22atm Privacy Policy — Your Data on Our Pakistan Platform

1 Introduction

22atm ("the Platform", "we", "us") is an online gaming and sports betting platform serving adult users in Pakistan. This Privacy Policy describes how we collect, process, store and protect personal data when you register an account, make a deposit in PKR, place a sports bet, play casino games or otherwise interact with the 22atm platform.

We take your privacy seriously. The data we collect is limited to what is genuinely needed to operate the platform, verify your identity, process your PKR transactions and comply with our responsible gaming obligations. We do not collect data for its own sake and we do not sell your information to advertisers or unrelated commercial parties.

This policy covers the 22atm website, the mobile app and all platform services offered under the 22atm brand. If you have questions about anything in this policy, you can contact us at [email protected].

2 Data We Collect

We collect personal data in a few different ways — directly from you when you register or use the platform, automatically when you interact with the site or app, and from third-party service providers as part of normal platform operations.

3 How We Use Your Data

We use the data we collect to run the platform properly and ensure a good experience for Pakistan users. The main purposes are listed below.

• Account Management: Creating and maintaining your account, processing logins and keeping your preferences saved.
• Transaction Processing: Handling PKR deposits via JazzCash, Easypaisa, Raast or Bank Transfer, and processing withdrawal requests to verified payment methods.
• Identity Verification: Confirming that account holders are adults aged 18 or above, and verifying identity for KYC compliance where required.
• Responsible Gaming: Monitoring account activity to detect patterns that may indicate problem gaming behaviour, and applying limits or restrictions accordingly.
• Fraud Prevention: Identifying suspicious transactions, detecting multi-account behaviour and protecting against unauthorised account access.
• Platform Improvement: Using aggregated, anonymised usage data to improve game performance, betting interfaces and overall user experience.
• Customer Support: Using your account history and communications to resolve queries and disputes efficiently.
• Marketing Communications: Sending promotional offers and platform updates to opted-in users. You can unsubscribe at any time from account settings.

4 Data Sharing

22atm does not sell your personal data. We only share data with third parties where it is necessary to operate the platform or meet our compliance obligations. The categories of parties we may share data with are listed below.

• Payment Processors: JazzCash, Easypaisa, Raast and banking partners receive transaction data necessary to process PKR deposits and withdrawals on your behalf.
• Game Providers: Providers like Pragmatic Play, Evolution and Spribe receive a session token and balance information when you launch a game. They do not receive your full identity data.
• Identity Verification Services: Third-party KYC providers may process identity documents to assist with age and identity verification. These providers operate under strict data processing agreements.
• Fraud Prevention Partners: Specialised fraud detection services may receive device and transaction data to help identify suspicious activity.
• Legal Obligations: We may disclose data if required to do so by a valid legal process, court order or other binding regulatory requirement.

5 Cookies & Tracking Technologies

22atm uses cookies and similar technologies to keep the platform working correctly, remember your preferences and understand how the site is being used. Cookies are small text files stored on your device by your browser.

• Essential Cookies: Required for the platform to function. These include session cookies that keep you logged in during your visit. Disabling these will prevent the platform from working correctly.
• Functional Cookies: Store your preferences such as language settings and game lobby filter selections so you don't have to reset them every session.
• Analytics Cookies: Help us understand which pages and features are most used so we can improve the platform. Data collected is aggregated and anonymised.
• Security Cookies: Used for fraud detection and to identify suspicious login attempts or unusual device activity.

You can manage cookie preferences through your browser settings. Most browsers allow you to see which cookies are stored and delete them individually or in bulk. Note that disabling essential cookies will affect your ability to use the platform normally.

6 Data Retention

We keep your personal data for as long as your account is active and for a reasonable period after account closure. Specific retention periods depend on the category of data.

• Account registration data is retained while your account is active. After account closure it is retained for a minimum period to allow dispute resolution and compliance review.
• Transaction records in PKR are retained for a minimum of five years from the date of the transaction for financial record-keeping purposes.
• Identity verification documents are retained for as long as required by compliance obligations. These are not kept beyond the period needed for their original purpose.
• Support communications are retained for a reasonable period to allow follow-up on unresolved queries.
• Usage and analytics data is aggregated and anonymised after the active account period ends. Anonymised data may be retained indefinitely for platform improvement purposes.

7 Your Rights Over Your Data

As a user of the 22atm platform you have a number of rights regarding your personal data. We aim to process all data rights requests within a reasonable timeframe. To exercise any of these rights, contact us at [email protected] with your registered account email and the specific request.

• Right of Access: You can request a copy of the personal data we hold about you. We will provide this in a readable format within a reasonable period.
• Right to Correction: If any personal data we hold is inaccurate or out of date, you can ask us to correct it. Basic details like email address and phone number can be updated directly from account settings.
• Right to Deletion: You can request deletion of your account and personal data. Note that data we are required to retain for legal or compliance reasons (such as transaction records) cannot be deleted before the applicable retention period ends.
• Right to Restrict Processing: You can ask us to limit how we use your data in certain circumstances, for example if you dispute its accuracy while we investigate.
• Opt-Out of Marketing: You can stop receiving promotional communications at any time by updating your notification preferences in account settings or by contacting support.

8 Data Security

22atm applies technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration or loss. These measures include encryption of data in transit using TLS, encrypted storage for sensitive data at rest, and access controls that limit who within the organisation can view personal account data.

Payment data related to your JazzCash, Easypaisa and Bank Transfer transactions is processed via secured payment channels. 22atm does not store your full payment credentials — only the minimum reference information required to process transactions and match withdrawals to the correct payment method.

In the event of a data security incident that materially affects your personal data, we will notify affected users as promptly as practicable through the contact information on your account.

9 Children & Minors

22atm is strictly an adult platform available to users aged 18 and above only. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that an account has been registered by a minor, that account will be immediately closed and any data associated with it will be deleted or anonymised.

Parents and guardians who believe a minor may have registered on the platform should contact support immediately with details. We will investigate and take appropriate action promptly.

Parental control software can be used to restrict access to online gaming and betting platforms. We encourage parents and guardians to make use of such tools to help keep minors away from adult gaming content.

10 Changes to This Privacy Policy

22atm may update this Privacy Policy from time to time. When we make material changes, we will notify registered users via the email on their account or through an in-platform notification. The updated policy will be published on this page with a revised "last updated" date.

Continued use of the 22atm platform after a policy update constitutes acceptance of the revised policy. If you do not agree with the updated terms, you should stop using the platform and may request account closure by contacting support.