Privacy Policy of 15winapp

The 15winapp is the controller of personal data processed under this Privacy Policy. The platform operates the website 15winapp.best and all associated services — Sports Betting, Live Casino, crash games, slots, and account features — and is responsible for decisions regarding how users' personal data is collected, stored, used, and deleted.

For any questions regarding the processing of your data, you may contact 15winapp through the privacy channel indicated in section 13 of this policy. We respond to all requests within the timeframes established by the LGPD.

The 15winapp collects personal data at various points during your interaction with the platform. Below are the types of data collected and the circumstances in which this occurs:

The 15winapp does not collect unnecessary sensitive data such as racial origin, political opinions, health data, or facial biometrics, except where required by a specific regulatory verification process and with the user's explicit consent.

Each piece of data collected by 15winapp has a specific, declared purpose. We do not use personal information for purposes beyond those listed below without notifying the user and, where required, obtaining fresh consent:

• Account creation and management: Verifying the user's identity, keeping the account active, and ensuring that only one account is registered per CPF.
• Financial transaction processing: Process deposits via Pix, credit/debit card, boleto bancário, PicPay, Mercado Pago, and bank transfer (TED); process withdrawals to verified Brazilian bank accounts.
• Fraud and money laundering prevention: Monitor suspicious usage patterns and comply with AML/CFT (Anti-Money Laundering and Counter-Terrorism Financing) obligations under Brazilian law.
• User support: Answering questions, resolving disputes related to bets or payments, and maintaining support history.
• Platform improvement: Analyze usage patterns in aggregated and anonymized form to improve the 15winapp user experience.
• Account communications: Send notifications about account activity, processed withdrawals, security alerts, and important updates to the Terms and Conditions or this Privacy Policy.
• Responsible gambling: Identify behavioral patterns that may indicate problematic platform use and activate protective tools in accordance with 15winapp's responsible gambling policies.
• Marketing communications: Send promotions, bonuses, and platform updates — only with user consent and with the option to unsubscribe at any time.

The LGPD requires that all personal data processing have a legal basis. The 15winapp processes your personal data on the following legal bases set out in Law No. 13,709/2018:

• Contract performance: Processing is necessary to provide the services you agreed to when registering with 15winapp — account creation, bet processing, and payments.
• Compliance with a legal or regulatory obligation: Identity verification (KYC), anti-money laundering compliance, and retention of financial records as required by Brazilian law.
• Legitimate interest: Fraud prevention, platform security, and service improvement, provided this does not override the fundamental rights and freedoms of the data subject.
• Consent: Sending marketing communications and using non-essential cookies. Consent may be withdrawn at any time without affecting your use of the platform.

The 15winapp does not sell or transfer your personal data to third parties for commercial purposes. Data sharing takes place only in the situations described below, with partners who are contractually bound by the same data protection obligations as the platform:

• Payment processors: Financial institutions and payment intermediaries (banks, card operators, Pix gateways, PicPay, Mercado Pago) receive only the data strictly necessary to process the transaction.
• Game providers: Casino game, crash games, and slots providers (such as Spribe, Pragmatic Play, SmartSoft, and Evolution Gaming) may receive session identifiers to ensure games function correctly and to maintain round history.
• Identity verification services: KYC platforms contracted to verify documents and confirm user identity prior to withdrawal processing.
• Legal authorities: When required by law, court order, or a competent Brazilian regulatory authority, data may be shared without the prior consent of the data subject.
• Fraud prevention: Anti-fraud and anti-money-laundering organizations may receive information where there are indications of unlawful activity, in accordance with legal obligations.

The 15winapp uses cookies and similar technologies to ensure the platform functions correctly and to improve the user experience. There are two main types:

• Essential cookies: Required for the platform's basic operation — keeping your session active, remembering language preferences, and ensuring transaction security. These cannot be disabled without affecting your use of the platform.
• Analytics and performance cookies: Collect aggregated and anonymized data on how users navigate the platform. They help identify pages with issues and improve the overall experience. They require your consent.

By accessing the 15winapp for the first time, you will see a cookie notice with the option to accept, decline, or customize non-essential categories. You can change your cookie preferences at any time in your account settings. Declining non-essential cookies does not prevent you from using the platform.

The 15winapp does not use third-party cookies for targeted behavioral advertising without explicit consent.

The 15winapp implements technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or destruction. Key measures include:

• SSL/TLS Encryption: All communication between your device — whether an Android phone, iPhone, or computer — and 15winapp's servers is encrypted using SSL/TLS protocol.
• Secure storage: Sensitive financial data, such as credit card numbers, is tokenized and never stored in plain text. Pix keys are stored with restricted access controls.
• Two-factor authentication (2FA): Available to all platform users. We recommend enabling 2FA for additional account security.
• Continuous monitoring: 15winapp's systems are monitored to detect suspicious activity, unauthorized access attempts, and security anomalies.
• Restricted internal access: Only 15winapp staff with an operational need have access to users' personal data, and that access is monitored and audited.
• Regular security testing: The platform's infrastructure undergoes periodic vulnerability and penetration testing conducted by specialized firms.

The 15winapp retains your personal data for as long as necessary to fulfill the purposes stated in this policy or to meet legal obligations, as detailed below:

• Active account data: Retained for as long as the account remains active on the platform.
• Financial data and transaction history: Retained for a minimum of 5 years after the last transaction, as required by Brazilian tax and anti-money-laundering legislation.
• KYC data (identity documents): Retained for the period required by applicable regulatory standards, generally 5 to 10 years.
• Support communication records: Retained for up to 2 years after the support interaction is closed.
• Closed account data: After account closure, data is anonymized or deleted within 90 days, except for data subject to mandatory legal retention.

Once retention periods expire, data is securely deleted or anonymized so that the holder can no longer be identified. You may request early deletion of your non-mandatory data at any time, as outlined in the rights described in section 9.

The LGPD grants you, as the data subject, a set of rights regarding how your personal information is handled. The 15winapp respects and facilitates the exercise of all of them:

To exercise any of these rights, please contact the Data Protection Officer (DPO) of 15winapp via the privacy email listed in section 13. You may also contact the National Data Protection Authority (ANPD) directly if you feel your rights have not been adequately addressed.

The 15winapp is a platform strictly prohibited for users under 18 years of age. We do not intentionally collect personal data from minors and do not allow them to register or use any of the platform's services.

If you are the parent or guardian of a minor and believe they may have provided data to the 15winapp irregularly, please contact our support team immediately. We will close the account and delete all related data once the situation is confirmed, and return any unplayed deposit balance.

Some service providers used by 15winapp — such as casino game providers, crash games, and cloud infrastructure — may be located outside Brazil. Where personal data is transferred internationally, the 15winapp ensures that:

• The recipient country or organization provides an adequate level of personal data protection equivalent to that required by the LGPD;
• Standard data protection contractual clauses are implemented with international partners;
• Only the data strictly necessary for the provision of the specific service is transferred.

The 15winapp prioritizes storing data in Brazil whenever technically and economically feasible. Where international transfer is required, it will be carried out with appropriate safeguards in accordance with ANPD guidelines.

The 15winapp may send communications about promotions, bonuses, platform news, and sporting events of interest — such as Brasileirão matchdays, Libertadores fixtures, or new crash game launches — to users who have consented to this type of communication during registration or in their account settings.

You may opt out of marketing communications at any time:

• By accessing the notification settings in your account on 15winapp;
• Clicking the unsubscribe link in any marketing email sent by the platform;
• Contacting 15winapp support via live chat or email.

Opting out of marketing communications does not affect the receipt of essential account notifications — such as withdrawal confirmations, security alerts, and updates to this Privacy Policy.

The 15winapp has appointed a Data Protection Officer (DPO) as required by the LGPD. The DPO serves as the point of contact between the platform, data subjects, and the National Data Protection Authority (ANPD).

To exercise your rights as a data subject, report a privacy concern, or obtain more information about how your data is processed, please contact us through the channels below:

The 15winapp may update this Privacy Policy periodically to reflect changes in Brazilian law — including new ANPD guidelines —, in the platform's structure, or in data processing practices. All updates will be communicated with reasonable advance notice to your registered email and will be available on this page with the new effective date and version number.

We recommend reviewing this policy periodically. Continued use of the 15winapp after the effective date of any update constitutes acceptance of the new terms. If you disagree with any change, you may close your account and request a withdrawal of your available balance before the effective date.