22win game Privacy Policy —
How We Collect, Use & Protect Your Data

Introduction

22win game is committed to maintaining the trust and confidence of every member in Pakistan and wherever else the platform is accessed. We recognise that the personal data you provide to us — whether during registration, payment processing, or platform use — represents a significant responsibility, and we take that responsibility seriously.

This Policy applies to all personal data collected through the 22win game website, mobile applications, customer support interactions, marketing communications (where consented to), and any other touchpoint through which you engage with the 22win game platform. It does not apply to third-party websites or services that may be referenced on or linked from the platform.

Data Controller

For the purposes of this Privacy Policy, 22win game is the data controller responsible for the personal information collected through the platform. As data controller, 22win game determines the purposes and means by which your personal data is processed.

If you have any questions or concerns regarding the handling of your personal data, or wish to exercise any of the rights described in Section 10 of this Policy, you may contact the 22win game Data Privacy team using the contact details set out in Section 15.

Personal Data We Collect

22win game collects personal data through several channels. The categories of data collected and the context in which they arise are set out in the table below:

22win game does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, biometric data for identification purposes, or health data, except where strictly required by applicable regulatory compliance obligations (for example, problem gambling self-exclusion programme coordination).

How We Use Your Personal Data

22win game uses the personal data collected for the following purposes:

• Account management: Creating, maintaining, and securing your 22win game member account, including authentication and fraud prevention.
• Service delivery: Processing deposits and withdrawals in PKR, settling bets and game winnings, and crediting bonus funds to your account in accordance with applicable promotion terms.
• Identity verification: Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations by verifying your identity before processing withdrawal requests above applicable thresholds.
• Platform improvement: Analysing aggregated and anonymised usage data to improve platform performance, game selection, and the overall member experience.
• Customer support: Responding to support enquiries, resolving disputes, and providing account assistance through WhatsApp, Telegram, live chat, and email channels.
• Marketing communications: Where you have provided consent, sending you promotional communications about 22win game bonuses, new game launches, and special offers. You may withdraw this consent at any time.
• Responsible gaming: Monitoring account activity to identify potential problem gambling indicators and proactively offering responsible gaming support tools where appropriate.
• Legal compliance: Meeting applicable regulatory, financial compliance, and law enforcement obligations where required by law.

Legal Basis for Processing

22win game processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms and Conditions you agreed to upon registration — including account creation, payment processing, and game operation.
• Legal obligation: Processing required to comply with applicable financial regulations, anti-money laundering laws, and other legally binding obligations, including KYC verification.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your fundamental rights.
• Consent: Processing for direct marketing communications, where you have provided explicit opt-in consent. This consent may be withdrawn at any time without affecting the lawfulness of prior processing.

Sharing Your Personal Data

22win game does not sell, rent, or trade your personal data to third parties for commercial gain. Your data may be shared with the following categories of recipients only where strictly necessary:

• Payment processors: Easypaisa, JazzCash, Raast, and banking partners (HBL, UBL, MCB Bank) receive the transaction reference data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and applicable financial data protection standards.
• Identity verification providers: Third-party KYC service providers who assist in verifying member identity documents for compliance purposes. These providers process data under strict data processing agreements with 22win game.
• Technology infrastructure providers: Cloud hosting, content delivery, and platform infrastructure providers who process data on 22win game's behalf under data processing agreements that impose equivalent data protection standards.
• Regulatory and law enforcement authorities: Where 22win game is legally required to disclose member information to a competent authority, regulator, or law enforcement body, we will comply with such legally binding requests.
• Professional advisers: Legal counsel, accountants, and auditors where disclosure is necessary for the provision of professional services, subject to professional confidentiality obligations.

Cookies and Tracking Technologies

The 22win game platform uses cookies and similar tracking technologies to enhance your experience, maintain session continuity, and analyse platform usage. The types of cookies used are as follows:

• Essential cookies: Required for the platform to function correctly, including session authentication, security tokens, and load balancing. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display configurations, to provide a more personalised experience.
• Analytical cookies: Used to collect anonymised, aggregated information about how members interact with the platform — including pages visited, session duration, and navigation paths — to help us improve the service.
• Security cookies: Used to detect fraudulent login attempts, bot activity, and unusual account behaviour patterns as part of our account security framework.

You may manage cookie preferences through your browser settings. Note that disabling certain cookie categories may impair the functionality of the 22win game platform.

Data Retention

22win game retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, subject to any legal or regulatory retention obligations. Indicative retention periods are as follows:

• Active account data: Retained for the duration of your active membership on the 22win game platform.
• Transaction and financial records: Retained for a minimum of 5 years following the relevant transaction, in compliance with applicable financial record-keeping requirements.
• Identity verification documents: Retained for a minimum of 5 years following account closure or the completion of the relevant KYC process, whichever is later.
• Customer support records: Retained for up to 3 years from the date of the interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for a period of up to 3 years following withdrawal of consent, to demonstrate compliance with marketing consent obligations.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 22win game's data disposal procedures.

Security Measures

22win game implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• AES-256 SSL encryption for all data in transit between your device and the 22win game platform.
• Encrypted storage of sensitive data at rest, including password hashes using industry-standard bcrypt or equivalent algorithms.
• Two-factor authentication (2FA) available to all members and enforced for platform administrator accounts.
• Real-time intrusion detection and automated alerting for unusual login patterns and potential account compromise events.
• Regular penetration testing and security audits conducted by qualified independent security professionals.
• Strict internal access controls ensuring that only authorised 22win game personnel with a genuine operational need can access member personal data.
• Staff data protection training and security awareness programmes.

While 22win game takes all reasonable measures to protect your data, no internet-based service can guarantee absolute security. You are responsible for maintaining the security of your own account credentials and for notifying 22win game promptly if you suspect any compromise.

Your Data Rights

As a 22win game member, you hold the following rights in relation to your personal data:

• Right of access: You may request a copy of the personal data 22win game holds about you at any time. We will respond to access requests within 30 days.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. Account details can be updated directly through your member dashboard.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to 22win game's legal and regulatory retention obligations.
• Right to restrict processing: You may request that we limit the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data.
• Right to data portability: Where processing is based on your consent or the performance of a contract, you may request your data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You have the right to object to processing based on legitimate interests, including profiling for responsible gaming monitoring purposes.

To exercise any of these rights, please contact the 22win game Data Privacy team at the contact details provided in Section 15. We may require identity verification before processing data rights requests to protect member privacy.

Children's Privacy

The 22win game platform is strictly intended for adults aged 18 and above. We do not knowingly collect, process, or store personal data from individuals under the age of 18. If we become aware that a member account has been registered by a person under the minimum age, the account will be closed immediately and any associated data will be deleted in accordance with our data disposal procedures.

If you have reason to believe that a minor has registered a 22win game account, please contact the support team immediately so that appropriate action can be taken.

Marketing Communications

22win game may send you promotional communications about bonuses, new game launches, seasonal promotions, and platform updates, but only where you have provided explicit opt-in consent to receive such communications during registration or through your account settings.

Marketing communications are sent via the mobile number or email address associated with your account. Each marketing message includes a clear and straightforward opt-out mechanism. You may also withdraw consent to marketing communications at any time by updating your communication preferences in your member account dashboard or by contacting the support team.

Withdrawing consent to marketing communications will not affect your ability to use the 22win game platform or receive essential transactional communications such as deposit confirmations, withdrawal notifications, and account security alerts.

Third-Party Links

The 22win game platform may contain references to third-party content providers, game studios, or payment providers. This Privacy Policy applies solely to data collected and processed by 22win game through the platform. Third-party services operate under their own privacy policies, and 22win game accepts no responsibility for the data practices of third-party providers.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the 22win game platform, particularly payment providers such as Easypaisa and JazzCash when completing transactions.

Changes to This Privacy Policy

22win game reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or platform functionality. Where material changes are made to this Policy, registered members will be notified via the contact details associated with their account at least seven days prior to the revised Policy taking effect.

The "Last updated" date at the top of this Policy reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how 22win game protects your personal data. Continued use of the platform following the effective date of any revision constitutes your acceptance of the updated Policy.

Contact — Data Privacy Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or to the handling of your personal data by 22win game, please contact the Data Privacy team through any of the following channels:

• Email: [email protected] — please include "Privacy Enquiry" in the subject line. We aim to respond within 5 business days.
• Live Chat: Available 24/7 through the live chat widget on the 22win game platform — ask to be connected to the Data Privacy team for sensitive enquiries.
• WhatsApp & Telegram: Contact details available within your member account dashboard following login.

For formal written data subject access requests or erasure requests, please contact us via email with appropriate identity verification. We will acknowledge formal requests within 3 business days and respond in full within 30 days.