Data Protection & Privacy
Your privacy matters to us. This Privacy Policy explains exactly what personal data 22atm collects from users across Pakistan, how that data is used, who it may be shared with, and the rights you hold over your own information. Please read it carefully alongside our Terms & Conditions.
Privacy at a Glance
Before reading the full policy, here is a plain-English summary of the six principles that underpin how 22atm handles your personal data.
We collect only the personal data that is genuinely necessary to operate your account, process transactions, verify your identity and comply with our legal obligations. No data is collected speculatively.
All personal data held by 22atm is stored and transmitted using industry-standard encryption protocols. Internal access to personal data is restricted on a strict need-to-know basis.
22atm does not sell, rent or trade your personal data to third-party marketers without your explicit prior consent. Your data is not a commodity.
You have the right to access, correct, restrict and — where applicable — request deletion of the personal data we hold about you. All requests are handled promptly and transparently.
We explain clearly what cookies and tracking technologies we use on the 22atm platform, what purpose they serve, and how you can manage your cookie preferences.
In the unlikely event of a data breach that affects your personal information, 22atm will notify affected users and relevant authorities within the timeframes required by applicable law.
22atm ("the Platform", "we", "us", "our") is committed to protecting the personal data of all users who interact with our platform. This Privacy Policy sets out in clear, transparent terms the categories of personal data we collect, the purposes for which that data is processed, the conditions under which it may be disclosed to third parties, the security measures we employ to protect it, and the rights available to you as a data subject.
22atm operates as an English-language online betting and casino information platform serving users across Pakistan — from Karachi and Lahore to Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. Our platform is designed for adult users only, and responsible data stewardship is an integral part of our commitment to running a trustworthy service.
This Privacy Policy was last reviewed and updated on 1 January 2026. Any material changes to this policy will be communicated to registered users before taking effect, in accordance with Section 14 below.
The Data Controller for Personal Data processed through the 22atm platform is the 22atm operator as identified in the platform's licensing and registration documentation. The platform is operated under a licence issued by the relevant regulatory authority in the operator's jurisdiction of incorporation.
22atm does not claim to be regulated by any Pakistani government body, the PTA, the State Bank of Pakistan or any provincial authority. Users located in Pakistan are responsible for satisfying themselves as to the legal status of online gambling in their jurisdiction before using the Platform. Nothing in this Privacy Policy constitutes legal advice regarding Pakistani law.
For all data-related queries and rights requests, please use the contact channels described in Section 15.
22atm collects Personal Data from Users through four primary channels: direct registration input, platform usage and behaviour, payment transaction processing, and automated technical collection. The specific categories of data collected are set out in the table below.
| Data Category | Examples | Collection Method |
|---|---|---|
| Identity Data | Full name, date of birth, CNIC / passport number, nationality | Registration form; KYC document upload |
| Contact Data | Email address, phone number, city of residence | Registration form; account settings |
| Financial Data | Deposit / withdrawal history, payment method identifiers (e.g., Easypaisa wallet reference, HBL account last four digits) | Payment processing; transaction logs |
| Technical Data | IP address, browser type, device model, operating system, session timestamps | Automated server logging; analytics cookies |
| Usage Data | Pages visited, games played, bet history, session duration, responsible gambling limit settings | Platform activity tracking |
| Communication Data | Live chat transcripts, support email correspondence, feedback submissions | Support channels; Help Center |
22atm processes Personal Data only where a valid lawful basis exists. The following lawful bases apply to the processing activities described in this Policy:
Personal Data collected by 22atm is used for the following purposes:
Identity and Contact Data are used to create and maintain your registered account, enable secure login, process password resets, communicate account-related notifications and facilitate KYC verification before withdrawals are authorised.
Financial Data is processed to execute deposit and withdrawal requests, verify payment method ownership, maintain accurate account balance records and generate transaction histories accessible within your account dashboard.
Usage Data and account activity information are monitored to identify patterns that may indicate problem gambling behaviour, to enforce the responsible gambling limits set by the User (deposit limits, loss limits, session time limits), and to action self-exclusion requests promptly. This processing is conducted in the interests of User welfare and regulatory compliance.
Technical Data and Usage Data are analysed to detect and prevent fraudulent activity, multi-accounting, money laundering and other prohibited conduct as defined in our Terms & Conditions. This analysis is conducted using automated systems and, where necessary, manual review by authorised staff.
Aggregated and anonymised Usage Data is used to understand how users navigate the Platform, which features generate the most engagement, and where the user experience can be improved. This analysis does not identify individual users.
Communication Data from support interactions is retained to manage ongoing queries, maintain accurate records of dispute histories and improve support team performance. Support transcripts are accessible to authorised support staff only.
Where you have explicitly opted in to receive marketing communications, 22atm may use your Contact Data to send promotional offers, bonus notifications and platform updates. You may unsubscribe from marketing communications at any time via your account settings or by following the unsubscribe link in any marketing email.
22atm does not sell, rent or trade your Personal Data to third parties for marketing purposes. Personal Data may be disclosed in the following limited circumstances:
We engage trusted third-party service providers to perform functions on our behalf — including payment processing, KYC and identity verification, fraud detection, cloud infrastructure hosting, customer support tooling and email delivery. These service providers access Personal Data only to the extent necessary to perform their contracted functions and are bound by written data processing agreements that prohibit them from using the data for any other purpose.
22atm may disclose Personal Data to regulatory bodies, law enforcement agencies, tax authorities or courts where required to do so by applicable law, a valid legal order or our licence obligations. In such cases, disclosure will be limited to the minimum data required to fulfil the legal obligation.
In the event of a merger, acquisition, restructuring or sale of all or part of the 22atm business, Personal Data held by the platform may be transferred to the successor entity as part of that transaction. Users will be notified of any such transfer and the Privacy Policy applicable to their data following the transfer before it takes effect.
Subject to Section 7.1 to 7.3 above, 22atm will not share your Personal Data with any third party for purposes other than those described in this Policy without first obtaining your explicit consent.
22atm uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used are described below.
| Cookie Type | Purpose | Consent Required? |
|---|---|---|
| Strictly Necessary | Maintain your login session, remember language preferences, prevent cross-site request forgery and enable core platform functionality. | No — essential for service delivery |
| Performance / Analytics | Collect aggregated, anonymised data on how users navigate the Platform to identify performance issues and improve the user experience. | Yes — consent-based |
| Functional | Remember user preferences such as display settings, preferred deposit method and last-used game category to personalise the experience. | Yes — consent-based |
| Marketing / Targeting | Used only where the User has opted in to receive personalised promotions and relevant platform communications. | Yes — explicit opt-in required |
You may manage your cookie preferences at any time via the cookie settings panel accessible from the Platform footer or your browser's privacy settings. Disabling strictly necessary cookies may impair your ability to use core platform features including logging in and accessing your account balance.
22atm retains Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal, regulatory and licensing obligations. The following general retention principles apply:
Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised.
22atm employs a layered approach to Personal Data security, commensurate with the sensitivity of the data held and the risks posed by unauthorised access, loss, destruction or disclosure. Our security measures include, but are not limited to:
While 22atm takes reasonable and appropriate steps to protect your Personal Data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account password and for ensuring that your own device security is adequate.
Subject to applicable law and the conditions of our operating licence, you have the following rights in relation to the Personal Data 22atm holds about you. To exercise any of these rights, please contact us using the details in Section 15.
Right of Access
You may request a copy of the Personal Data 22atm holds about you, together with information about how that data is being processed. We will respond to verified access requests within 30 days.
Right to Rectification
If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request its correction. You may update most account details directly via your account settings.
Right to Erasure ("Right to be Forgotten")
You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and no other lawful basis applies. Note that certain data must be retained for the periods specified in Section 9 to comply with legal and regulatory obligations.
Right to Restriction of Processing
You may request that 22atm restricts the processing of your Personal Data in certain circumstances — for example, while a rectification request is under review or where you contest the lawfulness of our processing.
Right to Data Portability
Where processing is based on your consent or a contract and is carried out by automated means, you may request a copy of your Personal Data in a structured, commonly used and machine-readable format.
Right to Object
You have the right to object to the processing of your Personal Data where that processing is based on the legitimate interests of 22atm. You also have an unconditional right to object to the use of your data for direct marketing purposes.
Rights Relating to Automated Decision-Making
Where 22atm makes decisions that significantly affect you solely by automated means (such as automated fraud flagging), you have the right to request human review of that decision, to express your point of view and to contest the outcome.
22atm's services are strictly limited to adults aged 18 years or older — or the higher minimum age required by the applicable operator licence jurisdiction. 22atm does not knowingly collect Personal Data from minors. If we become aware that Personal Data has been collected from a person below the applicable minimum age, we will take immediate steps to delete that data and close the associated account.
If you are a parent or guardian and believe that a minor has registered an account on 22atm using your details or independently, please contact our support team immediately via Live Chat or the Help Center so that appropriate action can be taken without delay.
As a platform serving users across Pakistan and operating with international cloud infrastructure and service providers, 22atm may transfer Personal Data to servers or processors located outside Pakistan. Where such transfers occur, 22atm will ensure that appropriate safeguards are in place — including contractual protections such as standard data protection clauses — to provide a level of protection for your Personal Data that is consistent with the standards set out in this Policy.
By using the 22atm Platform and providing your Personal Data during registration or in the course of using our services, you acknowledge that your data may be transferred to, stored in and processed in jurisdictions outside Pakistan.
22atm reserves the right to update or amend this Privacy Policy at any time. Where a material change is made — such as a new category of data collection, a new purpose for processing, or a new category of third-party sharing — 22atm will notify registered Users by email or via an in-platform notification at least seven (7) days before the change takes effect.
Minor or administrative updates that do not materially affect the rights of Users (such as clarifications of existing clauses, correction of typographical errors or updated contact details) may be made without advance notice, though the "Effective Date" at the top of the Policy will always reflect the date of the most recent revision.
Continued use of the 22atm Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.
For any queries, concerns or formal requests relating to this Privacy Policy — including the exercise of your data rights as described in Section 11 — please contact 22atm through the following channels:
When submitting a formal data rights request, please include your full registered name, the email address associated with your account and a clear description of the right you wish to exercise. We may ask you to provide proof of identity to protect against unauthorised requests. All formal data rights requests will receive an acknowledgement within five (5) working days and a substantive response within thirty (30) calendar days of verified receipt.
If you are not satisfied with our response to a data rights request or believe we are processing your Personal Data unlawfully, you have the right to lodge a complaint with the applicable data protection supervisory authority in the operator's licence jurisdiction.
Your Data. Your Rights.
Now you understand exactly how 22atm handles your personal data, you can use the platform with confidence. Visit our homepage to explore the full game library, or read our FAQ for quick answers to common account questions.
🔞 18+ only. This Privacy Policy was last updated on 1 January 2026. For data rights queries, contact [email protected]. This document does not constitute legal advice.