Privacy Policy

This Privacy Policy governs the collection, processing, storage, and protection of personal data by Win Sector N.V. (company ID 156833, registered at Kaya Seru Cueba 16, Curaçao; hereinafter — the Operator), which operates the website RajBet (hereinafter — the Site). By registering an account and using the Site, the User acknowledges that they have read, understood, and agreed to the terms set out in this Policy.

The Operator processes personal data in compliance with the requirements of its operating licence issued by Curaçao eGaming (Master Licence N.V. #365/JAZ) and applies data protection standards consistent with generally accepted international practices applicable to offshore gaming operators serving users in India.

1. Definitions

For the purposes of this Policy, the following terms have the meanings set out below:

• Personal Data — any information relating directly or indirectly to an identified or identifiable individual (the User).
• Processing — any operation performed on personal data, including collection, recording, storage, modification, retrieval, use, transfer, blocking, or deletion.
• User — any natural person who accesses or registers an account on the Site.
• Operator — Win Sector N.V., the legal entity responsible for personal data processing.
• KYC — Know Your Customer, the identity verification procedure required under the Operator’s licence obligations and anti-money laundering standards.

2. Data Collected

The Operator collects personal data that is necessary for the lawful provision of its services and the fulfilment of regulatory obligations. The categories of data collected include:

2.1 Registration and Account Data

• Full name;
• Date of birth (to verify that the User is at least 18 years of age);
• Email address;
• Country of residence;
• Username and encrypted password.

2.2 Identity Verification (KYC) Data

• Government-issued identity document (e.g. Aadhaar card, PAN card, passport);
• Proof of address;
• Selfie or liveness check image, where required.

2.3 Financial Data

• Payment method details (UPI ID, card details in tokenised form, e-wallet identifiers);
• Transaction history, including deposits and withdrawals;
• Source of funds documentation, where required by AML procedures.

2.4 Technical and Usage Data

• IP address and geolocation data;
• Device type, operating system, and browser information;
• Session logs, clickstream data, and activity on the Site;
• Cookies and similar tracking technologies (see Section 8).

2.5 Communication Data

• Content of communications with the support team via live chat or email;
• Records of complaint submissions and their resolution.

3. Legal Basis and Purposes of Processing

The Operator processes personal data on the following lawful bases and for the following purposes:

4. Data Sharing and Third-Party Disclosure

The Operator does not sell personal data to third parties. Personal data may be disclosed to the following categories of recipients solely to the extent necessary for the purposes described in Section 3:

• Payment processors and banking partners — to execute deposit and withdrawal transactions (including UPI providers, PayTM, Google Pay, Skrill, Neteller, and card schemes);
• Identity verification service providers — to perform KYC and document authentication procedures;
• IT infrastructure and hosting providers — operating under contractual data protection obligations;
• Anti-fraud and security vendors — for the purpose of detecting and preventing fraudulent activity;
• Regulatory and law enforcement authorities — where disclosure is required by applicable law, court order, or the Operator’s licence regulator (Curaçao eGaming);
• Cyprus-based subsidiary WIN SECTOR LTD — engaged in payment processing operations on behalf of the Operator.

All third-party recipients are required to handle personal data in a manner consistent with the protections described in this Policy and their contractual obligations with the Operator.

5. International Data Transfers

Given that the Operator is incorporated in Curaçao and uses internationally distributed infrastructure, personal data may be transferred to and processed in countries outside India. The Operator ensures that such transfers are subject to appropriate technical and contractual safeguards, including SSL encryption in transit and data processing agreements with service providers.

6. Data Retention

The Operator retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by the Operator’s regulatory obligations. Specific retention periods are as follows:

• Account and transaction records — retained for a minimum of five (5) years following account closure, in accordance with AML and licence obligations;
• KYC documentation — retained for the period required by Curaçao eGaming licence conditions;
• Support communications — retained for a period of three (3) years from the date of the last interaction;
• Technical and log data — retained for up to twelve (12) months, unless a longer period is required for security investigations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where a User requests account deletion, the Operator will close the account; however, transaction history and KYC records will be retained for the duration required by regulatory obligations, as confirmed in the Operator’s Terms and Conditions.

7. Data Security

The Operator implements technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between the User’s device and the Site;
• Encrypted storage of sensitive account and financial data;
• Access controls limiting data access to authorised personnel on a need-to-know basis;
• Anti-fraud monitoring systems and real-time transaction analysis;
• Identity verification procedures to prevent multiple or fraudulent registrations;
• Regular review of security practices in line with industry standards.

Notwithstanding the above, no method of electronic transmission or storage is entirely secure. Users are responsible for maintaining the confidentiality of their account credentials and must notify the Operator immediately upon suspecting unauthorised access to their account.

8. Cookies and Tracking Technologies

The Site uses cookies and similar tracking technologies to ensure the proper functioning of services, analyse usage patterns, and personalise the User’s experience. The following categories of cookies are used:

• Strictly necessary cookies — essential for the Site to function; these cannot be disabled;
• Analytical cookies — used to collect aggregated statistical information about how Users interact with the Site;
• Functional cookies — used to remember User preferences, such as language settings;
• Marketing cookies — used with the User’s consent to deliver relevant communications.

Users may manage cookie preferences through their browser settings. Disabling certain categories of cookies may affect the functionality of the Site. By continuing to use the Site without adjusting cookie settings, the User consents to the use of cookies as described above.

9. User Rights

Users have the following rights in relation to their personal data held by the Operator:

• Right of access — to request confirmation of whether personal data is being processed and to receive a copy of such data;
• Right to rectification — to request correction of inaccurate or incomplete personal data;
• Right to erasure — to request deletion of personal data where it is no longer necessary for the original purpose, subject to regulatory retention obligations;
• Right to restriction — to request that processing be limited in certain circumstances;
• Right to object — to object to processing carried out on the basis of legitimate interest, including for direct marketing purposes;
• Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, Users may contact the Operator’s support team by email at [email protected] or via the live chat available 24/7 on the Site. The Operator will respond to verified requests within a reasonable timeframe consistent with its operational and regulatory obligations.

10. Minors

The Site is strictly prohibited for persons under the age of 18. The Operator does not knowingly collect or process personal data of minors. If the Operator becomes aware that personal data of a person under 18 has been collected, such data will be deleted and the associated account will be closed immediately. If a User has reason to believe that a minor has registered on the Site, they should report this to the Operator via [email protected].

11. Responsible Gambling and Data Processing

In the context of responsible gambling obligations, the Operator may process behavioural and session data to monitor for indicators of problematic gambling patterns, enforce self-exclusion periods selected by the User, and apply account-level spending limits. Users who opt for self-exclusion (available for periods of 7, 30, 60, or 180 days) will have their accounts blocked accordingly, and data processed for this purpose will be retained to ensure the self-exclusion cannot be circumvented. Such processing is carried out on the basis of the Operator’s legitimate interest and licence obligations.

12. Promotional Communications

With the User’s consent provided at registration or subsequently, the Operator may send communications regarding promotions, bonuses, and platform updates. Users may withdraw consent to receive such communications at any time by contacting the support team or using any unsubscribe mechanism included in the communication. Withdrawal of consent will not affect the processing of data necessary for service provision.

13. Amendments to This Policy

The Operator reserves the right to update or amend this Privacy Policy at any time. Where material changes are made, the Operator will notify Users by posting the updated Policy on the Site and, where appropriate, by sending a notification to the email address registered with the account. Continued use of the Site following the publication of an updated Policy constitutes acceptance of the revised terms. Users are encouraged to review this Policy periodically.

14. Contact Information

For any questions, concerns, or requests relating to this Privacy Policy or the processing of personal data, Users may contact the Operator through the following channels:

• Email: [email protected]
• Live chat: available 24/7 via the widget on the Site
• Registered address: Win Sector N.V., Kaya Seru Cueba 16, Curaçao

Date of last revision: August 4, 2026