract
Platform analytics and improvement	Technical data, gameplay data (aggregated)	Legitimate interests
Promotional communications (opt-in only)	Email address, gameplay preferences	Consent
Legal and regulatory compliance	All data categories (as required)	Legal obligation

Marketing Communications

funcwin will only send you promotional emails, SMS messages, or in-platform notifications about bonuses, new games, seasonal promotions (such as Eid or BPL season offers), and other marketing content if you have explicitly opted in to receive such communications during registration or via your account settings. You may withdraw this consent at any time by updating your notification preferences in your account dashboard or by emailing support@funcwin. Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to withdrawal and will not prevent us from sending you transactional communications (such as deposit confirmations and security alerts) that are necessary for the performance of our contract with you.

Automated Decision-Making: funcwin uses automated systems to screen accounts for fraud indicators, unusual betting patterns, and potential responsible gaming concerns. Where an automated system flags an account for review, a human member of our compliance team will review the flag before any material action (such as account suspension or withdrawal hold) is taken. You have the right to request human review of any automated decision that significantly affects you by contacting support@funcwin.

3. Data Sharing & Third Parties

funcwin does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your data only in the limited circumstances described below, and only to the extent necessary for the specified purpose.

3.1 Payment Processing Partners

To process deposits and withdrawals in Bangladeshi Taka, we share necessary transaction data with our certified payment partners: bKash, Nagad, Rocket, Upay, and the card network operators (Visa, Mastercard) and their associated acquiring banks. The data shared is limited to the information required to execute the specific transaction (such as your registered mobile number for a bKash transfer). These partners operate under their own privacy policies and are independently responsible for data they control.

3.2 Identity Verification Service Providers

funcwin may engage third-party identity verification services to assist with automated KYC checks, document authentication, and age verification. These providers process your name, date of birth, and document images on our behalf and are contractually prohibited from using that data for any purpose other than performing the verification service. All such providers are required to maintain data security standards equivalent to or exceeding those applied by funcwin.

3.3 Game Content Providers

Games on the funcwin platform are delivered by licensed third-party game studios including Pragmatic Play, Evolution Gaming, Spribe, Ezugi, NetEnt, and Microgaming. When you play a game, your account identifier and bet/win data are shared with the relevant game provider's server in real time to operate the game. Game providers receive only the minimum data necessary to deliver the game session — they do not receive your full identity or payment details.

3.4 Analytics and Platform Security Providers

We use reputable third-party providers to support platform analytics and cybersecurity monitoring. These providers may process technical and device data (such as IP address, session duration, and page interaction data) to help us understand aggregate platform usage and to detect and respond to security threats. All such providers are engaged under data processing agreements that restrict their use of the data to the contracted purpose.

3.5 Legal and Regulatory Disclosure

funcwin may be required to disclose personal data to law enforcement agencies, financial intelligence units, regulatory bodies, or courts of competent jurisdiction where required by applicable law, in response to a valid legal order, or where we reasonably believe such disclosure is necessary to prevent fraud, money laundering, or other serious criminal activity. In such cases, we will disclose only the minimum data required to satisfy the legal obligation, and we will notify you of such disclosure to the extent permitted by law.

                No Cross-Border Data Transfers to High-Risk Destinations: funcwin does not transfer your personal data to jurisdictions that do not maintain adequate data protection standards without first implementing appropriate safeguards, such as standard contractual clauses. Our primary data infrastructure is hosted in secure data centres maintaining ISO 27001 certification or equivalent security standards.
              

4. Cookies & Tracking Technologies

funcwin uses cookies and similar client-side storage technologies (such as local storage and session storage) to operate the Platform effectively. This section explains what types of cookies we use, their specific purposes, and how you can manage your cookie preferences.

A cookie is a small text file placed on your device by a website server. Cookies cannot execute programmes or deliver viruses. They are used to remember information about your session and preferences so the Platform can function correctly and efficiently.

Cookie Category	Purpose	Duration	Can Be Disabled?
Strictly Necessary	Session authentication, security tokens, load balancing, language preference	Session / up to 24 hours	No — required for Platform to function
Functional	Remembering your preferred game lobby view, deposit method preference, responsible gaming limit settings	Up to 90 days	Yes — disabling may reduce personalisation
Analytics	Aggregate page view counts, session duration, feature usage metrics — used to improve Platform performance	Up to 12 months	Yes — opt out via account settings
Fraud & Security	Device fingerprinting for fraud detection, bot prevention, duplicate account detection	Up to 12 months	No — required for platform security

funcwin does not use third-party advertising cookies, retargeting pixels, or social media tracking scripts. We do not participate in cross-site behavioural advertising networks.

Managing Your Cookie Preferences

You can manage functional and analytics cookies through your account settings page. You can also control cookies at the browser level by adjusting your browser's privacy settings to block or delete cookies. Please be aware that disabling strictly necessary or security cookies will impair your ability to use the Platform — in particular, you will not be able to remain logged in to your account.

Most modern browsers provide detailed guidance on cookie management in their respective help sections. Clearing your browser's cookie storage will log you out of your funcwin session and will remove any saved preferences, requiring you to re-enter them on your next visit.

5. Data Retention & Deletion

funcwin retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following retention schedule applies to the principal data categories we hold:

Data Category	Retention Period	Basis for Retention
Account registration data	Duration of account + 5 years after closure	Legal obligation (AML / financial record-keeping)
KYC identity documents	Duration of account + 5 years after closure	Legal obligation (KYC / AML regulations)
Financial transaction records	7 years from transaction date	Legal obligation (financial record-keeping)
Gameplay and betting history	Duration of account + 3 years after closure	Dispute resolution / responsible gaming
Customer support correspondence	3 years from last contact	Legitimate interests (quality assurance)
Technical / device logs	12 months from collection	Legitimate interests (security monitoring)
Marketing consent records	Until consent is withdrawn + 2 years	Legal obligation (consent record-keeping)
Closed account data (self-excluded)	Duration of self-exclusion + 5 years	Responsible gaming / legal obligation

At the end of the applicable retention period, personal data is either securely and permanently deleted from our systems or irreversibly anonymised such that it can no longer be associated with any identifiable individual. Anonymised data may be retained for aggregate statistical purposes beyond the retention periods listed above.

Account Closure and Data: Closing your funcwin account does not result in the immediate deletion of all personal data. As shown in the retention schedule above, we are required to retain certain categories of data — particularly financial records and KYC documents — for defined periods after account closure to comply with anti-money laundering regulations and financial record-keeping requirements. You may request confirmation of what data is held about you after account closure by contacting support@funcwin.

6. Security Measures

funcwin implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. While no online platform can guarantee absolute security, we apply the following controls as a baseline:

Transport Layer Security (TLS 1.2/1.3): All data transmitted between your browser or device and our servers is encrypted in transit using TLS. Any attempt to connect over unencrypted HTTP is automatically redirected to HTTPS.
AES-256 Encryption at Rest: Personal data held in our databases — including KYC documents, account details, and transaction records — is encrypted at rest using AES-256 symmetric encryption.
Password Hashing: Account passwords are stored exclusively in irreversibly hashed form using a modern adaptive hashing algorithm (bcrypt). We do not store passwords in plain text or reversible encrypted form under any circumstances.
Two-Factor Authentication (2FA): We encourage all account holders to enable 2FA via their account security settings. When enabled, a one-time code sent to your registered mobile number is required in addition to your password for account access.
Access Controls: Access to personal data within funcwin's internal systems is restricted on a need-to-know basis. Employees access only the data categories required for their specific role. All internal data access is logged and subject to periodic audit.
Penetration Testing: funcwin engages independent cybersecurity specialists to conduct penetration testing of our Platform infrastructure at least annually. Identified vulnerabilities are remediated on a risk-prioritised basis.
Incident Response: In the event of a data security incident that poses a risk to the personal data of users, funcwin will notify affected account holders by email within 72 hours of becoming aware of the breach, in accordance with applicable data protection standards. The notification will describe the nature of the breach, the data categories affected, and the steps we have taken in response.

You also play an important role in the security of your account. You are responsible for maintaining the confidentiality of your login credentials and for ensuring your registered email address and mobile number remain current. If you suspect that your account has been accessed without authorisation, you should change your password immediately and contact support@funcwin without delay.

7. Your Privacy Rights

As a user of funcwin, you hold the following rights in respect of your personal data. These rights are exercisable free of charge and may be invoked at any time by submitting a written request to support@funcwin. We will respond to all verified requests within 30 calendar days of receipt, or within 10 business days for straightforward requests.

Right of Access: You may request a copy of all personal data we hold about you, together with information about how it is being processed, the lawful basis for processing, the categories of data held, the retention period applied, and any third parties with whom it has been shared.
Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that it be corrected. You may also update certain account details (such as your email address or phone number) directly through your account settings dashboard.
Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (and no other lawful basis applies), or where the data has been processed unlawfully. This right is subject to our legal retention obligations — we cannot delete data we are required to retain by law.
Right to Restriction of Processing: You may request that we restrict the processing of your personal data in certain circumstances — for example, while you contest the accuracy of the data, or while a request for erasure is under consideration.
Right to Object: You may object to the processing of your personal data where we rely on legitimate interests as the lawful basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, or where the processing is necessary for legal claims.
Right to Withdraw Consent: Where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
Right to Human Review of Automated Decisions: Where a significant decision affecting your account has been made by an automated system, you have the right to request that the decision be reviewed by a human member of our compliance or customer support team.

                Identity Verification for Privacy Requests: To protect your personal data from unauthorised access requests, we are required to verify your identity before responding to any data subject rights request. We may ask you to confirm your registered email address, account username, and one additional piece of identifying information. We will not share your personal data with any party who cannot be verified as the account holder to whom the data relates.
              

If you are dissatisfied with our response to any privacy rights request, you have the right to escalate your complaint. In the first instance, we encourage you to contact our internal privacy team at support@funcwin to seek resolution. If the matter remains unresolved, you may escalate to the applicable data protection supervisory authority in your jurisdiction.

8. Policy Updates & Contact

funcwin reviews this Privacy Policy at least once every 12 months and updates it whenever there is a material change to how we collect, use, or protect personal data, or when required to do so by changes in applicable law or Platform operations. The "Last Updated" date at the top of this page reflects the date of the most recent revision.

When we make material changes to this Policy — that is, changes that significantly affect your rights or our data processing activities — we will notify all registered account holders by email to the address on file at least 14 days before the revised Policy takes effect. We will also display a prominent notice on the Platform for the same period. Minor clarifications and non-material corrections may be made without advance notice, and the updated Policy will be effective immediately upon publication.

Your continued use of the funcwin Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to the revised Policy, you must stop using the Platform and may request account closure by contacting support@funcwin.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, wish to withdraw marketing consent, or have a concern about how funcwin handles your personal data, please contact our privacy team using the following details:

Email: support@funcwin (plain text — not a clickable link)
Response Time: We aim to acknowledge all privacy-related enquiries within 2 business days and to provide a full response within 10 business days for standard requests, or within 30 calendar days for complex data subject rights requests.
Language: All privacy correspondence is handled in English.
Operating Hours: Our support team is available 24 hours a day, 7 days a week, 365 days a year, including Bangladesh public holidays.

Responsible Gaming and Data: If you are using our responsible gaming tools — such as deposit limits , session time limits, cooling-off periods, or self-exclusion — the data you provide in connection with those tools is treated with the highest level of confidentiality. It is used solely to enforce the restrictions you have requested and to support your wellbeing. It is never used for marketing profiling or shared with third parties except where required by law. For immediate responsible gaming support, contact us at support@funcwin.

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Your Data Is Protected — Now Enjoy the Platform

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