ColdBet Privacy Policy – How We Handle Your Personal Data in Pakistan

1. Introduction

This Privacy Policy explains how ColdBet ("ColdBet", "we", "us", "our") collects, uses, stores, and protects the personal information of players and visitors on the ColdBet platform at coldbet.wine. It also explains your rights regarding your personal data and how you can exercise them.

ColdBet is committed to handling personal data responsibly and transparently. This Policy is part of our broader commitment to operating a trustworthy gaming platform for Pakistani players. It should be read alongside our Terms and Conditions, which govern your use of the platform as a whole.

By registering an account on ColdBet, making a deposit, or continuing to use the platform after being notified of updates to this Policy, you acknowledge that you have read and understood how your personal data is handled as described here.

2. Data Controller

For the purposes of this Privacy Policy, the data controller responsible for personal data collected through the ColdBet platform is ColdBet, operated at coldbet.wine. The data controller is the entity that determines the purposes and means by which personal data is processed.

If you have any questions about how ColdBet processes your personal data, or if you wish to exercise any of your data rights, you can contact the ColdBet Data Protection team directly via email at support@coldbet.wine. We will acknowledge your query within 24 hours and provide a substantive response within 30 days.

3. Personal Data We Collect

ColdBet collects the following categories of personal data depending on your interaction with the platform:

3.1 Registration Data

• Full legal name
• Date of birth
• Email address
• Phone number (Pakistani mobile number)
• Username and encrypted password
• Residential address

3.2 Identity Verification Data (KYC)

• Government-issued photo identification (CNIC, passport, or driving licence)
• Proof of address documentation
• Selfie or liveness check photograph (where required)
• Proof of payment method ownership

3.3 Financial and Transaction Data

• Deposit amounts, dates, and payment method references
• Withdrawal requests, amounts, and processing status
• Tokenised payment instrument identifiers (Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, card tokens)
• Account balance history

3.4 Gaming Activity Data

• Game history including bets placed, results, and timestamps
• Session duration and frequency data
• Responsible gaming tool usage (deposit limits set, self-exclusion periods)
• Bonus and promotion participation records

3.5 Technical and Device Data

• IP address at the time of login and transactions
• Device type, operating system, and browser version
• Session identifiers and authentication tokens
• Geographic location data derived from IP address

3.6 Communications Data

• Support chat transcripts and email correspondence with ColdBet
• Feedback and dispute records
• Survey responses (where voluntarily submitted)

4. How We Collect Your Data

ColdBet collects personal data through the following means:

• Directly from you: When you register an account, complete identity verification, make a deposit or withdrawal, contact support, or submit any form on the ColdBet platform.
• Automatically: When you visit or use the ColdBet platform, our servers automatically log technical data including your IP address, device information, session data, and browsing behaviour within the platform.
• From third-party service providers: ColdBet receives verification results from licensed KYC providers and fraud screening results from anti-fraud services. These providers share only the outcome of their checks, not raw data.
• From payment processors: When you make a deposit or withdrawal, ColdBet receives transaction confirmation data including tokenised payment references from Easypaisa, JazzCash, NayaPay, SadaPay, IBFT processors, and card networks.

5. Why We Use Your Personal Data

6. Legal Basis for Processing

ColdBet processes personal data on the following legal bases:

• Contract performance: Processing your registration data, financial data, and gaming activity is necessary to operate your ColdBet account and provide the services you have contracted for.
• Legal obligation: KYC verification, AML screening, and transaction record-keeping are required by applicable regulations and laws.
• Legitimate interests: Fraud detection, security monitoring, and platform improvement are carried out on the basis of ColdBet's legitimate interest in operating a secure and trustworthy platform. These activities are conducted in a way that does not disproportionately affect your privacy rights.
• Consent: Where ColdBet sends you direct marketing communications about promotions and offers, this is done on the basis of your consent. You can withdraw consent at any time by unsubscribing or by contacting support.

7. Sharing Your Personal Data

ColdBet does not sell, rent, or trade your personal data. Data is shared with third parties only where strictly necessary for the following purposes:

7.1 Licensed Service Providers

ColdBet works with a limited number of licensed third-party service providers who process data on our behalf. These include:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, IBFT network operators, and card processing networks – to execute your deposit and withdrawal transactions.
• KYC verification providers: Licensed identity verification services that process your identification documents to confirm your age and identity. These providers are contractually bound to handle your documents securely and delete them after the verification is complete.
• Fraud and AML screening services: To screen transactions and accounts for patterns consistent with fraud, money laundering, or other prohibited activity.
• Cloud hosting and infrastructure providers: ColdBet's platform is hosted on secure cloud infrastructure. Hosting providers have access to server data but are contractually prohibited from using it for any purpose other than providing the hosting service.

7.2 Regulatory and Legal Disclosure

ColdBet may disclose personal data to regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, legal process, or a binding order. ColdBet will notify you of any such disclosure where it is legally permissible to do so.

8. Payment Data Security

ColdBet handles PKR payment data with particular care given its sensitivity. The following technical measures are in place for all payment data on ColdBet:

9. Cookies and Tracking Technologies

ColdBet uses cookies and similar technologies to operate the platform, maintain your session, and improve the experience for Pakistani players. Here is what each type does:

9.1 Essential Cookies

These are required for the ColdBet platform to function. They manage your login session, security tokens, and game state. You cannot opt out of essential cookies while using ColdBet – they are strictly necessary for the service to work.

9.2 Functional Cookies

These remember your preferences on ColdBet such as language settings, last game played, and display options. They are not essential but they improve your experience. You can disable functional cookies through your browser settings without losing access to ColdBet's core features.

9.3 Analytics Cookies

ColdBet uses anonymised analytics data to understand how the platform is used – which pages load slowly, which features players use most, and where technical errors occur. This data is aggregated and cannot be used to identify individual players. No analytics data is shared with advertising networks.

9.4 No Third-Party Advertising Cookies

ColdBet does not use third-party advertising cookies, tracking pixels from social media platforms, or any technology that builds a profile of your behaviour for advertising retargeting purposes. Your browsing activity on ColdBet is not shared with external advertising systems.

10. Data Retention

ColdBet retains personal data for as long as necessary for the purpose it was collected and as required by applicable legal obligations. The following general retention periods apply:

• Account and registration data: Retained for the duration of your ColdBet account plus 5 years after account closure, to meet legal record-keeping requirements.
• KYC verification documents: Retained for 5 years from the date of verification or account closure, whichever is later, as required for AML compliance.
• Transaction records: Retained for 5 years from the date of each transaction.
• Game history records: Retained for 2 years from the date of each gaming session.
• Support communications: Retained for 2 years from the date of the communication.
• Technical log data: Retained for 90 days for security and fraud analysis purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any individual player. If you request deletion of your data, ColdBet will delete it to the extent permitted by its legal retention obligations.

11. Security Measures

ColdBet implements a range of technical and operational security measures to protect the personal data of Pakistani players:

• 256-bit SSL/TLS encryption on all platform connections
• Encrypted databases for storage of personal and financial data
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Audit logging of all access to personal and financial records
• Multi-factor authentication on internal systems used to manage player data
• Regular security reviews of platform infrastructure and code
• Incident response procedures in place for any potential data breach

In the event of a data breach that poses a risk to player rights, ColdBet will notify affected players as quickly as practicable and take immediate remediation steps. Notification will be sent to the email address registered on your ColdBet account.

12. Your Data Rights

As a ColdBet player, you have the following rights regarding the personal data the platform holds about you. To exercise any of these rights, contact ColdBet support at support@coldbet.wine with the subject line "Data Rights Request".

13. Children and Minors

ColdBet's platform is strictly for adults aged 18 and over. ColdBet does not knowingly collect personal data from individuals under 18. If a player is found to be under 18 during the registration or verification process, their account will be closed immediately and any balance forfeited in accordance with ColdBet's Terms and Conditions.

If you believe a minor has accessed ColdBet and provided personal data, please contact ColdBet support immediately. We will investigate and, if confirmed, delete the minor's data from our systems as quickly as possible.

ColdBet's responsible gaming tools include the ability to self-exclude and set strict deposit limits. Adults who are concerned about a minor in their household accessing online gaming platforms should use device-level parental controls in addition to ColdBet's platform controls.

14. Changes to This Privacy Policy

ColdBet reviews and updates this Privacy Policy periodically to reflect changes in our practices, legal requirements, or platform features. When material changes are made, ColdBet will:

• Update the "Last updated" date at the top of this page
• Send a notification email to all registered ColdBet players
• Display a prominent notice on the ColdBet platform for at least 14 days before the changes take effect

Your continued use of ColdBet after the effective date of any update constitutes your acknowledgement of the revised Policy. If you do not accept the changes, you should stop using the platform and contact support to arrange account closure.

15. Contact ColdBet About Privacy

For any question, request, or concern related to this Privacy Policy or the way ColdBet handles your personal data, please use the following contact options: