Trust and Transparency: Your Data at 1Win Kenya 🌟

Your privacy is paramount. This policy acts as our guarantee that your personal data will be managed securely, responsibly, and with complete transparency. We clearly define the data collection methods, the legal justification for each step, and our firm commitment to obeying the Data Protection Act, 2019, alongside all Kenyan Anti-Money Laundering (AML) and financial regulations. By accessing and using the 1Win Kenya platform, you agree to these protective measures, ensuring a secure environment for all users.

Data Collection: What Information We Obtain

We adhere strictly to the principle of necessity, gathering only the data essential for a compliant and efficient betting operation.

Registration and Personal Identification (Mandatory Verification)

This dataset is compulsory for Know Your Customer and age verification mandates:

• Core Personal Details: Your full name as per legal documents, date of birth, nationality, and the official number from your Kenyan National ID or Passport.
• Communication Channels: Your registered mobile number (crucial for M-Pesa/Airtel Money linkage), primary email address, and physical residential location.

Financial Records and Transactional Activity (Audit & Tax)

This information is required for accurate payment processing, account auditing, and governmental reporting:

• Transaction Summary: A complete record of all funds deposited, amounts withdrawn, specific bets placed, payouts received, and the automatic deduction of the mandatory 20% Withholding Tax (WHT).
• Payment Method Identification: Details confirming the mobile number, bank account, or other financial instrument used to facilitate funds transfers.

Platform Usage and Technical Logs (Service Improvement)

Data is collected anonymously to enhance system performance and user experience:

• Technical Environment: Your unique IP address, the type of device and operating system used, browser version, and an app-specific device identifier.
• Activity Metrics: Logged times of access, navigation flow through the site, frequency of feature usage, and metrics related to campaign performance.

The Lawful Basis for Data Processing

Every use of your data is supported by a defined legal or contractual justification:

• Contractual Fulfillment (Account & Payouts): Your Identity, Contact, and Transaction data are processed to deliver the agreed-upon service and manage the terms of your betting account.
• Legal Obligation (AML & Tax Reporting): We are compelled by Kenyan law (e.g., AML/POCAMLA and KRA mandates) to process Identity, Financial, and Technical data for compliance and statutory tax remittance.
• Legitimate Interests (Security & Integrity): We use Technical, Usage, and Identity data to protect our system and users from fraud, cheating, and technical misuse, upholding platform integrity.
• User Permission (Promotional Messages): Contact and Usage data are used for promotional communications only after securing your explicit, informed consent.
• Dispute Resolution (Legal Defence): Transaction History and Correspondence records may be used as necessary to address formal complaints or defend legal claims.

Note on Compliance: Strict adherence to Kenyan gambling and financial legislation means ID verification and transaction monitoring are non-derogable duties, dictating minimum data retention periods.

Data Sharing Protocol

We confirm our strict policy: We do not sell your personal data. Information is disclosed only to essential parties under confidentiality agreements or legal compulsion:

• Statutory Bodies: Required disclosure to regulatory agencies, including the BCLB (Betting Control and Licensing Board), KRA (Kenya Revenue Authority), and the FRC (Financial Reporting Centre) for legal and financial audit purposes.
• Financial Services: Sharing strictly necessary transaction details with partners like M-Pesa, Airtel Money, and banking institutions to ensure seamless fund processing.
• Fraud Prevention: Utilizing vetted, secure third-party services to check identity details against fraud databases.
• Judicial Mandate: Compliance with legally binding orders for data disclosure issued by a Kenyan court or authorized state agency.

Safeguarding Your Information: Our Security Measures

We invest heavily in technology and protocol to protect your funds and data:

• Secure Transmission: All sensitive data is protected during transfer using high-grade SSL/TLS encryption protocols.
• Internal Access Policy: Access to personal data is restricted to employees whose professional duties require it, enforced via a strict "need-to-know" principle.
• System Defence: Our infrastructure is protected by advanced firewalls and continuously monitored to identify and neutralize potential security vulnerabilities.

Data Retention Timeline

Statutory and regulatory requirements dictate how long we must keep your records:

• The 7-Year Rule: We are legally obligated to retain core KYC and transaction records for a minimum of seven (7) years following the date your account is closed, as mandated by Kenyan tax and AML legislation.
• Marketing Consent: All contact information used for marketing is immediately removed from active lists upon your request to withdraw consent.

Your Rights Under the Data Protection Act (Kenya)

You have powerful rights governing the handling of your data:

• The Right to Information: We must clearly and openly inform you about our data collection practices (as detailed herein).
• The Right of Access: You are entitled to request a copy of the personal data we hold about you. We commit to fulfilling this request within the legal timeframe (30 days).
• The Right to Correction: You can request that we update or rectify any incomplete or incorrect information stored on your file.
• The Right to Object: You can prohibit us from using your data for direct marketing at any time.
• The Right to Deletion (Conditional): While you can request account closure, we are legally required to keep core KYC/transaction data for the mandatory 7-year retention period due to statutory obligations.
• The Right to Complain: If you believe your rights have been violated, you are entitled to file a formal complaint with the Office of the Data Protection Commissioner in Kenya.

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