22wln Privacy Policy – How We Handle Your Data in Pakistan

01 Who We Are

22wln operates the online gaming and sports betting platform available at 22wln.app and through the 22wln mobile application. As the operator of this platform, 22wln is the data controller responsible for the personal information collected from Pakistan players who register and use our services.

This Privacy Policy applies to all personal data collected through the 22wln website, mobile app, live chat, email communications, and any other channel through which players interact with us. It should be read alongside our Terms and Conditions which govern your use of the platform more broadly.

02 Personal Data We Collect

The personal data we collect from Pakistan players falls into the following categories:

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, or health information unless specifically required by applicable legal obligations.

03 How We Collect Your Data

22wln collects personal data through the following methods:

• Directly from you: When you register an account, make a deposit or withdrawal, contact support, submit verification documents, or respond to communications from us.
• Automatically through the platform: When you use the website or app, certain technical data is collected automatically including your IP address, device information, and activity logs.
• From third parties: Identity verification providers and payment processors may share data with us as part of transaction processing or identity checks. This data is used solely for the purposes described in this policy.

04 How We Use Your Personal Data

The personal data we hold is used for specific, defined purposes. We do not use your data for purposes unrelated to providing and improving the 22wln platform.

• Account management: To create and maintain your 22wln account, process your registration, and manage your login credentials and preferences.
• Payment processing: To process PKR deposits via JazzCash, Easypaisa, Raast, Bank Transfer, and other supported channels, and to process withdrawal requests back to verified payment methods.
• Identity verification: To verify your age, identity, and payment method ownership as required before processing withdrawals or fulfilling certain bonus offers.
• Fraud prevention and security: To detect and prevent fraudulent activity, money laundering, or other misuse of the platform, and to protect the integrity of accounts and transactions.
• Responsible gaming: To monitor play patterns where this is necessary to support responsible gaming tools such as deposit limits or self-exclusion, and to act on requests for account restrictions.
• Customer support: To respond to your queries, resolve complaints, and improve the support experience based on interaction history.
• Platform improvement: To analyse aggregated usage patterns and improve the performance, design, and features of the platform for Pakistan players.
• Legal compliance: To meet record-keeping, reporting, and other obligations that apply to online gaming operators.

05 Legal Basis for Processing

22wln processes your personal data on the following legal bases:

• Contract performance: Processing necessary to fulfil the obligations in our Terms and Conditions — including running your account, processing transactions, and providing access to games and sports betting.
• Legal obligation: Processing required to comply with applicable legal obligations including identity verification, fraud prevention, and financial record-keeping.
• Legitimate interests: Processing where 22wln has a legitimate interest that is not overridden by your rights — including fraud detection, platform security, and service improvement through anonymised analytics.
• Consent: Where we rely on your consent for a specific processing activity, you have the right to withdraw that consent at any time by contacting support.

06 Sharing Your Personal Data

22wln does not share your personal data with third parties except in the following limited circumstances:

• Payment processors: JazzCash, Easypaisa, Raast, banks, and other payment service providers receive transaction data necessary to process deposits and withdrawals in PKR.
• Identity verification providers: Third-party KYC services may receive identity documents and personal details to complete age and identity verification checks. These providers act under strict data processing agreements with 22wln.
• Game software providers: Casino and live casino game providers may receive session data necessary to operate their games within the 22wln platform. This is limited to what is technically required for game operation.
• Legal and regulatory authorities: We may share personal data with law enforcement or regulatory bodies where required by applicable law, court order, or legal process.
• Fraud prevention services: Anonymised or pseudonymised data may be shared with fraud detection services to protect the platform against fraudulent activity and money laundering.

All third parties with whom 22wln shares personal data are required to handle that data securely and in accordance with applicable privacy obligations. We do not permit third parties to use your personal data for their own independent marketing purposes.

07 Payment Data Handling

22wln takes payment data security particularly seriously given that Pakistan players transact in PKR through mobile wallets and bank channels that are part of everyday financial life.

When you make a deposit via JazzCash, Easypaisa, or Raast, your payment credentials are handled by the relevant payment processor — they are not stored on 22wln's servers in full. 22wln receives confirmation of a successful transaction and records the transaction amount and method for account and withdrawal purposes.

For bank transfer deposits and withdrawals, we collect the account details necessary to process the specific transaction. These details are retained in accordance with our data retention policy and used only for transaction processing and verification purposes.

If you believe any payment-related data held in your account is incorrect, contact support and we will review and correct it promptly.

08 Cookies and Tracking Technologies

The 22wln website and mobile app use cookies and similar technologies to operate and improve the platform. These include:

• Essential cookies: Required for the platform to function — maintaining your login session, remembering your preferences, and ensuring secure operation. These cannot be disabled without affecting platform functionality.
• Analytics cookies: Used to understand how players navigate and use the platform, in aggregate and anonymised form. This helps us identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unusual access patterns.

Most browsers allow you to manage or block cookies through their settings. Blocking essential cookies will affect your ability to log in and use the platform normally. Blocking analytics cookies will not affect your ability to access any features.

The 22wln mobile app uses similar session and analytics technologies appropriate to the mobile environment, which can be managed through your device's app settings where applicable.

09 How Long We Keep Your Data

22wln retains personal data only for as long as necessary for the purposes described in this policy, and subject to applicable legal retention obligations.

• Active account data: Retained for the lifetime of your account and for a period after account closure to comply with financial and legal record-keeping requirements.
• Transaction records: Financial transaction records including PKR deposits and withdrawals are retained for a minimum of five years following the transaction date in line with standard financial record obligations.
• Verification documents: Identity and payment verification documents are retained for the period required by applicable compliance obligations, typically five years following account closure.
• Support communications: Live chat transcripts and email correspondence are retained for a period sufficient to resolve disputes and improve support quality.
• Analytics data: Anonymised and aggregated analytics data may be retained indefinitely as it no longer constitutes personal data.

When retention periods expire, data is securely deleted or irreversibly anonymised. You may request early deletion of your personal data subject to our legal retention obligations — see the section on your rights below.

10 Your Rights Over Your Personal Data

As a 22wln player, you have the following rights regarding your personal data:

• Right of access: You can request a copy of the personal data 22wln holds about you. We will respond within a reasonable timeframe.
• Right to rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request that it be corrected. You can update basic account details directly through your account settings, or contact support for other corrections.
• Right to erasure: In certain circumstances, you can request that we delete your personal data. Note that this right is subject to our legal obligations to retain certain records — we cannot delete transaction data that is required for financial compliance purposes.
• Right to restrict processing: You can request that we limit how we process your data in certain circumstances, for example while a correction request is being resolved.
• Right to object: You can object to processing carried out on the basis of legitimate interests. We will consider and respond to such objections.
• Right to withdraw consent: Where processing is based on your consent, you can withdraw that consent at any time without affecting the lawfulness of processing that took place before withdrawal.

To exercise any of these rights, contact 22wln support via live chat or email at [email protected] (plain text — not a clickable link). We will respond to rights requests in a timely manner and may need to verify your identity before processing the request.

11 Children's Privacy

The 22wln platform is strictly for adults aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has created an account on the platform, please contact support immediately. Any account found to belong to a person under 18 will be closed and their data deleted in accordance with this policy.

Parents and guardians who are concerned about underage access to online gaming platforms should make use of the parental control and content filtering tools available on their household devices and broadband services.

12 Security Measures

22wln implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, disclosure, or destruction. These include:

• Encrypted transmission of data between your device and the platform using HTTPS / TLS
• Secure server infrastructure with access controls and monitoring
• Role-based internal access controls so that only staff with a specific need can access personal data
• Regular security assessments and updates to address emerging threats
• Two-factor authentication available on player accounts for additional login security

No online platform can guarantee absolute security — internet transmissions carry inherent risks. However, 22wln takes all reasonable steps to maintain a secure environment for Pakistan players' personal and financial data. If you suspect your account has been compromised, contact support immediately and change your password.

13 Updates to This Privacy Policy

22wln may update this Privacy Policy from time to time to reflect changes in how we operate, changes to applicable legal requirements, or improvements to our data practices. When material changes are made, we will notify you through the platform or via email to your registered address.

The "Last updated" date at the top of this page reflects the most recent revision. We encourage you to review this policy periodically. Continued use of the platform after an updated policy takes effect constitutes your acceptance of the revised terms. If you do not agree with an update, you should stop using the platform and contact support to discuss account closure.

14 Contact Us About Privacy

If you have questions about this Privacy Policy, how 22wln handles your personal data, or wish to exercise any of your data rights, you can reach us through:

• Live Chat: Available within the 22wln platform 24 hours a day, 7 days a week
• Email: [email protected] (plain text — not a clickable link)

When contacting us about a data rights request, please include your registered account email and a brief description of your request. We may need to verify your identity before processing access, correction, or deletion requests.

For responsible gaming queries including self-exclusion requests, visit the Responsible Gaming page or mention it when contacting support — these requests are handled with priority.