Privacy Policy

This Privacy Policy ("Policy") is issued by the operator of the 222s platform ("222s", "Operator", "we", "us" or "our"), accessible at https://222s.cam. This Policy governs the collection, processing, storage and disclosure of personal data relating to all users ("User", "you" or "your") who access or use the Platform in any capacity, including as registered account holders, visitors or prospective users.

222s is an English-language online betting and live casino platform built with Pakistani users in mind. By accessing the Platform, registering an Account, or using any service offered through the Platform, you acknowledge that you have read, understood and consented to the data practices described in this Policy.

This Policy forms part of our broader legal framework alongside our Terms & Conditions and Responsible Gambling Policy. In the event of inconsistency between this Policy and the Terms & Conditions on a data-specific matter, this Policy prevails.

The following terms carry the meanings set out below throughout this Policy:

We collect personal data from you in three principal ways: data you provide directly, data generated through your use of the Platform, and data received from third parties in the course of operating our services.

3.1 Data You Provide Directly

• Registration data: Full name, date of birth, country of residence, email address, phone number and chosen account credentials when you create an Account.
• KYC documents: Government-issued photo ID (such as a Pakistani CNIC or passport), proof of address (such as a recent bank statement or utility bill), and selfie/liveness verification images submitted during identity verification.
• Payment information: Details necessary to process deposits and withdrawals, including payment method identifiers (e.g. registered mobile wallet number for Easypaisa or JazzCash, or bank account details for HBL, UBL, Meezan Bank or Bank Alfalah transfers). We do not store full card numbers on our servers where card processing is handled by a third-party payment processor.
• Support communications: Content of any communications you send to our support team via Live Chat, email or our Help Centre, including the nature of your query and any information you volunteer in that context.

3.2 Data Generated Through Platform Use

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and time zone setting.
• Usage and behavioural data: Pages visited, features used, games played, bet history, session duration, click patterns and navigation paths within the Platform.
• Transaction data: Deposit and withdrawal amounts, transaction timestamps, payment methods used and transaction reference numbers.
• Geolocation data: General location inferred from IP address for jurisdiction verification and fraud prevention purposes. We do not collect precise GPS location unless explicitly permitted by your device settings and disclosed at the point of collection.

3.3 Data Received from Third Parties

• Identity and age verification data from KYC service providers engaged to assist in document verification.
• Fraud risk signals and AML screening results from compliance and payment processing partners.
• Analytics data from platform performance monitoring tools used to maintain service quality.

We process your Personal Data on one or more of the following lawful bases, depending on the nature of the processing activity:

We use Personal Data only for the purposes for which it was collected or for compatible purposes as disclosed below. We do not use your Personal Data for purposes that are incompatible with the original collection purpose without your consent.

• Account Management: Creating, maintaining, authenticating and closing user accounts on the Platform.
• Service Delivery: Enabling you to place wagers, play casino games, deposit and withdraw funds, and access all features of the Platform.
• KYC & Age Verification: Verifying your identity and age to confirm eligibility, comply with licensing obligations and protect against underage gambling.
• AML & Fraud Prevention: Screening transactions and account activity for signs of money laundering, fraud, collusion, match-fixing or other prohibited conduct.
• Responsible Gambling: Monitoring usage patterns to identify potential problem gambling behaviour and, where appropriate, initiating responsible gambling interventions — such as offering limit-setting tools or self-exclusion support.
• Customer Support: Responding to account queries, technical issues, payment questions and complaints submitted through supported contact channels.
• Legal Compliance: Meeting record-keeping obligations, responding to lawful regulatory or law enforcement requests, and managing legal claims.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve platform performance, user experience and game catalogue quality.
• Marketing (where consented): Sending relevant promotional communications about offers, new features or Platform updates. You may opt out at any time through your account settings or by contacting support.

We do not sell your Personal Data to third parties. We may share Personal Data with the following categories of recipients only to the extent necessary and for the purposes set out in this Policy:

• KYC & Verification Providers: Third-party identity verification services that assist with document review and liveness checks as part of our KYC process. These providers act as Data Processors under contract.
• Payment Processors: Payment technology providers required to process deposit and withdrawal transactions. Only the minimum data necessary for the transaction is shared. Payment references to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are contextual examples of payment methods users may use — 222s does not claim these providers are our partners or that they endorse our services.
• AML & Compliance Screening Providers: Services engaged to assist with anti-money laundering checks, sanctions screening and fraud risk assessment.
• Game Software Providers: Where technically required to deliver specific game experiences, limited session and account data may be shared with licensed game content providers.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order or a request from a competent regulatory authority, we may disclose Personal Data to relevant bodies. We will, where legally permitted, notify you of such disclosure.
• Professional Advisors: Legal, accounting and audit professionals engaged under strict confidentiality obligations.

The Platform uses cookies and similar tracking technologies (collectively "Cookies") to operate core platform functionality, maintain your session, improve performance and — where you consent — to gather analytics and serve relevant content.

You may control Cookie settings through your browser settings or through the Cookie preference tool available on the Platform. Disabling strictly necessary Cookies may impair your ability to use the Platform. For general browser cookie controls, refer to your browser's support documentation.

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, licensing conditions or legitimate business need. The following general retention principles apply:

• Active Account Data: Retained for the duration of your Account's active status and for a minimum period thereafter as required by applicable AML/KYC regulations and our licensing obligations — typically no less than five (5) years following account closure.
• Transaction Records: Financial transaction records, including deposit and withdrawal histories, are retained for a minimum of five (5) years following the transaction date, in compliance with applicable financial record-keeping requirements.
• KYC Documents: Identity verification documents are retained for the minimum period required by applicable anti-money laundering regulations applicable to the Operator's licensing jurisdiction.
• Support Communications: Records of support interactions are retained for a reasonable period to facilitate ongoing service quality and dispute resolution, typically two (2) years from the date of the interaction.
• Marketing Data: Where processed on the basis of consent, marketing-related data is retained until you withdraw consent or for a reasonable period of inactivity as specified in our marketing communications.

Where retention is no longer required and no legal obligation mandates continued retention, we will take reasonable steps to securely delete or anonymise your Personal Data.

We implement appropriate technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include, but are not limited to:

• Transmission of Personal Data over the Platform is protected by industry-standard Transport Layer Security (TLS/SSL) encryption.
• Access to Personal Data is restricted to authorised personnel on a need-to-know basis, subject to confidentiality obligations.
• Payment card data is handled by PCI-DSS compliant third-party payment processors — full card numbers are not stored on Platform servers.
• KYC document handling follows secure submission protocols — documents submitted outside of the Platform's secure portal cannot be accepted and should not be sent.
• Regular internal reviews of data handling practices and access controls are conducted to identify and address security risks.

Depending on the data protection law applicable to your situation, you may hold some or all of the following rights in relation to your Personal Data held by us. We will respond to verified rights requests within a reasonable timeframe and no later than the period required by applicable law.

The 222s Platform is strictly for adults aged 18 years or older, or the higher minimum age required by the Operator's licensing jurisdiction. We do not knowingly collect Personal Data from individuals below the applicable minimum age.

Age verification is a mandatory part of our KYC process. Where we discover or reasonably suspect that an Account has been created by or on behalf of a minor, we will suspend the Account immediately, conduct a review, retain records as required by applicable regulations, and delete unnecessary data promptly following the review.

Given the global nature of online platform operations, your Personal Data may be transferred to and processed in countries outside of Pakistan, including countries where the Operator is incorporated or where its Data Processors are located.

Where Personal Data is transferred to jurisdictions that do not provide an equivalent level of data protection to that applicable in the Operator's licensing jurisdiction, we take appropriate safeguards — including contractual measures with Data Processors — to ensure your Personal Data remains adequately protected.

The Platform may integrate or operate alongside third-party services — including game software providers, payment processing systems, KYC verification tools and analytics platforms. Each such third-party service provider operates under its own privacy policy.

222s does not control how third-party providers process your data beyond the terms of the data processing agreements in place. We select third-party providers with care and require contractual data protection obligations where required by applicable law. Users are encouraged to review the privacy policies of any third-party services they interact with independently of the 222s Platform.

Payment method references used on the Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are contextual educational references only. 222s does not claim partnership or data-sharing arrangements with these providers beyond what is strictly required to process transactions where those methods are available in the cashier.

We reserve the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered Users through in-platform notifications or email to the registered address on file, where reasonably practicable.

The current effective date is displayed at the top of this page. Your continued use of the Platform following the publication of a revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you must cease using the Platform and may request Account closure in accordance with our Terms & Conditions.

We encourage you to review this Policy periodically. Archived versions of previous Policy documents may be made available on request via our support team.

If you have any questions, concerns or requests relating to this Privacy Policy — including rights requests, data deletion requests, or concerns about how your Personal Data is handled — please contact us through any of the following channels:

We will acknowledge receipt of your enquiry and respond within a reasonable period, consistent with applicable legal requirements. We may request proof of identity before processing certain rights requests to protect against fraudulent access attempts.