1 Who We Are
22win is an online gaming platform operating the website at https://22win-win.com, providing Pakistani players with access to casino games, sports betting, and related gaming entertainment services. When this Privacy Policy refers to "22win", "we", "us" or "our", it means the 22win platform and its operating entity responsible for processing your personal data.
22win acts as the data controller for all personal data collected through the platform. This means we determine the purposes and means of processing your data and bear primary responsibility for its security and correct use. For any data-related queries, our Data Protection contact is available through the support channels listed at the end of this policy.
2 Personal Data We Collect
22win collects personal data from you through several channels — when you register an account, when you make deposits or withdrawals, when you use our games and platform features and when you contact our support team. The categories of data we collect are:
| Category |
Specific Data Points |
When Collected |
| Identity Data |
Full name, date of birth, CNIC number (for verified accounts), nationality |
Registration & KYC verification |
| Contact Data |
Pakistani mobile number, email address |
Registration |
| Financial Data |
Payment method identifiers (Easypaisa number, JazzCash number, bank account reference), transaction amounts and dates |
Deposit & withdrawal processing |
| Technical Data |
IP address, device type, browser type, operating system, session timestamps |
Platform use (automatic) |
| Gaming Activity Data |
Game sessions, wager amounts, win/loss records, bonus usage |
Platform use (automatic) |
| Communications Data |
Support chat transcripts, email correspondence, WhatsApp and Telegram message records |
Support interactions |
What we do NOT collect: 22win does not collect full payment card numbers, CVV codes or banking PINs. These are processed directly by payment providers and are never transmitted to or stored on 22win systems. We also do not collect data about your ethnicity, religion, political views or health status.
3 How We Use Your Personal Data
22win uses the personal data we collect for the following specific purposes only:
- Account creation and management: To create and administer your 22win player account, authenticate your login sessions and maintain account records.
- Identity verification (KYC): To verify your age and identity as required for regulatory compliance and to prevent underage gaming and fraudulent account creation.
- Payment processing: To process PKR deposits and withdrawals through your selected payment methods — Easypaisa, JazzCash, NayaPay, SadaPay, bank transfer or debit card.
- Fraud and security monitoring: To detect, investigate and prevent fraudulent activity, money laundering, multi-account abuse and other security threats to the platform and to individual player accounts.
- Regulatory compliance: To fulfil legal and regulatory obligations including anti-money laundering (AML) requirements and financial record-keeping obligations.
- Customer support: To respond to your enquiries, resolve complaints and provide assistance with account or payment issues.
- Platform improvement: To analyse aggregated, anonymised usage patterns to improve platform performance, game selection and user experience. Individual player data is not used for this purpose in identifiable form.
- Responsible gaming: To monitor gaming activity for signs of problematic behaviour and to apply responsible gaming interventions where appropriate, in line with our duty of care to players.
- Direct communications: To send you account notifications, security alerts and, where you have opted in, promotional communications about 22win offers and games.
22win does not use your personal data for automated profiling that produces legal or similarly significant effects on you without human review. Gaming activity data used for responsible gaming monitoring is reviewed by a human team member before any action is taken on your account.
Payment Data
When you make a deposit or withdrawal at 22win using Easypaisa, JazzCash, NayaPay, SadaPay, bank transfer or a Pakistani debit card, payment processing is handled by your payment provider's own systems. 22win records only the reference identifier and transaction amount necessary to credit or debit your 22win wallet — we never see or store your wallet PIN, banking password, full card number or CVV. Your PKR payment credentials remain entirely within your provider's secure system.
4 Legal Basis for Processing
22win processes personal data on the following legal bases, each of which justifies a specific category of data use:
- Contractual necessity: Processing required to create and fulfil the player account agreement — registration, payment processing, account management and customer support.
- Legal obligation: Processing required to comply with applicable laws and regulations — identity verification, age checking, anti-money laundering record-keeping and responses to lawful regulatory requests.
- Legitimate interests: Processing for fraud prevention, platform security monitoring and aggregated analytics for service improvement — where these interests are not overridden by your privacy rights.
- Consent: Processing for optional promotional communications — where you have actively opted in to receive marketing messages from 22win. You may withdraw this consent at any time through your account settings or by contacting support.
5 Payment Data and Financial Information
All financial transactions at 22win are conducted in Pakistani Rupees (PKR) through locally trusted payment methods — Easypaisa, JazzCash, NayaPay, SadaPay, IBFT bank transfer and Pakistani Visa/Mastercard debit cards. The way 22win handles financial data reflects the sensitivity of this category of personal information.
When you initiate a deposit or withdrawal, the actual payment is processed by your chosen payment provider's own secure system. 22win receives a confirmation of the transaction's success or failure along with a reference number and the PKR amount — nothing more. Full wallet credentials, bank account numbers, card numbers and security codes are handled exclusively by your payment provider and are never transmitted to or accessible by 22win.
22win retains records of transaction amounts, dates, reference numbers and the payment method type (for example, "Easypaisa" or "IBFT") for the purposes of account management, dispute resolution and regulatory compliance. These records are stored securely and retained for the period required by applicable financial record-keeping obligations.
Same-Source Policy: 22win's withdrawal same-source policy — returning funds to the payment method used for deposit — is both a financial security measure and a data protection practice. It prevents funds from being redirected to payment accounts not associated with your verified identity, protecting you against account compromise.
6 Cookies and Tracking Technologies
22win uses cookies and similar tracking technologies to operate the platform, maintain your login session and improve your experience. The types of cookies used by 22win are:
- Essential cookies: Required for the platform to function correctly. These maintain your login session, remember your account preferences and enable secure communication between your browser and 22win servers. Essential cookies cannot be disabled without breaking core platform functionality.
- Functional cookies: Used to remember your preferences such as your preferred language setting, display options and previously used payment methods for a smoother deposit experience.
- Analytics cookies: Used to collect anonymised, aggregated data about how players navigate and use the 22win platform. This data is used solely to improve platform performance and user experience — it does not identify individual users and is not shared with third parties for advertising.
- Security cookies: Used to detect and prevent fraudulent activity, including automated bot traffic, credential stuffing attempts and session hijacking. These cookies are essential for player account security.
22win does not use third-party advertising cookies or allow external advertisers to place tracking cookies on the 22win platform. You will not be tracked across other websites as a result of visiting 22win.
You can manage cookie settings through your browser's privacy controls. Note that disabling essential cookies will prevent you from logging into your 22win account and using core platform features.
Third-Party Sharing
22win shares personal data with a carefully limited set of trusted service providers — only those whose services are necessary for the platform to function. Each provider is bound by data processing agreements that restrict their use of your data to the specific service they provide for 22win. None of these providers are permitted to use your data for their own marketing purposes or to share it further. The list of categories includes identity verification services, payment processing infrastructure, fraud detection systems and customer support platforms.
7 Third-Party Data Sharing
22win shares personal data only in the following strictly limited circumstances:
- Service providers: Identity verification providers, payment processors, fraud detection services and customer support platform providers — all under binding data processing agreements, all restricted to using your data solely for their contracted service.
- Regulatory and legal authorities: Where 22win is legally obligated to disclose data in response to a lawful request from a relevant regulatory authority or law enforcement agency, such disclosure will be made in compliance with applicable Pakistani law. 22win will not voluntarily disclose data beyond what is legally required.
- Business transactions: In the event of a merger, acquisition or sale of 22win assets, player data may be transferred to the acquiring entity — subject to equivalent data protection obligations. Players will be notified of any such change and provided with options regarding their data.
22win does not share personal data with:
- Advertising networks or marketing data brokers
- Social media platforms for targeting or profiling purposes
- Any third party for their own commercial use
- Overseas entities beyond what is necessary for the payment processing infrastructure of supported payment providers
Our commitment: Your personal data will never be sold to any third party under any circumstances. This is a firm commitment, not a qualified statement with exceptions buried in sub-clauses.
8 Data Security
22win implements multiple layers of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration or destruction:
- Encryption in transit: All data transmitted between your device and 22win servers is encrypted using TLS 1.3, the current industry standard for secure communications.
- Encryption at rest: Personal data stored on 22win servers is encrypted at rest using current cryptographic standards.
- Access controls: Access to personal data within 22win's systems is restricted to personnel who genuinely need it to perform their roles. Access is logged and regularly reviewed.
- Payment data handling: Payment card numbers, wallet PINs and banking credentials are never stored on 22win systems after a transaction is completed.
- Incident response: 22win maintains a data breach incident response procedure. In the event of a security incident affecting player data, affected players will be notified as promptly as practically possible with information about what happened and what steps were taken.
- Two-factor authentication: 2FA is available and recommended for all 22win player accounts as an additional layer of account security against credential theft.
While 22win takes all reasonable precautions to protect your data, no online system can guarantee absolute security. We encourage players to use strong, unique passwords for their 22win account and to enable two-factor authentication.
9 Data Retention
22win retains personal data for as long as is necessary for the purpose for which it was collected, or as required by applicable legal obligations. Our general retention practices are:
- Active accounts: Personal data associated with an active 22win account is retained for the duration of the account relationship.
- Closed accounts: Following voluntary account closure, identity and account data is retained for a minimum of five years as required by anti-money laundering regulations. Transaction records are retained for the same period for financial compliance purposes.
- Support communications: Customer support correspondence is retained for three years after the resolution of the relevant issue.
- Cookies and session data: Session cookies are deleted when you close your browser. Analytics data is retained in anonymised, aggregated form indefinitely.
- Marketing consent records: Records of your consent to receive marketing communications are retained until you withdraw consent plus one additional year for compliance purposes.
When the retention period for any data category expires, that data is securely and irreversibly deleted from 22win systems.
10 Your Privacy Rights
As a 22win player based in Pakistan, you have the following rights in relation to your personal data. You may exercise any of these rights at any time by contacting the 22win support team:
Right of Access
Request a copy of all personal data 22win holds about you. We will provide this within 30 days of your verified request.
Right to Rectification
Request correction of any inaccurate or incomplete personal data held on your account. Corrections are made promptly after identity verification.
Right to Erasure
Request deletion of your personal data where it is no longer needed for the original purpose and no legal retention obligation applies.
Right to Restrict Processing
Request that 22win suspends processing of your data in certain circumstances — for example, while accuracy is being verified following a rectification request.
Right to Data Portability
Request your personal data in a structured, machine-readable format for transfer to another service provider where technically feasible.
Right to Withdraw Consent
Where processing is based on your consent — such as marketing communications — you may withdraw that consent at any time without affecting prior lawful processing.
To exercise any of these rights, contact the 22win Data Protection team via Live Chat, WhatsApp, Telegram or email at support@22win-win.com. We will acknowledge your request within 48 hours and complete it within 30 days. Identity verification may be required before processing sensitive data requests.
11 Children's Privacy
22win is strictly an 18+ platform. We do not knowingly collect personal data from individuals under 18 years of age. If you are under 18, you are not permitted to register, deposit or use any 22win services.
If 22win becomes aware that a minor has registered and provided personal data, that account will be immediately closed, all data associated with the account will be deleted as quickly as legally permissible and any deposits will be returned to the source payment method after verification.
Parents or guardians who believe a minor in their household has registered a 22win account should contact our support team immediately. We take underage access extremely seriously and will act on all credible reports promptly.
12 Changes to This Privacy Policy
22win may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements or platform operations. When material changes are made, we will notify registered players through one or more of the following: a prominent notice on the platform; an email notification to your registered address; or an in-platform notification on your next login.
The "Last Updated" date at the top of this page shows when the most recent revision was made. We encourage players to review this policy periodically. Continued use of the 22win platform following notification of changes to this policy constitutes acceptance of the revised version.
If you disagree with any change to this Privacy Policy, you have the right to close your 22win account and request deletion of your personal data subject to applicable legal retention requirements.
13 Contact Us About Privacy
If you have any questions, concerns or requests regarding this Privacy Policy or the way 22win handles your personal data, please contact us through any of the following channels:
- Live Chat: Available 24/7 directly on the 22win platform — the fastest way to reach us for any privacy query.
- WhatsApp: Available 24/7 for support in English or Urdu.
- Telegram: Available 24/7 on our official support channel.
- Email: support@22win-win.com — for formal data rights requests and written privacy enquiries.
For formal data subject rights requests — access, rectification, erasure, portability or restriction — please contact us by email or Live Chat with your account username and the specific right you wish to exercise. We will acknowledge all data rights requests within 48 hours and complete them within 30 days of receiving sufficient information to process the request.
We take privacy seriously. If you are not satisfied with how 22win has handled a privacy concern after raising it with our support team, you have the right to escalate the matter through appropriate regulatory or legal channels applicable in Pakistan.
