1. Introduction
This Privacy Policy (hereinafter "Policy") applies to all personal data processed by dc22 (hereinafter "dc22", "we", "us", "our") in connection with your use of the website accessible at https://dc22.cam and all associated services, features and content (collectively, the "Platform").
dc22 is an online casino and sports betting platform targeting users in Pakistan and operating in English. This Policy describes what personal data we collect, the purposes for which it is processed, the legal bases that justify that processing, how long data is kept, who it may be disclosed to and the rights you hold as a data subject.
By registering for or using the dc22 Platform, you acknowledge that you have read and understood this Policy. This Policy is incorporated by reference into the Terms & Conditions. Where there is a conflict between this Policy and the Terms & Conditions on matters of data processing, this Policy shall prevail.
2. Definitions
For the purposes of this Policy, the following terms have the meanings set out below:
- "Personal Data" means any information relating to an identified or identifiable natural person ("data subject").
- "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure and erasure.
- "Data Controller" means dc22, which determines the purposes and means of processing Personal Data collected through the Platform.
- "Data Processor" means a third party that processes Personal Data on behalf of dc22 pursuant to a written data-processing agreement.
- "KYC" means Know Your Customer — identity and document verification required by the operator for regulatory compliance.
- "AML" means Anti-Money Laundering — regulatory and legal obligations to detect and prevent financial crime.
- "Cookies" means small text files placed on a user's device by a website for the purpose of storing session or preference data.
- "User", "you", "your" means any individual who accesses, registers on or uses the dc22 Platform.
3. Personal Data We Collect
3.1 Registration Data
When you create a dc22 Account, we collect the information you provide directly, which typically includes:
- Full legal name
- Date of birth (for age verification purposes)
- Email address
- Residential address (including city — for example Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
- Phone number
- Username and encrypted password
3.2 Identity Verification (KYC) Data
To comply with KYC and AML obligations, dc22 requires identity documents before withdrawals are authorised. Documents collected may include:
- Government-issued photo identification (e.g., Pakistani CNIC, passport)
- Proof of address (e.g., utility bill, bank statement)
- Proof of payment method ownership (e.g., screenshot of Easypaisa, JazzCash or bank account in your name)
3.3 Financial Transaction Data
dc22 records deposit and withdrawal transactions to maintain account integrity, detect fraud and satisfy regulatory requirements. This includes transaction amounts (in PKR), timestamps, payment method type and transaction identifiers. Full payment credentials (card numbers, mobile wallet PINs) are not stored by dc22 — these are handled by the relevant payment processor.
3.4 Behavioural and Usage Data
dc22 automatically collects certain technical data when you access the Platform:
- IP address and approximate geolocation
- Device type, operating system and browser version
- Pages visited, session duration and navigation patterns
- Game activity logs (bets placed, games accessed, outcomes — for platform integrity and responsible gambling monitoring)
3.5 Communications Data
If you contact dc22 support, we retain records of that communication — including message content, timestamps and any attachments — for quality assurance, compliance and dispute resolution purposes.
4. Legal Basis for Processing
dc22 processes Personal Data only where a lawful basis exists. The applicable bases for our processing activities are as follows:
| Processing Activity | Legal Basis |
|---|---|
| Account registration and management | Performance of a contract (the Terms & Conditions you accept) |
| Identity verification (KYC) | Legal obligation (AML/KYC regulatory requirements) |
| Payment processing and transaction records | Performance of a contract; Legal obligation |
| Fraud detection and security monitoring | Legitimate interests of dc22 in maintaining platform integrity |
| Responsible gambling monitoring | Legal obligation; Legitimate interests (player protection) |
| Customer support communications | Performance of a contract; Legitimate interests |
| Platform analytics and performance improvement | Legitimate interests of dc22 |
| Marketing communications (where opted in) | Consent (which may be withdrawn at any time) |
5. How We Use Your Personal Data
dc22 uses collected Personal Data for the following defined purposes:
- Account operations: creating and maintaining your registered Account, authenticating logins and processing transactions.
- KYC and compliance: verifying your identity and age, conducting AML screening and satisfying any applicable regulatory reporting obligations.
- Payment processing: facilitating deposits and withdrawals through payment methods available in the cashier (subject to provider availability).
- Fraud prevention and security: detecting and preventing unauthorised account access, bonus abuse, money laundering and other prohibited conduct.
- Responsible gambling: monitoring gambling patterns to identify signs of problem gambling behaviour and applying requested limits (deposit limits, self-exclusion etc.).
- Customer support: responding to queries, processing complaints and resolving disputes.
- Platform improvement: analysing usage data to improve site performance, navigation and game selection.
- Marketing (consent-based): sending promotional communications about dc22 offers, cricket season promotions, PSL-related betting features and other relevant content — only where you have provided explicit consent and only to the extent permitted by applicable law.
6. Data Sharing and Third-Party Disclosure
6.1 Service Providers
dc22 may share Personal Data with third-party service providers acting as Data Processors under contractual obligation. Categories of service provider include:
- Payment processors (processing deposits and withdrawals — including references to Easypaisa, JazzCash, Raast and banking channels where supported)
- KYC and identity verification technology providers
- Cloud hosting and infrastructure providers
- Fraud detection and cybersecurity services
- Customer support software providers
- Platform analytics providers
All service providers are required to process Personal Data only as instructed by dc22 and may not use it for their own purposes.
6.2 Legal and Regulatory Disclosure
dc22 may disclose Personal Data to competent authorities, regulators or courts where required by applicable law, valid legal process or court order. Such disclosures are made to the minimum extent required.
6.3 Business Transfers
In the event of a merger, acquisition, restructuring or sale of assets involving dc22, Personal Data held by dc22 may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.
6.4 No Data Sales
dc22 does not sell, rent, trade or otherwise transfer Personal Data to third parties for their own independent commercial or marketing purposes.
7. Cookies and Similar Technologies
dc22 uses cookies and similar tracking technologies (collectively "Cookies") to operate the Platform, maintain session security, understand usage patterns and support fraud prevention.
| Cookie Category | Purpose | Basis |
|---|---|---|
| Strictly Necessary | Session management, authentication, security, CSRF protection. Required for the Platform to function. | Necessary for contract performance; not subject to consent withdrawal |
| Functional | Remembering user preferences (language, display settings), improving navigation. | Legitimate interests |
| Analytical / Performance | Aggregated usage statistics, page load analysis, navigation flow assessment. | Legitimate interests; consent where required |
| Fraud & Security | Device fingerprinting, bot detection, AML risk signals. | Legal obligation; Legitimate interests |
You may manage Cookie preferences through your browser settings. Please note that disabling strictly necessary Cookies will impair or prevent your ability to log in and use the Platform.
8. Data Retention
dc22 retains Personal Data only for as long as necessary to fulfil the purposes described in this Policy or to comply with applicable legal obligations. Indicative retention periods are set out below:
| Data Category | Indicative Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of active account plus 5 years post-closure | Legal and regulatory obligation |
| KYC / identity documents | Up to 5 years post-account closure (or longer if required by applicable law) | AML/KYC legal obligation |
| Financial transaction records | Up to 5 years post-transaction | Legal and regulatory obligation |
| Customer support communications | Up to 3 years post-resolution | Legitimate interests (dispute resolution) |
| Analytical / usage data | Up to 24 months (aggregated or anonymised thereafter) | Legitimate interests |
| Marketing preferences | Until consent is withdrawn, plus reasonable administrative period | Consent |
Following the expiry of relevant retention periods, Personal Data is securely deleted or anonymised so that it can no longer identify you.
9. Your Data Subject Rights
Subject to applicable law and the conditions of specific rights under the operator's license jurisdiction, you may exercise the following rights in respect of your Personal Data: