222bat Privacy Policy

1 Who We Are

222bat operates the online casino and sports betting platform accessible at 222bat.cam and its associated mobile-optimised interfaces. References to "222bat", "we", "us", and "our" throughout this Privacy Policy refer to the operator entity responsible for the 222bat platform and all services delivered through it.

222bat operates under an international gaming licence and is committed to maintaining robust data protection standards consistent with the obligations imposed by that licence and applicable international privacy frameworks. The 222bat platform is designed for and primarily serves English-speaking Pakistani players seeking a regulated, transparent online gaming environment.

For any privacy-related queries, the 222bat compliance team can be reached via the live chat facility on the platform or by email at the address listed in Section 15 of this Policy. Email addresses on this page are displayed as plain text and are not clickable links.

2 Scope of This Policy

This Privacy Policy applies to all personal data collected and processed by 222bat in connection with:

• Your registration and maintenance of a 222bat account.
• Your use of any game, betting market, live dealer table, or other service offered on the 222bat platform.
• Any deposit, withdrawal, or other financial transaction conducted through the platform using methods including JazzCash, EasyPaisa, Raast, HBL, UBL, and Meezan Bank.
• Your communications with the 222bat customer support team, whether via live chat, email, or any other channel.
• Your participation in promotions, bonuses, loyalty programmes, or surveys operated by 222bat.
• Your browsing of the 222bat website, including pages you visit and features you interact with, as captured through cookies and analytics tools.

This Policy does not apply to any third-party websites, services, or platforms that may be referenced or linked from the 222bat platform. 222bat is not responsible for the privacy practices of any third party.

3 Personal Data We Collect

222bat collects personal data across several categories, each justified by a specific operational, legal, or regulatory purpose:

4 How We Collect Your Data

222bat collects personal data through the following primary channels:

• Direct Collection: Information you provide when registering a 222bat account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated Collection: Technical and usage data gathered automatically when you access the 222bat platform, including through cookies, server logs, and analytics tools. This data is collected regardless of whether you are logged into your account.
• Third-Party Sources: Identity verification data obtained from KYC and anti-money laundering service providers. Fraud signals obtained from risk management and payment processing partners. Device reputation data obtained from cybersecurity partners where applicable.
• Payment Providers: Transaction confirmation data received from payment partners including JazzCash, EasyPaisa, Raast, and partnered banks such as HBL, UBL, and Meezan Bank, to reconcile deposits and withdrawals to your 222bat account.

5 Purpose and Legal Basis for Processing

222bat processes your personal data only where we have a clearly identified and documented lawful basis. The table below maps our key processing activities to their corresponding purposes and legal bases:

• Contract Performance: Processing necessary to register your account, provide gaming and betting services, process PKR transactions, and operate the 222bat loyalty programme.
• Legal Obligation: KYC and identity verification, anti-money laundering screening, age verification (21+ requirement), regulatory reporting to the licensing authority, and tax-related record keeping.
• Legitimate Interests: Fraud detection and prevention, platform security monitoring, responsible gaming tool operation, customer support quality assurance, and product improvement analytics — where these interests are not overridden by your rights.
• Consent: Sending you promotional emails, SMS, or push notifications about 222bat offers, new games, and PSL or cricket betting markets — only where you have explicitly opted in. You may withdraw this consent at any time via your account settings or by contacting support.

6 Sharing Your Personal Data

222bat does not sell or rent your personal data to any third party. We may share your data with the following categories of recipients where strictly necessary for the purposes described in this Policy:

• Payment Service Providers: JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and any other payment processor necessary to complete your deposit or withdrawal transactions. These providers receive only the minimum data required to process your transaction securely.
• KYC and Compliance Partners: Third-party identity verification and anti-money laundering screening services engaged by 222bat to fulfil its regulatory obligations under its gaming licence. These partners are contractually bound to process your data solely for the purpose for which it is shared.
• Technology and Infrastructure Providers: Cloud hosting, data storage, cybersecurity, and platform analytics providers who process data on 222bat's behalf as data processors under binding data processing agreements.
• Regulatory and Law Enforcement Authorities: Where required by law, court order, or regulatory directive, 222bat will disclose personal data to the relevant gaming regulator, financial intelligence authority, or law enforcement body.
• Game Software Providers: Where the rules of a specific game require communication with the game's RNG certification body or software provider for audit purposes, limited technical session data may be shared. No identifiable personal data is shared with game providers beyond what is necessary for regulatory certification.

All third parties with whom 222bat shares personal data are subject to contractual obligations requiring them to maintain appropriate technical and organisational security measures and to use the data only for the specified purpose.

7 Data Retention

222bat retains personal data for no longer than is necessary for the purpose for which it was collected, taking into account legal, regulatory, and operational retention requirements. The key retention periods applied by 222bat are as follows:

• Active Account Data: Retained for the full duration of your account relationship with 222bat, and for a period of five (5) years following account closure, to satisfy anti-money laundering record-keeping obligations.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of verification, as required under applicable gaming licence conditions and AML regulations.
• Transaction Records: Retained for five (5) years from the date of the transaction, consistent with financial record-keeping requirements.
• Customer Support Communications: Retained for three (3) years from the date of the interaction, to allow for dispute resolution and service quality review.
• Technical and Usage Data: Retained for a period of up to twenty-four (24) months from collection for analytics and fraud prevention purposes, after which it is aggregated or deleted.
• Marketing Consent Records: Retained for the duration of your opt-in period and for one (1) year following opt-out, to evidence your consent history.

When data reaches the end of its applicable retention period, 222bat will securely delete or anonymise it in a manner that prevents recovery or reconstruction.

8 Security Measures

222bat implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 222bat platform, including during 222bat login sessions and payment processing.
• Encryption at rest for sensitive personal data stored in 222bat's databases, including financial records and identity documents submitted for KYC.
• Role-based access controls that restrict internal access to personal data to only those staff members who require it for their specific operational responsibilities.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• Multi-factor authentication requirements for all internal system access by 222bat staff.
• Automated monitoring and alerting systems designed to detect and respond to unusual access patterns or potential security incidents in real time.
• Documented incident response procedures, including mandatory breach notification to the relevant regulatory authority where a personal data breach meets the applicable notification threshold.

9 Cookies and Tracking Technologies

222bat uses cookies — small text files stored on your device — and similar tracking technologies including pixel tags and local storage objects. The categories of cookies used on the 222bat platform are as follows:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies that keep you logged into your 222bat account, security tokens, and load-balancing cookies. These cannot be disabled without rendering the platform unusable.
• Functional Cookies: Remember your preferences — such as language settings, display preferences, and responsible gaming tool configurations — to personalise your experience on repeat visits.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate the 222bat platform — which pages are most visited, which features are used most frequently, and where technical issues arise. This data informs product improvements and is not used to identify you personally.
• Marketing Cookies: Used only where you have given explicit consent to receive personalised promotional communications. These may track whether you have opened a 222bat email or interacted with a promotional notification.

You may manage or withdraw your cookie preferences at any time. Essential cookies cannot be disabled. For other categories, preferences can be updated via the cookie settings panel accessible in the platform footer.

10 International Data Transfers

222bat operates under an international gaming licence, and as a result, some of the infrastructure, service providers, and compliance partners engaged by 222bat may be located in jurisdictions outside Pakistan. Where personal data is transferred internationally, 222bat ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses or equivalent transfer mechanisms approved by the relevant regulatory authority, incorporated into agreements with all third-party data processors and sub-processors.
• Transfers to jurisdictions that have been assessed as providing an adequate level of data protection comparable to the standards 222bat is required to maintain under its licensing obligations.
• Binding corporate rules or equivalent intra-group transfer frameworks where data is shared within 222bat's associated corporate structure.

Further information on the specific safeguards applicable to any particular international transfer can be obtained by contacting the 222bat compliance team at the address listed in Section 15.

11 Your Privacy Rights

Subject to the conditions and limitations imposed by applicable law and 222bat's regulatory obligations, you hold the following rights in respect of your personal data:

• Right of Access: You may request a copy of all personal data 222bat holds about you, together with information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held in your 222bat account.
• Right to Erasure: In certain circumstances — for example, where data is no longer necessary for the purpose for which it was collected — you may request deletion of your personal data. This right does not apply where retention is required by law or regulatory obligation.
• Right to Restriction of Processing: You may request that 222bat temporarily ceases processing your data — for example, while a dispute about its accuracy is being resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you may request that 222bat provide your data in a structured, machine-readable format for transfer to another service provider.
• Right to Object: You may object to processing of your personal data where that processing is based on legitimate interests. 222bat will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent — such as marketing communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact the 222bat compliance team via live chat on the platform or by email. 222bat will respond to all valid requests within the timeframes required under applicable data protection law, typically within thirty (30) days of receipt.

12 Children's Privacy

The 222bat platform is strictly intended for adults aged 21 years and above. 222bat does not knowingly collect, store, or process personal data belonging to individuals under the age of 21. Registration on the 222bat platform requires affirmative confirmation that the applicant meets the minimum age requirement, and age verification documentation may be requested at any point during the account lifecycle.

Parents and guardians in households with minors are encouraged to make use of parental control and internet filtering software to prevent access to gambling platforms by underage family members.

13 Third-Party Links and Services

The 222bat platform may contain references to third-party services — for example, payment providers such as JazzCash and EasyPaisa — whose own privacy policies and data handling practices are independent of and separate from this Policy. When you interact with a third-party service in connection with a 222bat transaction, you should review that provider's privacy policy directly.

222bat is not responsible for the privacy practices, data security standards, or content of any third-party website or service. The inclusion of a reference to a third-party provider on the 222bat platform does not constitute an endorsement of that provider's privacy practices.

14 Amendments to This Privacy Policy

222bat reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or the way in which 222bat processes personal data. The date of the most recent revision is displayed in the "Last Updated" bar at the top of this page.

Where amendments are material — meaning they significantly affect how your personal data is processed or the rights available to you — 222bat will notify registered account holders by email or via a prominent notice on the platform prior to the changes taking effect. For non-material updates, the revised Policy will be published on this page with an updated effective date.

Continued use of the 222bat platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not accept the revised Policy, you should cease using the platform and contact support to arrange account closure.

15 Contact and Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which 222bat processes your personal data, please contact the 222bat compliance and privacy team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly on the 222bat platform following login.
• Email: [email protected] (plain text — not a clickable link)

222bat aims to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within thirty (30) days. Complex requests involving multiple data categories or regulatory consultation may require additional time, and you will be kept informed of progress throughout.

If you are not satisfied with 222bat's response to a privacy complaint, you may escalate the matter to the data protection authority or gaming regulatory body responsible for overseeing 222bat's operations under its international gaming licence. Details of the relevant supervisory authority are available upon request from the 222bat compliance team.