Your Privacy, Our Legal Duty: The 1Win Kenya Data Protection Policy 🔒

At 1win Kenya, we view your privacy as an essential component of our service. This comprehensive policy outlines the specific ways we handle your personal information, ensuring complete adherence to the Data Protection Act, 2019 and all relevant financial compliance and Anti-Money Laundering (AML) regulations in Kenya. By using our platform, you confirm your acceptance of the measures described here, which are designed to create a secure, legal, and trustworthy betting environment.

Data Collection: The Principle of Necessity

We only collect and process the minimum amount of personal data required to operate a fully compliant and efficient online betting service.

Identity Verification and Account Setup (Legal Mandate)

This data is mandatory for "Know Your Customer" (KYC) checks and verification of age, as legally required for all regulated operators:

• Identification: Full legal name, date of birth, and the official number from your Kenyan National ID or Passport.
• Contact Information: Your primary mobile number (essential for mobile money services like M-Pesa), email address, and registered physical address.

Financial and Transactional Data (Tax & Audit)

This is processed for payment finalization, account auditing, and mandatory reporting to government bodies:

• Activity Logs: Detailed records of all deposits, withdrawals, specific wagers placed, payouts, and the automatic deduction of the required 20% Withholding Tax (WHT).
• Payment Details: The identifier (e.g., mobile number or bank details) of the payment instrument used for account funding and withdrawals.

Platform Usage and Technical Data (Service Optimization)

This information is gathered to enhance security, troubleshoot issues, and improve your user experience:

• Technical Identifiers: Unique IP address, device type, operating system, and browser version.
• Interaction Data: Time stamps of login/logout, page navigation flow, and performance metrics for our services.

The Legal Basis for Our Data Processing

We rely on clear legal justifications for every data processing activity:

Processing Purpose	Legal Basis (Under Kenyan Law)	Data Used
Service Provision (Account Management & Wagers)	Contractual Necessity	Identity, Contact, Transactional Data
Legal Compliance (AML, KYC, Tax Reporting)	Statutory Obligation	Identity, Financial, Technical Data
Platform Security (Fraud & Cheating Prevention)	Legitimate Interest	Technical, Usage, Identity Data
Promotional Offers (Marketing Communications)	Explicit Consent	Contact and Usage Data
Dispute Resolution (Customer Complaints & Legal Defence)	Legal Defence/Contractual Fulfillment	Transaction History, Correspondence

Note: Due to strict Kenyan gambling and financial legislation (including AML laws), certain processes like ID verification and transaction monitoring are legally required and cannot be opted out of. These mandates also determine the minimum time we must retain your data.

Strict Data Sharing Protocol

1Win operates under a zero-tolerance policy for selling user data. Your information is only shared when absolutely necessary and under strict confidentiality terms:

• Regulatory & Governmental Bodies: Mandatory sharing with the Betting Control and Licensing Board (BCLB), Kenya Revenue Authority (KRA), and the Financial Reporting Centre (FRC) for legal and audit compliance.
• Payment Processors: Disclosure of strictly necessary transactional details to M-Pesa, Airtel Money, and other banking partners to facilitate your fund transfers.
• Security Partners: Vetted third-party services used for verifying identity against global fraud and security databases.
• Judicial Orders: Compliance with legally binding warrants or court orders issued by an authorised Kenyan judicial or state agency.

Your Rights Under the Data Protection Act, 2019

As a Kenyan data subject, you are entitled to exercise the following robust rights:

Your Right	Our Obligation
The Right to be Informed	We must clearly and openly communicate our data practices (fulfilled by this policy).
The Right of Access	You may request a copy of the personal data we hold. We will provide this within the statutory timeframe (30 days).
The Right to Rectification	You can demand the correction or update of any inaccurate or incomplete data we have on file.
The Right to Object	You may opt out of receiving direct marketing messages at any time.
The Right to Deletion (Conditional)	While you can request account closure, we are legally compelled to retain core KYC and transaction records for a mandatory seven (7) year period after closure, as per Kenyan tax and AML requirements.
The Right to Complain	You are entitled to file a formal complaint with the Office of the Data Protection Commissioner (ODPC) in Kenya if you feel your rights have been breached.

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