22atm Privacy Policy

This Privacy Policy is issued by the 22atm online gaming platform, accessible at https://22atm.app (referred to herein as "22atm", "we", "us", or "our"). It describes how we collect, process, store, share, and protect the personal data of individuals who register accounts, visit our website, or otherwise interact with our services (referred to as "you", "your", or "Player").

22atm is committed to maintaining the highest standards of data privacy. We handle all personal information in accordance with applicable data protection laws and our internal data governance framework. This Privacy Policy should be read alongside the 22atm Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

This policy applies to all personal data collected through the 22atm website, mobile-optimised platform, customer support channels, and any other touchpoints through which you interact with 22atm. It does not apply to third-party websites or services that may be linked to or from our platform.

22atm collects personal data through several channels — directly from you at registration and during account operation, automatically through your use of the platform, and from authorised third-party verification partners. The categories of data we collect are set out below.

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric data, or health data, except where strictly required by applicable law or regulatory obligation (for example, problem gambling self-declaration data provided voluntarily by a Player through our Responsible Gaming tools).

22atm uses your personal data only for the specific, legitimate purposes listed below. We do not use your data for any purpose that is incompatible with the original reason it was collected without first obtaining your explicit consent.

• Account creation and management: To set up, verify, and maintain your 22atm account, including processing registration details, verifying your identity, and managing your account preferences and security settings.
• Service delivery: To provide access to cricket betting, live casino, jackpot slots, and all other gaming services available on the 22atm platform, and to process your deposits, wagers, and withdrawals accurately and promptly.
• KYC and fraud prevention: To conduct Know Your Customer identity checks required before processing withdrawals, to detect and prevent fraudulent activity, bonus abuse, multi-accounting, and money laundering, and to fulfil our anti-money laundering obligations.
• Responsible gaming: To monitor gaming patterns for indicators of problem gambling, to enforce deposit limits and self-exclusion requests, and to communicate responsible gaming information to Players where appropriate.
• Customer support: To respond to your enquiries, complaints, and support requests through live chat, email, and any other support channels, and to maintain records of those interactions for quality assurance and dispute resolution purposes.
• Legal and regulatory compliance: To comply with applicable laws, respond to lawful requests from regulatory authorities, and to meet our record-keeping obligations under anti-money laundering and data protection regulations.
• Platform improvement: To analyse aggregated usage data in order to improve platform performance, fix technical issues, develop new features, and optimise the overall player experience on 22atm.
• Marketing communications (opt-in only): To send promotional offers, bonus notifications, and news about 22atm services to Players who have expressly opted in to receive such communications. You may withdraw this consent at any time via your account settings or by contacting support.

22atm processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between you and 22atm — including account creation, service delivery, payment processing, and customer support — is carried out on the basis that it is necessary for the fulfilment of that contract.
• Legal obligation: Certain processing activities — including KYC verification, anti-money laundering checks, and the retention of transaction records — are carried out because 22atm is legally required to do so under applicable regulations.
• Legitimate interests: 22atm processes technical and usage data for fraud prevention, platform security, and service improvement on the basis of our legitimate interests, provided those interests are not overridden by your fundamental privacy rights.
• Consent: Where we rely on consent — for example, for opt-in marketing communications or for voluntary submission of responsible gaming self-assessment information — you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

22atm does not sell, rent, or trade your personal data to third parties for their independent commercial use. We share your data only in the limited circumstances described below, and only to the extent strictly necessary for the relevant purpose.

• KYC and identity verification providers: We share identity documents and personal details with authorised third-party KYC verification partners for the purpose of confirming your identity and age prior to account approval and withdrawal processing.
• Payment processors: We share the minimum transaction data necessary with payment service providers including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other approved processors to facilitate deposits and withdrawals.
• Game providers and platform vendors: Licensed game studios and software vendors who power casino games, live tables, and sports betting markets on the 22atm platform may receive limited usage data strictly for the purpose of game delivery and technical support.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory direction, 22atm will disclose personal data to the relevant government or regulatory authority. We will only do so to the extent legally compelled.
• Professional advisers: Our legal counsel, auditors, and compliance consultants may have access to personal data on a strictly confidential and need-to-know basis in connection with the provision of professional services to 22atm.

All third-party service providers who receive personal data from 22atm are contractually required to process that data in accordance with applicable data protection standards and solely for the purpose for which it was disclosed.

The 22atm platform uses cookies and similar tracking technologies to ensure the platform functions correctly, to maintain your session security, and to gather anonymised performance analytics. The types of cookies we use are described below:

• Strictly necessary cookies: These cookies are essential for the platform to operate. They manage your login session, maintain your language and currency preferences, and protect against cross-site request forgery attacks. These cookies cannot be disabled without breaking core platform functionality.
• Analytics cookies: We use anonymised analytics cookies to understand how players navigate the 22atm platform — which pages are most visited, where players encounter errors, and how sessions typically flow. This data is aggregated and never linked to individual identities for marketing purposes.
• Fraud prevention cookies: Certain cookies assist our security systems in identifying unusual access patterns, automated bot activity, and multi-account behaviour. These cookies are a core component of our player protection infrastructure.
• Preference cookies: These store non-sensitive preferences such as your chosen display settings and notification preferences to improve your experience on repeat visits.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect platform functionality. 22atm does not use third-party advertising cookies or behavioural profiling cookies for the purpose of serving targeted ads on external platforms.

22atm retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention principles apply:

• Active account data: Personal data associated with an active 22atm account is retained for the duration of the account relationship and for a minimum of five years following permanent account closure, in order to meet anti-money laundering record-keeping requirements.
• Transaction records: Financial transaction records including deposit history, withdrawal records, and wagering data are retained for a minimum of five years from the date of the transaction.
• KYC and identity documents: Verification documents submitted during the KYC process are retained for the period required by applicable regulations, typically five years from the end of the business relationship.
• Support communications: Customer support transcripts and email correspondence are retained for three years from the date of the interaction, or longer where the communication relates to an unresolved dispute or regulatory matter.
• Marketing data: Data held solely for the purpose of sending marketing communications is deleted promptly upon withdrawal of consent or account closure.

As a player on the 22atm platform, you have the following rights in respect of your personal data. To exercise any of these rights, contact our support team at [email protected] with your account username and a clear description of your request. 22atm will respond within 30 calendar days.

• Right of access: You have the right to request a copy of all personal data that 22atm holds about you, together with information about how it is being processed.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it without undue delay.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where you object to processing based on legitimate interests. This right is subject to our legal retention obligations.
• Right to restriction: You have the right to request that 22atm restricts processing of your data in certain circumstances — for example, while we verify the accuracy of data you have contested.
• Right to data portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing based on legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

22atm implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes the following safeguards:

• Encryption: All data transmitted between your device and the 22atm platform is encrypted using TLS 1.3. Stored personal data and financial records are encrypted at rest using AES-256.
• Access controls: Access to personal data within 22atm's systems is strictly limited on a role-based, need-to-know basis. All internal access is logged and audited. Administrative access requires multi-factor authentication.
• Infrastructure security: 22atm's platform is hosted in enterprise-grade data centres equipped with physical security controls, continuous network monitoring, intrusion detection systems, and regular independent penetration testing.
• Incident response: In the event of a data security incident that poses a risk to your rights and freedoms, 22atm will notify affected players and relevant authorities within the timeframes required by applicable law, and will take immediate remediation action.

The 22atm platform is strictly an adults-only service. We do not knowingly collect personal data from individuals under the age of 21. The platform employs age verification procedures at registration and during the KYC process to enforce this restriction.

If 22atm becomes aware that personal data has been collected from an individual under the age of 21, we will immediately suspend the relevant account, delete the personal data collected, return any deposited funds to the original payment method, void any winnings generated, and report the matter to the relevant authorities where legally required.

As an online platform serving Pakistani players with global technology infrastructure, 22atm may transfer personal data to and process it in countries outside Pakistan. Such transfers may occur when data is processed by our KYC partners, payment processors, or cloud infrastructure providers who operate internationally.

Where personal data is transferred to a country that does not provide an equivalent level of data protection to that applicable in Pakistan, 22atm ensures that appropriate safeguards are in place. These safeguards include:

• Contractual data protection clauses that require the receiving party to handle your data to the same standard required by 22atm's Privacy Policy.
• Due diligence assessments of third-party processors prior to engagement, including review of their data security certifications and privacy practices.
• Limiting the data transferred to the minimum necessary for the specific processing purpose.

By using the 22atm platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject always to the safeguards outlined above.

22atm reserves the right to update or amend this Privacy Policy at any time. The most current version will always be accessible at https://22atm.app/privacy-policy. The "Last Updated" date at the top of this policy reflects the date of the most recent revision.

Where changes to this Privacy Policy are material — meaning they significantly affect the way we collect or use your personal data — 22atm will notify active account holders via their registered email address prior to the changes taking effect, where reasonably practicable. For minor or clarificatory amendments, we will update the policy without individual notification.

Your continued use of the 22atm platform following the effective date of any amendment to this Privacy Policy constitutes your acceptance of the revised policy. If you do not accept the revised terms, you must cease using the platform and contact support to arrange account closure and data deletion where applicable.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 22atm handles your personal data, please contact our dedicated data privacy support team through the following channels:

• Live Chat: Available 24/7 within your logged-in account dashboard. This is the fastest channel for general privacy queries and data access requests.
• Email: [email protected] — please include "Privacy Request" in your subject line along with your account username and a clear description of your query. We acknowledge all privacy-related emails within 24 hours and provide a substantive response within 30 calendar days.

For formal data subject access requests, erasure requests, or complaints regarding 22atm's data processing practices, please mark your correspondence clearly as a formal data request. 22atm will process all formal requests in accordance with applicable data protection law and the timelines described in Section 8 of this policy.

This Privacy Policy was last reviewed and updated in January 2026. The version published at https://22atm.app/privacy-policy supersedes all previous versions.