Privacy Policy

This Privacy Policy ("Policy") sets out the practices of 522win ("Company", "we", "us", "our") in relation to the collection, storage, use, sharing and protection of personal data belonging to users ("you", "your") of the 522win platform accessible at https://522win.cam ("Platform").

522win is an English-language online betting and casino information platform designed for users in Pakistan. We understand that privacy is a fundamental concern — particularly for users in Pakistan where digital financial transactions via services like Easypaisa, JazzCash and Raast are part of everyday life. We are committed to handling your personal data with the highest standards of care, discretion and security.

This Policy applies to all personal data collected through the Platform, including data submitted during account registration, KYC (Know Your Customer) verification, deposits, withdrawals, customer support interactions, and passive data collected through your use of the Platform such as browsing behaviour and device information.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, which are incorporated by reference. In the event of any conflict between this Policy and the Terms & Conditions specifically regarding data matters, this Policy shall prevail.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" — any information that identifies or can reasonably be used to identify a living individual, either alone or in combination with other data. This includes name, CNIC number, date of birth, email address, device identifiers, IP address and financial account details.
• "Processing" — any operation or set of operations performed on personal data, including collection, storage, retrieval, use, disclosure, alteration, combination or erasure.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, 522win is the Data Controller in respect of data collected through the Platform.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller under documented instructions, such as payment processors, identity verification providers and cloud hosting services.
• "KYC Data" — identity and address verification documentation submitted by Users including, but not limited to, CNIC, passport, driving licence, proof of address and payment method confirmation documents.
• "Cookies" — small data files placed on your device by the Platform to support functionality, session management, analytics and personalisation.
• "Sensitive Personal Data" — a subset of personal data that carries higher inherent risk and is afforded additional protections, including government-issued identification numbers, financial data and data revealing health information relevant to responsible gambling determinations.

522win collects personal data through several distinct channels. The following table summarises the categories of data we collect, the source of that data, and the primary purpose for which it is collected:

522win processes your personal data on one or more of the following legal bases, depending on the specific processing activity involved:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions, including account management, bet settlement, payment processing and KYC verification.
• Legitimate Interests: Processing that serves the Company's legitimate business interests, including fraud detection, security monitoring, platform analytics and improvement of services, provided such interests are not overridden by your fundamental rights and freedoms.
• Legal Obligation: Processing required to comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and licence-jurisdiction legal obligations, including mandatory record-keeping and reporting requirements.
• Consent: Where we rely on your consent as the legal basis — such as for certain marketing communications or non-essential cookies — you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Vital Interests: In exceptional circumstances where processing is necessary to protect the vital interests of a person, such as a safeguarding concern arising from responsible gambling interactions.

Your personal data is used by 522win solely for the purposes set out below. We do not sell your personal data to third parties for their own marketing purposes.

• Account Management: To create, maintain and administer your 522win account, including authentication, account settings management and communication regarding account status.
• Transaction Processing: To process PKR deposits and withdrawals, resolve payment queries, and maintain accurate financial records of your account activity.
• Identity Verification (KYC): To verify your identity in accordance with our KYC obligations, including confirming your age (18+), confirming you are not subject to sanctions, and ensuring the integrity of payment methods used.
• Fraud Prevention & Security: To detect, investigate and prevent fraudulent activity, money laundering, account takeover attempts, bonus abuse and other prohibited conduct as defined in our Terms & Conditions.
• Responsible Gambling: To administer your self-imposed responsible gambling restrictions, monitor activity patterns that may indicate problem gambling behaviours, and fulfill obligations to apply self-exclusion measures.
• Customer Support: To respond to your queries, resolve disputes, manage complaints and provide technical assistance via Live Chat, email and Help Centre channels.
• Platform Improvement: To analyse usage patterns, diagnose technical issues and improve the performance, features and user experience of the Platform for all Pakistani users.
• Legal Compliance: To comply with applicable legal obligations including AML/CTF record-keeping requirements, responses to lawful regulatory or judicial requests, and enforcement of our Terms & Conditions.
• Marketing Communications: Where you have opted in to marketing communications, to send you information about promotions, bonuses, new features and relevant sporting events (including Pakistan cricket, PSL, ICC tournaments). You may opt out at any time.

522win does not sell, rent or trade your personal data. We share data only in the circumstances described below and only to the extent strictly necessary for the stated purpose:

• Payment Processors: Your transaction data is shared with the payment service providers used to process your deposits and withdrawals. These processors act as Data Processors under contractual data-processing agreements and are prohibited from using your data for their own independent purposes.
• KYC / Identity Verification Providers: CNIC scans, passport images and other identity documents may be shared with third-party identity verification services operating under binding data-processing agreements with appropriate security standards.
• Regulatory & Law Enforcement Authorities: Where required by law, court order or a valid request from a competent regulatory or law enforcement authority, we will disclose personal data as legally obligated. We will notify you of such requests where legally permitted to do so.
• Fraud Prevention Networks: Information about accounts involved in suspected fraud, money laundering or bonus abuse may be shared with industry fraud prevention databases to which the Company subscribes, where lawful to do so.
• Technology & Hosting Providers: Cloud hosting, database and infrastructure providers process data on our behalf under strict data-processing agreements. They do not have independent access to your personal data beyond what is required to provide their technical services.
• Business Transfers: In the event of a merger, acquisition, asset sale or business restructuring, your personal data may be transferred to the acquiring entity, subject to the same privacy protections set out in this Policy.

522win uses cookies and similar tracking technologies to operate the Platform and improve your user experience. The following categories of cookies may be active on the Platform:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens and user preference storage. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Enable enhanced functionality and personalisation such as remembering your language preference, display settings and last-visited sections of the Platform.
• Analytics Cookies: Collect aggregated, anonymised data about how users interact with the Platform — page views, session duration, navigation paths — to help us improve performance and content. These are only set with your consent where required.
• Security & Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, including identifying unusual login patterns and flagging suspicious account behaviour.

You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality and performance of the Platform. Note that strictly necessary cookies cannot be disabled via cookie preferences as they are integral to Platform operation.

522win retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, and in compliance with applicable legal retention obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is either securely deleted or anonymised so that it can no longer be attributed to an identifiable individual. Where data is retained in anonymised aggregate form for statistical or analytics purposes, it is no longer considered personal data under this Policy.

522win implements a range of technical and organisational security measures designed to protect your personal data from unauthorised access, disclosure, alteration, loss or destruction. Our security programme includes:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the 522win Platform is encrypted in transit using industry-standard TLS encryption protocols.
• Password Hashing: User passwords are stored using one-way cryptographic hashing algorithms. Plain-text passwords are never stored or transmitted by the Platform.
• Two-Factor Authentication (2FA): Users are encouraged to enable 2FA on their accounts for an additional layer of access security.
• Access Controls: Strict role-based access controls limit internal access to personal data to authorised personnel with a demonstrable business need.
• Penetration Testing & Security Audits: The Platform undergoes regular security assessments to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: The Company maintains a documented data breach response procedure. In the event of a security incident that poses a risk to your personal data, affected users will be notified in accordance with applicable legal obligations.

Subject to applicable law and certain exceptions that may apply, you have the following rights in relation to the personal data that 522win holds about you. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request".

We will respond to valid rights requests within 30 calendar days. Where the request is complex or involves large volumes of data, we may extend this period by a further 30 days with prior notification. We will not charge a fee for responding to rights requests unless they are manifestly unfounded, excessive or repetitive.

522win is strictly an adults-only platform. We do not knowingly collect, store or process personal data belonging to individuals under the age of 18, or the higher minimum age required by the applicable operator or licence jurisdiction, whichever is greater.

Age verification is a mandatory component of our KYC process. All users are required to demonstrate they meet the minimum age requirement before their account is fully activated and before any withdrawals are processed. CNIC verification is the primary age-confirmation mechanism for Pakistani users.

If we become aware that personal data has been collected from a minor — whether through registration fraud, shared device use or any other means — we will immediately suspend the account, delete all associated personal data to the extent not required for regulatory purposes, and return any deposited funds to the source payment method.

As an online platform serving Pakistani users through internationally hosted infrastructure, your personal data may be transferred to, stored in, and processed in countries other than Pakistan. These countries may have data protection laws that differ from those applicable in Pakistan.

Where personal data is transferred outside the jurisdiction in which it was collected, we ensure that appropriate safeguards are in place, including but not limited to: contractual clauses requiring the recipient to protect your data to at least the standard described in this Policy; use of service providers operating under recognised data protection frameworks; or other lawful transfer mechanisms.

By using the 522win Platform and providing your personal data, you acknowledge and consent to the transfer of your data to international locations as described in this section, subject to the safeguards described above.

The 522win Platform may contain references to or integration with third-party services such as payment providers, game studios and analytics tools. This Privacy Policy applies solely to data processed by 522win as Data Controller.

522win is not responsible for the privacy practices, data collection activities or security standards of any third-party services, even where those services are integrated into or referenced by the Platform. We encourage you to review the privacy policies of any third-party services you use in connection with your 522win account, including your payment provider (whether Easypaisa, JazzCash, HBL, UBL, Meezan Bank, Bank Alfalah or otherwise).

522win reserves the right to update or amend this Privacy Policy at any time in response to legal, regulatory, technical or business developments. The revised Policy will be published on this page with an updated "Last updated" date.

Where amendments are material — meaning they significantly affect your rights or the way your data is processed — we will provide advance notice via in-platform notification or email to your registered address, with a minimum of 14 days' notice where practicable.

Your continued use of the Platform following publication of an amended Policy constitutes your acceptance of the revised terms. If you do not agree to the amended Policy, you must discontinue use and request account closure before the effective date.

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the 522win Data Protection team using the details below. All contact information is provided as plain text — do not use any method not listed here.

If you are dissatisfied with our response to a privacy complaint, you have the right to escalate your complaint to the competent supervisory authority in the Company's jurisdiction of incorporation. We will assist you in identifying the appropriate authority upon request.