Data Privacy

22rs Privacy Policy – How We Protect Your Data in Pakistan

Your privacy matters to 22rs. This policy tells you exactly what personal data we collect when you use our platform, why we need it, how it is stored and protected, and what rights you have over it as a player in Pakistan.

Last updated: 1 January 2024

What We Collect

Name, CNIC, contact details, payment information, device data, and gameplay activity — only what is genuinely needed to operate the 22rs platform and meet regulatory requirements.

Why We Use It

Account management, PKR payment processing, KYC/AML compliance, responsible gaming monitoring, fraud prevention, and improving the 22rs experience for Pakistani players.

Your Rights

Access your data, request corrections, withdraw marketing consent, and request deletion — all without having to go through complicated processes. Just contact 22rs support.

1 About This Policy

This Privacy Policy explains how 22rs — the online gaming platform operating at 22rs.biz — collects, uses, stores, and protects the personal information of players registered on the platform. It covers all interactions between you and 22rs, including account registration, deposits, gameplay, withdrawals, customer support contacts, and use of the 22rs website from any device.

22rs is committed to handling your personal data responsibly. We collect only what we genuinely need, we keep it only for as long as we have a legitimate reason to do so, and we do not sell it. As a platform built specifically for Pakistani players, we understand that trust is the foundation of any lasting relationship — and that trust starts with being clear and honest about how your information is handled.

Who this applies to: This policy applies to all registered 22rs account holders, visitors to 22rs.biz who have not yet registered, and former account holders whose data we are legally required to retain. By using the 22rs platform, you confirm that you have read and understood this Privacy Policy.

This policy should be read alongside the 22rs Terms and Conditions and the Responsible Gaming page, both of which contain additional provisions relevant to your rights and obligations as a player.

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2 Personal Data We Collect

The types of personal data 22rs collects depend on how you use the platform. Below is a comprehensive breakdown:

Category Specific Data Points When Collected
Identity Full name, date of birth, CNIC number, passport number (if applicable), nationality Registration & KYC verification
Contact Mobile phone number, email address, mailing address Registration & account updates
Financial Easypaisa / JazzCash account number, NayaPay / SadaPay wallet ID, bank account details for IBFT, masked card number for Visa/Mastercard transactions Deposits & withdrawals
Verification Copies of identity documents (CNIC front/back, passport bio page), proof of address (utility bill, bank statement dated within 90 days) KYC process (first withdrawal or on request)
Gameplay Game history, bet amounts, win/loss records, session durations, responsible gaming tool usage, bonus claiming and wagering history Ongoing during platform use
Technical IP address, device type and operating system, browser version, referring URL, session timestamps Automatically on every platform visit
Communications Content of support chats and emails, complaint records, survey responses When you contact 22rs support

22rs does not collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, health information, or biometric identifiers beyond what is contained in a standard CNIC or passport for identity verification.

3 How We Collect Your Data

22rs collects personal data through the following channels:

  • Directly from you: When you register an account, complete identity verification, make a deposit or withdrawal, contact support, respond to a survey, or update your account settings on 22rs.
  • Automatically: When you visit or use the 22rs platform, our systems automatically record technical data including IP address, device identifiers, browser type, and session activity. This happens regardless of whether you are logged in.
  • From payment processors: When you make a deposit or withdrawal via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, or card, the payment provider shares transaction confirmation data with 22rs to update your balance.
  • From identity verification providers: When you submit KYC documents, our verification partner processes and confirms the document authenticity before sharing a verification status with 22rs. The actual document images are stored securely by 22rs.
  • From fraud prevention tools: 22rs uses risk-scoring tools that analyse technical signals (device fingerprinting, IP reputation, velocity checks) to detect suspicious account or payment activity.
Note: 22rs does not buy marketing lists or acquire personal data from data brokers. Every data point we hold about you was either provided by you directly, generated by your use of the platform, or received from a functional partner in the course of delivering the 22rs service.
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4 Legal Basis for Processing

22rs processes your personal data on one or more of the following legal grounds, depending on the purpose of processing:

  • Contract performance: Processing that is necessary to provide the 22rs service you have signed up for — including account creation, deposit processing, gameplay, withdrawal fulfilment, and customer support. Without this processing, 22rs cannot operate your account.
  • Legal obligation: Processing required by applicable financial regulations, including Anti-Money Laundering (AML) rules and Know Your Customer (KYC) obligations. 22rs is required by law to collect and retain certain identity and transaction data and to report suspicious activity to relevant authorities.
  • Legitimate interests: Processing conducted to protect the integrity of the 22rs platform — including fraud detection, responsible gaming monitoring, security incident investigation, and general platform improvement — where our interests in running a safe and fair platform do not override your privacy rights.
  • Consent: Marketing communications and optional personalisation features are processed only where you have given clear consent. You may withdraw consent at any time as described in Section 12.
5 How We Use Your Personal Data

22rs uses your personal data for the following purposes, each of which is tied to a legitimate reason for processing:

  • Account management: Creating and maintaining your 22rs account, authenticating logins, processing account settings changes, and communicating account-related updates.
  • Payment processing: Processing PKR deposits and withdrawals via your chosen payment method, reconciling balances, handling failed transactions, and managing refunds or reversals.
  • Identity verification (KYC): Verifying your identity and age before processing your first withdrawal, and at any point where regulatory obligations or risk indicators require verification.
  • Fraud and security: Detecting and preventing unauthorised account access, payment fraud, multi-accounting, bonus abuse, and other conduct that breaches the 22rs Terms and Conditions or applicable law.
  • Responsible gaming compliance: Monitoring gameplay patterns to identify players who may be experiencing gambling-related harm, applying responsible gaming tools, and maintaining exclusion records.
  • Customer support: Responding to your queries, investigating complaints, and maintaining a record of support interactions to provide continuity of service.
  • Legal compliance and reporting: Fulfilling AML reporting obligations, responding to lawful requests from regulatory or law enforcement authorities, and maintaining records as required by applicable financial regulations.
  • Platform improvement: Aggregated, anonymised analysis of gameplay patterns, feature usage, and technical performance to improve the 22rs product for Pakistani players.
  • Marketing (with consent only): Sending promotional communications about 22rs offers, new games, tournaments, and VIP Club updates to players who have opted in. See Section 12.
What we do not do: 22rs does not use your personal data for automated decision-making that produces significant legal effects without human review. We do not create personal profiles for sale to advertisers. We do not use your data to discriminate against you in ways unrelated to legitimate gaming activity assessment.
6 Who We Share Your Data With

22rs does not sell your personal data. We share it only with the categories of third parties listed below, and only to the extent necessary for the stated purpose:

Third Party Type Purpose Data Shared
Payment Processors
Easypaisa, JazzCash, NayaPay, SadaPay, bank partners, Visa/Mastercard acquirers
Processing PKR deposits and withdrawals Name, account/wallet identifier, transaction amount and reference
Identity Verification Partner KYC document authentication Document images (CNIC/passport), selfie (if required), extracted document data
Game Software Providers Delivering certified game content Session token, balance updates — providers do not receive your full identity data
Fraud Prevention Tools Risk scoring and anomaly detection IP address, device fingerprint, velocity data — no full identity data sent
Regulatory Authorities Legal / AML reporting obligations As required by applicable law — 22rs cannot limit this sharing
IT Infrastructure Providers Hosting, database, security services Encrypted data at rest; providers process under strict confidentiality agreements

All third parties who receive personal data from 22rs are bound by contractual obligations to handle it securely, use it only for the purpose for which it was shared, and not retain it beyond the period necessary for that purpose.

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7 Cookies & Tracking Technologies

22rs uses cookies and similar tracking technologies (local storage, session tokens) to operate the platform correctly and to improve your experience as a Pakistani player. Cookies are small text files stored in your browser or device when you visit 22rs.biz.

The categories of cookies used by 22rs are:

  • Essential cookies: Required for the platform to function. These include your login session token, balance display preferences, and CSRF protection cookies. They cannot be disabled without breaking the 22rs service.
  • Functional cookies: Remember your language preference, game lobby filters, and last-viewed sections so the platform feels consistent between sessions on 22rs.
  • Analytics cookies: Collect anonymised data on how pages are used — which sections are visited most, how long sessions last, and where players exit the registration flow. This data helps 22rs improve the platform. No personally identifiable information is included in analytics reports.
  • Security cookies: Record device and session fingerprints to detect account takeover attempts and anomalous login patterns.

22rs does not use third-party advertising cookies or allow ad networks to track players across other websites via the 22rs platform. You may manage non-essential cookies through your browser settings. Disabling all cookies will prevent you from logging in to your 22rs account.

8 Data Security

22rs implements technical and organisational security measures appropriate to the sensitivity of the data we hold and the risks to Pakistani players from unauthorised access or disclosure. These measures include:

  • Encryption in transit: All data transmitted between your device and the 22rs platform is encrypted using TLS (Transport Layer Security). Your connection to 22rs.biz is always HTTPS.
  • Encryption at rest: Sensitive fields including identity document data, financial account identifiers, and KYC verification records are encrypted at rest in the 22rs database.
  • Access controls: Access to personal data within 22rs's internal systems is restricted to staff with a legitimate operational need. All internal access is logged and audited.
  • Security testing: 22rs conducts regular security assessments including vulnerability scanning and penetration testing of key infrastructure components.
  • Incident response: In the event of a data breach that poses a risk to players, 22rs will notify affected players by email as quickly as possible and take immediate steps to contain and remediate the incident.
No system is completely immune to security incidents. You can also protect your own account by using a strong, unique password and not sharing your 22rs login credentials with anyone. If you suspect your account has been accessed without authorisation, contact 22rs support immediately at support@22rs.biz.
9 Data Retention

22rs retains personal data only for as long as there is a legitimate reason to do so. The following retention periods apply:

  • Active account data: Retained for as long as your 22rs account remains open and for a period after closure as described below.
  • Financial and KYC records: Retained for a minimum of five years from account closure in compliance with AML regulations. In some cases, a longer retention period may apply if an account is subject to an investigation or legal proceedings at the time of closure.
  • Customer support records: Retained for three years from the date of the interaction, unless the content of the interaction requires longer retention under AML or dispute resolution obligations.
  • Self-exclusion records: Retained indefinitely to prevent a re-registration by a player who has self-excluded, even if the exclusion period has formally ended. This is a responsible gaming safeguard.
  • Marketing consent records: Retained until consent is withdrawn, plus one year to demonstrate compliance if challenged.
  • Technical / log data: Access logs and session data are retained for 90 days for security incident investigation purposes, then deleted.

When data is no longer required, 22rs deletes or anonymises it in a secure and irreversible manner. Anonymised aggregate data (with no possibility of re-identifying individuals) may be retained indefinitely for statistical analysis.

10 Your Privacy Rights

As a 22rs player and data subject, you have the following rights regarding the personal data we hold about you. All requests should be directed to support@22rs.biz with your account username and a description of your request.

Right of Access
Request a copy of the personal data 22rs holds about you. We will provide this within 30 days of receiving a valid request.
Right to Rectification
Request correction of any inaccurate or incomplete personal data. Most contact detail updates can be made directly in your 22rs account settings.
Right to Erasure
Request deletion of your personal data where we no longer have a legitimate reason to hold it. Note that legal retention obligations (AML) may prevent full erasure immediately after account closure.
Right to Restriction
Request that we limit how your data is used while a correction or objection request is being processed, rather than deleting it outright.
Right to Portability
Receive your personal data in a structured, commonly used, machine-readable format where the processing was based on your consent or a contract with 22rs.
Right to Object
Object to processing based on 22rs's legitimate interests, including profiling for responsible gaming monitoring. We will review and respond within 30 days.

22rs will respond to all valid privacy rights requests within 30 days. Where a request is complex or involves a high volume of data, we may extend this by a further 60 days, in which case we will notify you of the extension and the reason for it.

Verification required: To protect your privacy, 22rs will verify your identity before processing any data access, correction, or erasure request. You will be asked to confirm your account details and may be asked to provide a copy of your CNIC.
11 Children's Privacy

The 22rs platform is strictly for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. Age verification is conducted as part of the registration process and again at the KYC verification stage before a first withdrawal is processed.

If you are a parent or guardian and you believe that a minor has registered on 22rs using false age information, please contact us immediately at support@22rs.biz with the account details. We will investigate and act within 24 hours — the account will be suspended pending investigation, and if a minor is confirmed, the account will be permanently closed and any deposited funds returned to the originating payment method.

We encourage parents and guardians in Pakistan to use parental control software to prevent minors from accessing online gaming or gambling websites. 22rs cooperates fully with any responsible party seeking to protect minors from gambling-related harm.

12 Marketing Communications

22rs sends marketing communications — including promotional offers, new game announcements, tournament invitations, and VIP Club updates — only to players who have opted in to receive them. Opting in is a separate, voluntary action during or after registration and is never a condition of using the 22rs platform.

Marketing communications are sent by email and, where you have provided consent, by SMS to your registered Pakistani mobile number. 22rs does not use WhatsApp groups, social media messaging, or phone calls for mass marketing.

You can withdraw your marketing consent at any time by:

  • Clicking the "Unsubscribe" link in any 22rs marketing email.
  • Updating your notification preferences in your 22rs account settings under the Communications section.
  • Contacting 22rs support at support@22rs.biz and requesting removal from marketing communications.

Withdrawal of marketing consent does not affect your ability to use the 22rs platform or claim bonuses. Transactional communications — including deposit confirmations, withdrawal notifications, account security alerts, and KYC requests — are not marketing communications and will continue to be sent regardless of your marketing consent status.

13 Changes to This Privacy Policy

22rs reviews this Privacy Policy regularly and updates it when necessary to reflect changes in how we operate the platform, changes in applicable data protection law, or feedback from players and regulators. The "Last Updated" date at the top of this page shows when the current version came into effect.

Where changes are material — meaning they affect your rights, the types of data we collect, or the purposes for which we use it — 22rs will notify registered players by email to their registered address and by an in-platform notification at next login. Minor clarifications and corrections that do not alter the substance of the policy will be applied without advance notice.

Continuing to use the 22rs platform after notification of a material policy update constitutes your acceptance of the revised Privacy Policy. If you object to any change, you may request account closure as described in the Terms and Conditions.

14 Contact & Privacy Enquiries

For any questions about this Privacy Policy, to exercise your data rights, or to raise a privacy-related concern about how 22rs handles your personal data, please get in touch through the channels below:

Email (Privacy Requests)
support@22rs.biz — include "Privacy Request" in your subject line and your 22rs username.
Live Chat
Available 24/7 from your logged-in 22rs account dashboard. Best for quick queries and account-level requests.
Response Times
Privacy rights requests: within 30 days as required by applicable law. General privacy queries via email: within 2 business days. Live chat: under 5 minutes.

For responsible gaming support specifically, please visit the Responsible Gaming page which contains additional tools and contacts relevant to players in Pakistan experiencing gambling-related concerns.

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