22vin Privacy Policy

Data Controller

For the purposes of this Privacy Policy, the data controller responsible for the personal information of 22vin players is the entity operating the 22vin platform under its international online gaming licence. The platform is accessible at 22vin.ws and all associated subdomains and mobile-optimised interfaces.

As the data controller, 22vin determines the means and purposes for which personal data collected from registered players and platform visitors is processed. All data processing activities described in this Policy are carried out either directly by 22vin or by third-party data processors acting under our written instruction and bound by appropriate data processing agreements.

If you have any questions about this Privacy Policy, about how your personal data is handled, or wish to exercise any of your data rights described in Section 11 below, please contact the 22vin Data Protection team using the contact details provided in Section 14 of this document.

Personal Data We Collect

22vin collects personal data from you across several categories, depending on the nature of your interaction with the platform. The following table sets out the categories of personal data we collect, together with specific examples and the reason for collection:

How We Collect Your Data

22vin collects personal data through the following channels and mechanisms:

• Direct Submission at Registration: When you create a 22vin account, you provide your name, date of birth, Pakistani mobile number, email address, and city. This information is submitted directly through the registration form.
• KYC Document Uploads: When you submit identity verification documents — such as your CNIC or proof of payment method — these are uploaded directly through the secure 22vin verification portal and transmitted to our KYC processing partner under encryption.
• Payment Transactions: When you make a deposit or withdrawal via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/MasterCard, or USDT, transaction data including the payment method identifier, amount in PKR, and transaction timestamp is captured automatically.
• Automated Technical Collection: When you access 22vin, our servers automatically record technical data including your IP address, device identifiers, browser type, and network carrier. This occurs for all visitors regardless of whether they are logged in.
• Cookies and Similar Technologies: 22vin uses cookies and similar tracking technologies on its platform. See Section 7 for full details.
• Customer Support Interactions: When you contact 22vin support via live chat or email, the content of those communications is recorded and stored as part of your account record.
• Third-Party Data Sources: In limited circumstances — specifically for fraud prevention and AML compliance — 22vin may receive data about you from third-party sources such as identity verification bureaus or financial crime databases, where this is permitted under applicable law and our licensing obligations.

Legal Basis for Processing

22vin processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing your identity data, contact data, and financial data is necessary to perform the contract between you and 22vin — specifically, to create and manage your account, process your PKR deposits and withdrawals, and deliver gaming services. Without this processing, 22vin cannot provide you with its services.
• Legal Obligation: 22vin is required to process certain personal data — particularly identity documents and financial transaction records — to comply with the KYC and AML obligations imposed by our international gaming licence. This processing is mandatory and cannot be declined.
• Legitimate Interests: 22vin processes technical data, usage data, and behavioural data to pursue its legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and service improvement. These interests are balanced against your privacy interests and do not override your fundamental rights.
• Consent: Where 22vin sends you optional marketing communications — such as promotional emails about new games or PSL cricket betting offers — we rely on your explicit consent, which you can withdraw at any time by updating your communication preferences in account settings or by contacting support.

How We Use Your Personal Data

22vin uses the personal data described in Section 2 for the following specific purposes:

• Account Creation and Management: To register your account, maintain your player profile, manage your PKR wallet balance, and provide access to all 22vin gaming and betting services.
• Age and Identity Verification: To verify that you are at least 21 years of age and that your identity matches the details provided at registration — a mandatory requirement under 22vin's international operating licence.
• Payment Processing: To process your deposits from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/MasterCard, and USDT, and to process withdrawal requests back to your designated payment method. This includes sharing necessary transaction details with our payment processing partners.
• AML and Fraud Prevention: To monitor transactions and gaming activity for indicators of money laundering, fraud, bonus abuse, multiple account operation, or other prohibited conduct as defined in our Terms and Conditions.
• Responsible Gaming Compliance: To monitor player gaming patterns for indicators of problem gambling behaviour and to apply responsible gaming measures — including limits and account reviews — where required by our licensing obligations or at the player's request.
• Customer Support: To handle queries, complaints, account disputes, and technical issues raised through live chat or email support, in Urdu and English.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the 22vin platform — including mobile performance optimisation for Pakistani Android devices and 4G network reliability.
• Marketing Communications (Consent-Based): To send promotional emails, SMS notifications, or in-platform messages about bonuses, new games, PSL cricket betting markets, or VIP offers — only where you have provided explicit consent and only until that consent is withdrawn.
• Legal and Regulatory Compliance: To fulfil reporting obligations to regulatory authorities, respond to lawful requests from law enforcement or government bodies, and to enforce 22vin's legal rights under its Terms and Conditions.

Sharing Your Personal Data

22vin does not sell your personal data. We share personal data with third parties only in the following limited and controlled circumstances:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/MasterCard acquirers, and USDT processing services receive the minimum transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and applicable Pakistani financial regulations.
• KYC and Identity Verification Providers: Third-party identity verification services receive your CNIC information, date of birth, and document images to perform age and identity verification on 22vin's behalf. These providers are bound by confidentiality agreements and data processing contracts.
• Fraud Detection and AML Services: Specialised fraud prevention and anti-money-laundering service providers may receive transaction data and behavioural signals to assist in identifying suspicious activity. Access is limited to what is necessary for these specific purposes.
• Game Software Providers: Third-party game providers whose titles appear on the 22vin platform may receive your player ID and gaming session data to facilitate game delivery and RNG certification. They do not receive your full personal profile or payment details.
• Regulatory and Legal Authorities: 22vin may disclose personal data to its licensing authority, financial intelligence units, law enforcement agencies, or courts where required by law, by court order, or by our licence conditions. We will not notify you of such disclosures where doing so would compromise a lawful investigation.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of 22vin's business, personal data may be transferred to the acquiring entity. You will be notified of any such transfer and, where legally required, given the opportunity to object.

Cookies & Tracking Technologies

22vin uses cookies — small data files stored on your device — and similar technologies to operate and improve the platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies that keep you logged in to your 22vin account, security cookies that protect against cross-site request forgery, and load-balancing cookies. These cannot be disabled without breaking platform functionality.
• Functional Cookies: Remember your preferences — such as language settings, preferred game category, and display options — to personalise your 22vin experience across sessions.
• Analytics Cookies: Collect anonymised usage data to help 22vin understand how players navigate the platform, which games are most accessed, and where technical difficulties arise. This data is aggregated and does not identify individual players.
• Security and Fraud Prevention Cookies: Used to detect and prevent fraudulent account access, bot activity, and multiple account abuse by analysing technical fingerprinting data across sessions.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair 22vin platform functionality, including the ability to log in and maintain a session. For mobile users accessing 22vin via a mobile browser on Pakistani networks — whether Jazz, Telenor, Zong, or Ufone — cookie settings are managed through your mobile browser's privacy settings.

Data Retention

22vin retains personal data for no longer than is necessary for the purpose for which it was collected, taking into account our legal and regulatory obligations. The following general retention periods apply:

• Account Data and KYC Documents: Retained for a minimum of five years following account closure, as required by AML regulations and 22vin's licensing authority obligations.
• Financial Transaction Records (PKR deposits and withdrawals): Retained for a minimum of five years post-transaction, as required for financial record-keeping and AML compliance.
• Gaming History: Retained for three years post-account closure for dispute resolution purposes, thereafter anonymised or deleted.
• Customer Support Communications: Retained for two years from the date of last interaction with support, thereafter reviewed and deleted unless a formal dispute remains open.
• Technical and Usage Data: Retained for up to 12 months from collection, after which it is anonymised for aggregate analytics purposes or deleted.
• Marketing Consent Records: Retained for the duration of your consent plus two years following withdrawal of consent, for the purpose of demonstrating compliance with consent obligations.

Upon expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised in accordance with 22vin's internal data lifecycle management procedures.

Data Security

22vin implements a layered approach to data security, combining technical, organisational, and procedural measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• Transport Encryption: All data in transit between your device and 22vin's servers is encrypted using TLS 1.3 with 256-bit AES encryption — the same standard employed by major Pakistani banks and financial institutions for internet banking.
• Data at Rest Encryption: Personal data and financial records stored in 22vin's systems are encrypted at rest, ensuring that even in the event of an infrastructure breach, stored data cannot be read without appropriate decryption keys.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. 22vin employees are granted the minimum level of data access required for their specific role. Access is logged, monitored, and reviewed regularly.
• Multi-Factor Authentication: Internal 22vin systems holding personal data require multi-factor authentication for all staff access. Similarly, 22vin recommends and supports two-factor authentication for all player accounts.
• Penetration Testing and Security Audits: 22vin's technical infrastructure undergoes regular independent security assessments, including penetration testing, to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: 22vin maintains a documented data breach response procedure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, you will be notified without undue delay and in accordance with applicable regulatory requirements.

International Data Transfers

22vin operates under an international gaming licence and, as a consequence, your personal data may be processed by 22vin or its third-party service providers in jurisdictions outside Pakistan. This includes the jurisdiction in which 22vin's licensing authority is based, as well as the locations of KYC verification providers, payment processing partners, and cloud infrastructure providers.

When personal data is transferred internationally, 22vin ensures that appropriate safeguards are in place to protect your data to a standard equivalent to, or greater than, the protections applicable in the data's country of origin. These safeguards may include:

• Standard contractual clauses between 22vin and the receiving entity, requiring the recipient to protect the data to specified standards.
• Binding corporate rules where data is transferred within a corporate group.
• Adequacy decisions issued by relevant data protection authorities confirming that the destination jurisdiction provides an adequate level of data protection.

For further information about the specific safeguards in place for international transfers of your personal data, please contact 22vin's Data Protection team using the details in Section 14.

Your Data Rights

As a registered 22vin player, you have the following rights with respect to your personal data. These rights are not absolute — they are subject to applicable law and, in some cases, to 22vin's regulatory obligations — but 22vin will handle all rights requests promptly and transparently:

To exercise any of the above rights, please contact 22vin using the details in Section 14. We will respond to valid requests within 30 days. In complex cases, this period may be extended by a further two months, in which case you will be notified of the extension and the reason for it within the initial 30-day period.

Children & Minors — Strict 21+ Policy

22vin employs active age verification measures — including CNIC verification during the KYC process — to identify and prevent account registration by individuals under 21. Where 22vin becomes aware, through any means, that a registered account belongs to a person under the age of 21:

• The account will be immediately suspended pending investigation.
• Access to all gaming and betting services will be revoked.
• Any account balance will be returned to the originating payment method after verification of ownership.
• All personal data collected in connection with the account will be handled in accordance with applicable data protection law, and will be deleted or retained only to the extent required for legal compliance purposes.
• The incident may be reported to 22vin's licensing authority as required under our regulatory obligations.

If you have reason to believe that a person under the age of 21 has registered a 22vin account, please report this to our support team immediately using the contact details in Section 14. We take underage gambling extremely seriously and act on all credible reports without delay.

Changes to This Privacy Policy

22vin reviews this Privacy Policy periodically and may update it to reflect changes in our data processing practices, changes to applicable law, or requirements imposed by our licensing authority. The effective date shown at the top of this document indicates when the current version came into force.

When material changes are made to this Privacy Policy, 22vin will notify registered players via the email address or mobile number associated with their account, or through a prominent notice on the platform, prior to the changes taking effect. For non-material changes — such as corrections of typographical errors or clarifications that do not alter the substance of our data practices — the Policy will be updated without individual notification.

Your continued use of the 22vin platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you disagree with any material change, you have the right to close your account and request deletion of your personal data (subject to the retention obligations described in Section 8) by contacting 22vin support.

Contact Us — Data Protection Queries

For all privacy-related queries, data rights requests, concerns about how your personal data is being processed, or to report suspected underage account access, please contact the 22vin team through the following channels:

• Live Chat: Available 24 hours a day, seven days a week, directly within the 22vin platform after login. For privacy and data protection queries, please select the "Account & Privacy" category when initiating your chat. Average response time is under 4 minutes. Support is available in Urdu and English.
• Email: [email protected] — For formal data rights requests, please include "Data Rights Request" in your email subject line along with the specific right you wish to exercise. Formal requests will receive a written response within 30 days.

This Privacy Policy, together with 22vin's Terms and Conditions and Responsible Gaming Policy, constitutes the complete framework governing your relationship with the platform with respect to data privacy and protection. In the event of any conflict between this Policy and any other 22vin document, this Privacy Policy shall prevail with respect to matters of personal data processing.