Privacy policy

1. INTRODUCTION

WST Global Solutions LTD, operating as Winnersofts (“we,” “us,” “our,” or “Company”), is committed to processing your personal data in accordance with applicable data protection laws. This Privacy Policy governs the collection, use, storage, and disclosure of personal information in connection with our iGaming platform, including but not limited to Black Label, White Label, Casino Engine, and all current and future products, services, and features we may develop, acquire, or offer.

By accessing our platform, creating an account, or using any of our services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and consent to the processing of your personal data as described herein.

2. DATA CONTROLLER

Company Name: WST Global Solutions LTD

Trading As: Winnersofts

Contact Email: admin@winnersofts.com

IMPORTANT: All inquiries, requests, complaints, and correspondence regarding this Privacy Policy, your personal data, or exercising your rights must be directed exclusively to admin@winnersofts.com. We reserve the right to verify your identity before processing any requests.

3. INFORMATION WE COLLECT

3.1 Personal Identification Information

We collect and process the following categories of personal data:

Full legal name, date of birth, place of birth, gender, and nationality
Residential address (current and historical)
Email address, telephone number, and other contact information
Government-issued identification documents (passport, driver’s license, national ID)
Photographs, scanned documents, and biometric data for verification purposes
Tax identification numbers and social security numbers (where applicable)
Proof of address and source of funds documentation

3.2 Financial and Transactional Data

Payment method details (credit/debit card numbers, bank account information, e-wallet identifiers)
Complete transaction history (deposits, withdrawals, transfers, refunds)
Transaction amounts, timestamps, currencies, and payment processor data
Cryptocurrency wallet addresses and blockchain transaction records
Financial verification documents and banking correspondence

3.3 Account and Gaming Activity Data

Username, account credentials, and authentication information
Complete gaming history (bets placed, games played, wins, losses, outcomes)
Account balance, wagering patterns, and gameplay preferences
Bonus usage, promotion participation, and loyalty program activity
Responsible gaming settings and behavioral indicators
VIP status, player segmentation data, and profiling information

3.4 Technical and Usage Data

IP address, geolocation data (country, region, city, coordinates)
Device information (type, model, operating system, hardware identifiers, MAC address)
Browser type, version, language, time zone, and screen resolution
Cookies, web beacons, pixels, local storage, and tracking technologies
Session duration, login timestamps, clickstream data, and navigation patterns
System logs, error reports, crash diagnostics, and performance metrics
Network connection details and internet service provider information

3.5 Communication and Support Data

Customer support inquiries, tickets, emails, and live chat transcripts
Phone call recordings and voice data (where permitted by law)
Social media interactions, comments, and public communications
Survey responses, feedback, reviews, and testimonials
Complaint records and dispute resolution documentation

3.6 Marketing and Behavioral Data

Marketing preferences, communication opt-ins, and consent records
Response rates to campaigns, promotional engagement, and conversion data
Behavioral profiling, segmentation data, and predictive analytics
Affiliate source, referral information, and acquisition channel data
A/B testing participation and experiment results

4. HOW WE USE YOUR INFORMATION

We process your personal data for the following purposes, based on one or more lawful bases under applicable data protection law:

4.1 Service Provision and Business Operations

Account creation, verification, management, and authentication
Processing transactions, deposits, withdrawals, and payment operations
Providing access to gaming services, betting platforms, and all current and future features
Managing bonuses, promotions, tournaments, loyalty programs, and VIP services
Customer support and dispute resolution
Platform optimization, system maintenance, and performance improvement

4.2 Legal, Regulatory, and Compliance Obligations

Age verification and prevention of underage gambling
Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance
Counter-terrorist financing and sanctions screening
Compliance with gaming licenses, regulatory requirements, and government mandates
Tax reporting and revenue compliance
Record retention for statutory and audit purposes
Cooperation with law enforcement, judicial authorities, and regulatory bodies

4.3 Security, Fraud Prevention, and Risk Management

Detecting and preventing fraud, collusion, bonus abuse, and account takeover
Monitoring for suspicious transactions, money laundering, and illegal activities
Cybersecurity threat detection and prevention
Investigation of Terms and Conditions violations
Protection of our systems, assets, and intellectual property
Sharing data with sports integrity organizations and anti-fraud networks

4.4 Marketing, Personalization, and Business Development

Sending promotional communications (email, SMS, push notifications, in-app messages)
Creating personalized offers, recommendations, and tailored experiences
Player segmentation, profiling, and behavioral analysis
Conducting market research, surveys, and customer satisfaction studies
Developing new products, services, and features
A/B testing and optimization of user experience

4.5 Analytics and Automated Decision-Making

Analyzing platform usage, player behavior, and business performance
Automated fraud detection and risk scoring
AI-driven responsible gaming monitoring and intervention triggers
Chatbot interactions and automated customer support
Predictive modeling for business intelligence

4.6 Legal Claims and Business Transactions

Establishing, exercising, or defending legal claims and disputes
Facilitating mergers, acquisitions, business sales, or restructuring
Protecting our legitimate business interests

LEGAL BASIS FOR PROCESSING: We process your personal data based on (i) your consent, (ii) performance of our contract with you, (iii) compliance with legal obligations, (iv) our legitimate business interests, or (v) other lawful bases permitted by applicable law. Where we rely on legitimate interests, we have determined that our interests do not override your fundamental rights and freedoms.

5. DATA SHARING AND DISCLOSURE

We may share your personal data with the following categories of recipients for the purposes described in this Policy:

5.1 Service Providers and Business Partners

Payment processors and financial institutions: For transaction processing and payment services
Game providers and software developers: For gaming content delivery
Identity verification and KYC/AML service providers: For compliance checks
Cloud hosting and infrastructure providers: For data storage and platform operations
Marketing and analytics platforms: For campaign management and data analysis
Customer support and CRM systems: For service delivery
Cybersecurity and fraud prevention vendors: For security monitoring
Email, SMS, and communication service providers: For message delivery
Affiliate networks and marketing partners: For acquisition and referral tracking
Other third-party service providers: As necessary for business operations

5.2 Regulatory Authorities and Law Enforcement

Gaming regulators and licensing authorities
Financial intelligence units (FIUs) and anti-money laundering agencies
Tax authorities and government revenue bodies
Law enforcement agencies and judicial authorities
Sports integrity organizations and anti-corruption bodies
Data protection supervisory authorities

5.3 Corporate Transactions

In the event of a merger, acquisition, sale of assets, bankruptcy, or corporate restructuring, your personal data may be transferred to the acquiring entity or successor organization. Such transfers will be conducted in accordance with applicable law.

5.4 Legal Obligations and Rights Protection

We may disclose your personal data where required by law, court order, subpoena, or legal process, or where necessary to protect our legal rights, property, safety, or that of our users or third parties.

5.5 With Your Consent

We may share your data with other parties where you have provided explicit consent for such disclosure.

IMPORTANT: By using our services, you expressly consent to the sharing of your personal data with the recipients described above for the purposes outlined in this Policy. We reserve the right to share your data with additional third parties as necessary for our business operations, legal compliance, or legitimate interests.

6. INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to, stored, and processed in countries outside your jurisdiction, including countries that may not provide the same level of data protection as your home country. Such transfers are necessary for the provision of our services and the operation of our global business.

Where required by applicable law, we implement appropriate safeguards for international data transfers, which may include Standard Contractual Clauses, adequacy decisions, or other legally recognized transfer mechanisms.

By using our services, you expressly consent to the transfer of your personal data to any country where we or our service providers operate, regardless of the level of data protection in such jurisdiction.

7. DATA RETENTION

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests.

Data Category	Retention Period	Purpose
Account and identification data	Duration of account + 10 years after closure	Legal compliance, AML/KYC obligations
Financial transaction records	10 years from transaction date	Financial regulations, tax compliance, audit requirements
Gameplay and betting history	Duration of account + 10 years after closure	Regulatory obligations, dispute resolution, responsible gaming
Marketing and communication data	Until consent withdrawal + 3 years	Legal compliance, record-keeping
Customer support communications	Duration of account + 7 years after closure	Dispute resolution, service improvement, legal claims
Technical logs and system data	24-36 months	Security monitoring, fraud detection, system optimization
Legal claims and compliance records	10 years from resolution or as required by law	Legal proceedings, regulatory requirements

IMPORTANT: We may retain your data for longer periods where required by law, regulatory obligations, or our legitimate business interests, including but not limited to fraud prevention, dispute resolution, and protection of our rights. Deletion of data upon account closure is subject to these retention requirements.

8. DATA SECURITY

We implement commercially reasonable technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, alteration, or disclosure. These measures include:

SSL/TLS encryption for data transmission
Encrypted database storage for sensitive information
Firewalls and intrusion detection systems
Multi-factor authentication and access controls
Regular security audits and vulnerability assessments
Employee training on data protection and confidentiality
Secure backup and disaster recovery procedures

LIMITATION OF LIABILITY: While we strive to protect your personal data, no security system is impenetrable. We cannot guarantee absolute security and are not liable for unauthorized access, hacking, data breaches, cyberattacks, or other security incidents resulting from circumstances beyond our reasonable control, except where such liability cannot be excluded by law.

You are responsible for: Maintaining the confidentiality of your account credentials, using strong passwords, enabling two-factor authentication, not sharing your account with others, and logging out after each session.

9. YOUR RIGHTS AND CHOICES

Subject to applicable law and the limitations described below, you may have the following rights regarding your personal data:

9.1 Right of Access

You may request access to your personal data and information about how we process it.

9.2 Right to Rectification

You may request correction of inaccurate or incomplete personal data.

9.3 Right to Erasure (“Right to be Forgotten”)

You may request deletion of your personal data in certain circumstances.

IMPORTANT LIMITATIONS: We may refuse erasure requests where retention is necessary for: (i) compliance with legal or regulatory obligations (AML, KYC, tax, gaming regulations), (ii) establishment, exercise, or defense of legal claims, (iii) fraud prevention and security, (iv) protection of our legitimate business interests, or (v) any other purpose permitted by applicable law. In such cases, your data will be retained for the periods specified in Section 7.

9.4 Right to Restriction of Processing

You may request that we restrict processing of your personal data in limited circumstances.

9.5 Right to Data Portability

Where technically feasible and legally required, you may request a copy of your personal data in a structured, machine-readable format.

9.6 Right to Object

You may object to processing based on our legitimate interests or for direct marketing purposes.

MARKETING OPT-OUT: You can unsubscribe from marketing communications by clicking the “Unsubscribe” link in emails, texting “STOP” to SMS messages, or adjusting your account preferences. Note that you will continue to receive transactional and service-related communications even after opting out of marketing.

9.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

9.8 Automated Decision-Making

We use automated systems and AI for fraud detection, risk assessment, personalization, and responsible gaming monitoring. You may request human review of automated decisions where required by law.

9.9 Exercising Your Rights

To exercise any of these rights, contact us at admin@winnersofts.com. We will respond within the timeframes required by applicable law (typically 30 days). We reserve the right to:

Verify your identity before processing requests
Charge reasonable administrative fees for manifestly unfounded, excessive, or repetitive requests
Refuse requests that are unlawful, abusive, or not required by applicable law
Extend response times where necessary due to request complexity

DISPUTE RESOLUTION: If you are dissatisfied with our response to your request or believe we have violated your data protection rights, you may contact us at admin@winnersofts.com to resolve the matter. We are committed to addressing your concerns in good faith. Any disputes shall be resolved in accordance with Section 14 (Governing Law and Dispute Resolution) of this Policy.

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, web beacons, pixels, local storage, and similar tracking technologies to enhance user experience, analyze platform usage, personalize content, deliver targeted advertising, and improve our services.

Types of Cookies We Use:

Strictly Necessary Cookies: Essential for platform functionality, security, and account access
Performance Cookies: Analyze traffic, page load times, and user interactions
Functional Cookies: Remember your preferences (language, currency, display settings)
Marketing/Advertising Cookies: Track activity for personalized advertising and campaign optimization

You can manage cookie preferences through your browser settings or our cookie consent tool. However, disabling certain cookies may affect platform functionality.

Third-party cookies: Our platform may use third-party cookies from analytics providers (Google Analytics), advertising networks (Facebook Pixel), payment processors, and other service providers. These third parties have their own privacy policies governing cookie use.

11. CHILDREN AND UNDERAGE USERS

Our services are strictly prohibited for individuals under 18 years of age (or the legal gambling age in your jurisdiction, whichever is higher). We do not knowingly collect personal data from minors.

If we discover that we have inadvertently collected data from a minor, we will immediately suspend or delete the account, securely delete the associated data, and refund any deposits made by the minor (subject to our Terms and Conditions).

Report underage accounts to: admin@winnersofts.com

12. THIRD-PARTY WEBSITES AND SERVICES

Our platform may contain links to third-party websites, advertisers, affiliate partners, social media platforms, or external services that are not operated or controlled by us. We are not responsible for the privacy practices, content, security, or data processing activities of third-party sites.

This Privacy Policy applies only to personal data collected by WST Global Solutions LTD through our platform. We strongly recommend that you review the privacy policies of any third-party websites you visit.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify, update, or replace this Privacy Policy at any time, at our sole discretion, to reflect changes in our business practices, legal requirements, technological developments, new products or services, or for any other reason.

Notification of Changes:

Where changes are material and affect your rights or how we process your data, we will notify you by:

Email to your registered email address (at least 30 days before the changes take effect)
Prominent notice on our website or mobile application
In-app notifications upon login

Continued use of our services after the updated Privacy Policy takes effect constitutes your acceptance of the changes. If you do not agree with the updated Policy, you must immediately cease using our services and contact admin@winnersofts.com to close your account. Account closure is subject to our retention obligations outlined in Section 7.

Each version of this Policy will be dated and version-controlled. Previous versions are archived and available upon request.

14. GOVERNING LAW AND DISPUTE RESOLUTION

14.1 Governing Law

This Privacy Policy and all matters relating to your use of our services shall be governed by and construed in accordance with the laws of the jurisdiction in which WST Global Solutions LTD is registered and licensed, without regard to conflict of law principles.

14.2 Dispute Resolution and Arbitration

Any disputes, claims, or controversies arising out of or relating to this Privacy Policy, our processing of your personal data, or your use of our services shall be resolved as follows:

Informal Resolution: You agree to first contact us at admin@winnersofts.com to attempt to resolve the matter informally through good-faith negotiations for a period of at least 30 days.
Binding Arbitration: If informal resolution is unsuccessful, you agree that any dispute shall be resolved through final and binding arbitration conducted by a single arbitrator in accordance with the arbitration rules of the jurisdiction where WST Global Solutions LTD is registered. The arbitration shall be conducted in English, and the arbitrator’s decision shall be final and binding on all parties.
Waiver of Class Actions: You agree that any dispute resolution proceedings shall be conducted on an individual basis and not as a class action, consolidated action, or representative action. You waive any right to participate in a class action lawsuit or class-wide arbitration.
Jurisdiction and Venue: To the extent arbitration is not applicable or enforceable, you agree that any legal proceedings shall be brought exclusively in the courts of the jurisdiction where WST Global Solutions LTD is registered, and you consent to the personal jurisdiction of such courts.

YOUR RIGHTS UNDER LOCAL LAW: Nothing in this Section is intended to limit any mandatory rights you may have under applicable consumer protection or data protection laws that cannot be waived by agreement. However, to the maximum extent permitted by law, you agree to resolve disputes in accordance with the procedures outlined above.

14.3 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW:

WST Global Solutions LTD shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to this Privacy Policy, data processing activities, or security incidents, even if advised of the possibility of such damages.
Our total aggregate liability for all claims arising out of or related to this Privacy Policy or your personal data shall not exceed the lesser of: (i) the total amount you have deposited into your account in the 12 months preceding the claim, or (ii) €100 (one hundred euros).
We are not liable for data breaches, unauthorized access, cyberattacks, or security incidents resulting from circumstances beyond our reasonable control, including but not limited to force majeure events, third-party actions, your failure to secure your account credentials, or vulnerabilities in third-party services.

EXCEPTIONS TO LIMITATION OF LIABILITY: The above limitations do not apply to: (i) liability for death or personal injury caused by our negligence, (ii) liability for fraud or fraudulent misrepresentation, or (iii) any other liability that cannot be excluded or limited under applicable law.

14.4 Indemnification

You agree to indemnify, defend, and hold harmless WST Global Solutions LTD, its affiliates, directors, officers, employees, agents, and service providers from and against any claims, liabilities, damages, losses, costs, or expenses (including reasonable legal fees) arising out of or related to:

Your breach of this Privacy Policy or our Terms and Conditions
Your violation of any applicable laws, regulations, or third-party rights
Your fraudulent, negligent, or malicious conduct
Unauthorized access to your account resulting from your failure to secure your credentials
Any misrepresentation or false information provided by you

15. MISCELLANEOUS PROVISIONS

15.1 Entire Agreement

This Privacy Policy, together with our Terms and Conditions, constitutes the entire agreement between you and WST Global Solutions LTD regarding the processing of your personal data and supersedes all prior or contemporaneous understandings, agreements, representations, and warranties.

15.2 Severability

If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid provision shall be replaced with a valid provision that most closely reflects the intent of the original provision.

15.3 Waiver

Our failure to enforce any right or provision of this Privacy Policy shall not constitute a waiver of such right or provision. No waiver shall be effective unless made in writing and signed by an authorized representative of WST Global Solutions LTD.

15.4 Assignment

We may assign, transfer, or delegate our rights and obligations under this Privacy Policy to any third party without your consent, including in connection with a merger, acquisition, sale of assets, or corporate restructuring. You may not assign or transfer your rights or obligations under this Policy without our prior written consent.

15.5 Force Majeure

We shall not be liable for any failure or delay in performing our obligations under this Privacy Policy due to circumstances beyond our reasonable control, including but not limited to acts of God, natural disasters, pandemics, war, terrorism, cyberattacks, government actions, or failure of telecommunications or internet infrastructure.

15.6 Language

This Privacy Policy is written in English. In the event of any conflict between the English version and any translation, the English version shall prevail.

16. CONSENT AND ACKNOWLEDGMENT

By creating an account, using our services, or continuing to access our platform after the effective date of this Privacy Policy, you expressly acknowledge and agree that:

You have read, understood, and agree to be bound by this Privacy Policy in its entirety.
You understand how we collect, use, store, share, and process your personal data as described in this Policy.
You consent to the processing of your personal data for all purposes outlined in this Policy, including but not limited to account management, transaction processing, regulatory compliance, fraud prevention, marketing, personalization, analytics, and any other legitimate business purposes.
You consent to the international transfer of your personal data to any country where we or our service providers operate, regardless of the level of data protection in such jurisdiction.
You consent to the sharing of your personal data with third-party service providers, business partners, regulatory authorities, and other recipients as described in Section 5.
You understand and accept the data retention periods outlined in Section 7 and acknowledge that we may retain your data for longer periods where required by law or our legitimate business interests.
You acknowledge the limitations on your rights described in Section 9 and understand that we may refuse requests for data erasure, restriction, or portability where legally permitted.
You agree to resolve disputes in accordance with the arbitration and governing law provisions in Section 14.
You acknowledge the limitations of liability and indemnification provisions in Section 14.3 and 14.4.
You understand that your continued use of our services after any updates to this Privacy Policy constitutes your acceptance of such changes.

YOUR CONSENT IS VOLUNTARY. However, if you do not agree with this Privacy Policy or wish to withdraw your consent, you must immediately cease using our services and contact admin@winnersofts.com to close your account. Please note that certain processing activities may continue after account closure to the extent required for legal compliance or our legitimate interests.

CONTACT US

For all inquiries, requests, complaints, or questions regarding this Privacy Policy, your personal data, or exercising your rights, please contact:

WST Global Solutions LTD (Winnersofts)

admin@winnersofts.com

We will respond to all requests within the timeframes required by applicable law. Please allow up to 30 days for processing.