Privacy Policy
22vin Platform

This Privacy Policy ("Policy") is issued by 22vin ("22vin", "we", "us", "our"), the operator of the online gaming information and platform accessible at https://22vin.cam (the "Platform"). It describes how 22vin collects, uses, stores, shares and protects personal data relating to users ("you", "your") of the Platform.

By accessing or using the 22vin Platform — including registering an account, making a deposit, placing a wager or simply browsing our content — you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, which together govern your use of the 22vin Platform. If you do not agree with this Policy, you should discontinue use of the Platform.

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, email address, date of birth, financial information, device identifiers and behavioural data.
• "Data Controller" — 22vin, which determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" — A third party that processes personal data on behalf of 22vin under a contractual data-processing agreement.
• "Processing" — Any operation performed on personal data, including collection, storage, use, disclosure, transfer or deletion.
• "Consent" — Freely given, specific, informed and unambiguous indication of agreement to the processing of personal data.
• "KYC Data" — Identity verification documents and information submitted as part of the Know Your Customer process, including CNIC, passport data, selfie images and proof of address.
• "Cookies" — Small text files placed on your device by the Platform to store session state, preferences and analytics data.
• "Sensitive Data" — Categories of personal data requiring heightened protection, including financial account details, government identification numbers and biometric data (where applicable).

We collect the following categories of personal data from users of the 22vin Platform:

Identity & Contact Information

Financial Information

Activity & Behavioural Data

Technical & Device Data

22vin collects personal data through the following mechanisms:

1. Direct submission: Information you voluntarily provide during account registration, KYC verification, payment processing, support interactions, survey participation or any other form of direct communication with 22vin.
2. Automated collection: Technical and behavioural data collected automatically when you access and interact with the Platform, including through cookies, server logs, session tracking and similar technologies.
3. Third-party sources: Identity and fraud-prevention data received from KYC verification service providers, payment processors and anti-money laundering screening services, where applicable to your account.
4. Device-level data: Information about the device, operating system, browser and network you use to access the Platform, collected automatically for security, fraud detection and service optimisation purposes.

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

• Contractual necessity: Processing required to perform the contract between you and 22vin, including account management, deposits, withdrawals, game participation and support services.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC verification requirements, tax reporting and data retention mandates.
• Legitimate interests: Processing necessary for fraud prevention, platform security, service improvement, responsible gambling monitoring and analytics, where those interests are not overridden by your fundamental rights.
• Consent: Processing for optional purposes such as marketing communications, where you have provided explicit, freely given and revocable consent. You may withdraw consent at any time without affecting prior lawful processing.

22vin uses the personal data we collect for the following specific purposes:

• To create, manage and maintain your account, including processing deposits and withdrawals in PKR or other accepted currencies.
• To verify your identity and age (18+) in accordance with KYC requirements and to comply with AML and counter-fraud obligations.
• To process and settle sports bets, casino games and other wagering activities conducted through the Platform.
• To deliver customer support, respond to queries and resolve disputes relating to your account or any Platform service.
• To enforce our Terms & Conditions, detect prohibited conduct and investigate suspected fraud, collusion or money laundering.
• To administer promotional offers, loyalty programmes and VIP tier benefits, including verification of eligibility.
• To monitor gambling activity patterns for responsible gambling purposes, including identifying indicators of problem gambling and applying account safeguards where appropriate.
• To improve Platform performance, personalise content presentation and conduct internal analytics on usage patterns and service quality.
• To send transactional communications including deposit confirmations, withdrawal notifications, account security alerts and policy update notices.
• To send marketing communications where you have provided explicit consent and have not subsequently withdrawn it.

22vin does not sell or rent your personal data to third parties for their independent commercial use. We may share your personal data with the following categories of recipient, solely to the extent necessary for the stated purpose:

• Payment processors: To facilitate deposits and withdrawals in PKR via available payment channels. These processors receive only the data necessary to execute the transaction and are bound by their own data protection obligations.
• KYC and identity verification providers: Third-party services engaged to verify your identity documents, age and address as part of the onboarding and ongoing compliance process.
• AML and fraud-prevention services: Screening services that check transactions and account data against sanctions lists, watchlists and fraud-detection databases to meet regulatory obligations.
• Technology and hosting providers: Cloud hosting, infrastructure and software-as-a-service providers that process data on behalf of 22vin under contractual data-processing agreements.
• Analytics providers: Platform analytics tools that process anonymised or pseudonymised user behaviour data to help us understand how the Platform is used and to improve services.
• Legal and regulatory authorities: Where required by applicable law, court order, regulatory investigation or law enforcement request, 22vin will disclose personal data to competent authorities.
• Business successors: In the event of a merger, acquisition, restructuring or sale of assets involving 22vin, user data may be transferred to the acquiring entity, subject to continued protection under this Policy or an equivalent standard.

22vin uses cookies and similar technologies (including local storage, session tokens and pixel tags) to operate and improve the Platform. The following categories of cookie are used:

• Strictly necessary cookies: Essential for Platform functionality including user authentication, session management and security controls. These cannot be disabled without impairing Platform use.
• Performance and analytics cookies: Used to collect anonymised data on how users interact with the Platform — which pages are visited most, where users navigate to and from, and how long sessions last. This data helps us optimise the user experience.
• Functional cookies: Remember your preferences such as language selection, display settings and last-visited game category to provide a more personalised experience on subsequent visits.
• Security cookies: Support fraud detection and account protection mechanisms, including detection of unusual login patterns or suspicious transaction activity.

22vin does not deploy advertising or behavioural profiling cookies for the benefit of third-party advertisers. You may manage cookie preferences through your browser settings; however, disabling necessary cookies may restrict your ability to use certain Platform features.

22vin retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, AML or tax obligations. Specific retention considerations include:

• Account data: Retained for the duration of your active account relationship with 22vin, and for a defined period following account closure to meet legal and regulatory obligations.
• KYC and identity documents: Retained for a minimum period as required by applicable AML legislation in the operator's license jurisdiction, which typically ranges from five to seven years post-account closure.
• Transaction records: Financial transaction logs are retained for the minimum period required by applicable tax and AML laws, generally five years from the date of the transaction.
• Support communication records: Retained for a reasonable period to enable dispute resolution, quality assurance and legal defence, typically two to three years from the date of the interaction.
• Analytics data: Behavioural analytics data is anonymised or deleted within a reasonable period and is not linked back to individual user accounts.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymised or archived in a manner that prevents re-identification.

As an international online platform, 22vin may transfer personal data to servers, service providers or affiliated entities located outside Pakistan or the user's country of residence. Such transfers may include data processed in jurisdictions that may not offer the same level of data protection as the user's home country.

Where international transfers occur, 22vin takes appropriate measures to ensure that personal data continues to be protected to a standard consistent with this Policy, including through the use of contractual safeguards with data processors, standard contractual clauses or equivalent mechanisms where applicable under relevant data protection law.

By using the 22vin Platform, Pakistani users acknowledge that their personal data may be transferred to and processed in countries outside Pakistan. We encourage users to be aware that Pakistani data protection law is evolving and that international transfers may be subject to future regulatory developments.

22vin implements a range of technical and organisational security measures designed to protect your personal data from unauthorised access, loss, misuse, alteration or disclosure. These measures include:

• Encrypted HTTPS transmission for all data exchanged between your device and the 22vin Platform.
• Access controls and role-based permissions limiting access to personal data to authorised personnel only, on a need-to-know basis.
• Regular security assessments and vulnerability testing of the Platform's infrastructure.
• Two-factor authentication options for user accounts to reduce the risk of unauthorised login.
• Secure, encrypted storage of sensitive data including passwords (stored as hashed values only) and KYC documents.
• Incident response procedures in the event of a confirmed or suspected data breach, including timely notification where required by applicable law.

Notwithstanding these measures, no data transmission over the internet or electronic storage system is completely secure. 22vin cannot guarantee absolute security and accepts no liability for unauthorised access that is beyond our reasonable control.

The 22vin Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the applicable operator or license jurisdiction. 22vin does not knowingly collect, use or store personal data from minors under the age of 18.

If we become aware that personal data has been submitted by a person under the minimum age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the 22vin Platform, please contact us immediately at [email protected] (plain text — not a clickable link).

Subject to the applicable data protection legislation in the operator's license jurisdiction and any mandatory legal retention obligations, you may exercise the data rights described in the "Your Data Rights" section above by submitting a request to 22vin through the following process:

1. Send your request to [email protected] (plain text — not a clickable link), clearly stating the specific right you wish to exercise and the data it concerns.
2. 22vin may require you to verify your identity before processing your request, to prevent unauthorised access to or modification of another person's data.
3. We will acknowledge receipt of your request and provide a substantive response within a reasonable timeframe, and in any event no later than required by applicable law.
4. Where we are unable to fulfil your request — for example, due to a mandatory legal retention obligation — we will explain the reason in our response.
5. There is no charge for reasonable data requests. We reserve the right to charge a reasonable administrative fee for manifestly unfounded or excessive requests.

22vin may send you promotional communications about bonuses, seasonal offers, new game releases, VIP tier updates and other marketing content where you have provided explicit consent to receive such communications at the time of registration or subsequently.

You may opt out of marketing communications at any time by:

• Using the unsubscribe link included in every marketing email we send.
• Updating your communication preferences through your account settings.
• Contacting our support team at [email protected] (plain text) and requesting removal from marketing lists.

Withdrawing consent for marketing communications does not affect your receipt of transactional emails relating to your account, such as deposit confirmations, withdrawal notifications, security alerts and essential policy updates, which are sent on the basis of contractual necessity regardless of marketing consent.

During any active self-exclusion period, all marketing communications will be suppressed for the relevant account automatically.

The 22vin Platform may contain references to or integrations with third-party services, including payment gateways, game studio interfaces and analytics tools. This Policy applies only to data processed by 22vin directly. We are not responsible for the privacy practices of third-party services, and we encourage you to review the privacy policies of any third-party providers whose services you use in connection with the Platform.

Payment provider names referenced on the Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are used as contextual references only. The data practices of these third-party payment providers are governed by their own respective privacy policies, which 22vin does not control.

22vin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or Platform functionality. When material changes are made, we will notify registered users via the email address on file or through a prominent notice on the Platform.

The "Last updated" date at the top of this Policy will be revised whenever changes are made. We encourage you to review this Policy periodically to stay informed about how we are protecting your data. Your continued use of the Platform following the publication of any amendments constitutes acceptance of the revised Policy.

If you have any questions, concerns or complaints about this Privacy Policy or our data processing practices, or if you wish to exercise any of your data rights, please contact the 22vin data team. All contact details below are provided as plain text only — they are not clickable links.

• Privacy & Data Queries: [email protected] — mark your subject line as "Privacy Request" or "Data Enquiry" for faster routing.
• General Support: [email protected] — for all account-related support queries.
• General Information: [email protected] — for non-account general information requests.
• Response Target: We aim to respond to all privacy requests within a reasonable timeframe. Complex requests or those requiring legal review may take longer; we will acknowledge receipt promptly in all cases.
• Language: Support and privacy responses are provided in English. Urdu-language assistance is available on request — please indicate your language preference in your initial message.