we222 Privacy Policy —
How We Protect Your Personal Data

This Privacy Policy is issued by we222 (referred to in this document as "we222", "we", "us", or "our") and governs the collection, use, storage, and disclosure of personal data relating to all users of the we222 online casino and sports betting platform available at we222.app ("the Platform").

We222 is committed to protecting your privacy in accordance with internationally recognised data protection principles and the obligations imposed under our gaming licence terms. This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy, both of which form part of the overall agreement between you and we222.

By registering an account on we222 or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with any part of this Privacy Policy, you should discontinue use of the Platform and contact our support team to close your account.

we222 collects personal data from you directly when you register an account, make a deposit, contact support, or use our services, and automatically through your interaction with the Platform. The categories of personal data we collect are as follows:

2.1 Registration & Identity Data

• Full legal name as it appears on your CNIC
• Date of birth (for mandatory 21+ age verification)
• Pakistani National Identity Card (CNIC) number and copy
• Residential address (city, province, Pakistan)
• Email address
• Mobile phone number
• Username and encrypted password

2.2 Financial & Payment Data

• JazzCash or EasyPaisa mobile account number
• HBL, UBL, or Meezan Bank account details (account title and number) for bank transfer processing
• Deposit and withdrawal transaction history denominated in PKR
• Source of funds documentation where requested under our AML obligations

2.3 Usage & Technical Data

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Session timestamps and duration
• Game play history, betting records, and wagering patterns
• Pages and features accessed within the Platform
• Login and logout timestamps

2.4 Responsible Gaming Data

• Deposit limits, loss limits, and session time limits you have set
• Cooling-off period and self-exclusion status and dates
• Responsible gaming self-assessment responses (where voluntarily submitted)

2.5 Communications Data

• Support ticket content and live chat transcripts
• Email correspondence with the we222 team
• Feedback or complaint submissions

we222 uses the personal data it collects for the following specific purposes:

we222 does not use your personal data for automated individual decision-making that produces legal or similarly significant effects, except where required for fraud prevention or AML screening. In such cases, you have the right to request human review of any automated decision that affects your account.

we222 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is necessary for the performance of our contract with you — including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable legal obligations under our gaming licence, including KYC identity verification, age verification, AML screening, and responsible gaming record-keeping.
• Legitimate Interests: Processing that is necessary for we222's legitimate business interests, such as fraud detection, platform security, and analytics, where those interests are not overridden by your privacy rights.
• Consent: Where we rely on your consent for processing — for example, for optional marketing communications — you may withdraw that consent at any time by contacting support or updating your account preferences. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

we222 does not sell, rent, or trade your personal data to any third party. We may share your personal data with the following categories of recipients only where strictly necessary:

• Game Providers: Licensed third-party game providers who supply casino games and sports betting markets on the Platform. These providers receive only the minimum data necessary to deliver the game service (e.g., player session tokens). They are contractually prohibited from using player data for their own purposes.
• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, for the sole purpose of processing your deposit and withdrawal transactions in PKR. Payment data is shared only to the extent required to complete the transaction.
• KYC & Identity Verification Services: Third-party identity verification providers used to process CNIC verification as part of our KYC obligations. These providers operate under strict data processing agreements and are not permitted to retain or repurpose your identity data.
• Regulatory Authorities: Where we are legally required to disclose information to a gaming regulatory authority, law enforcement agency, or court of competent jurisdiction in connection with our gaming licence obligations, AML investigations, or legal proceedings.
• IT & Security Service Providers: Cloud hosting providers, cybersecurity vendors, and platform infrastructure partners who process data on our behalf under binding data processing agreements that require them to maintain appropriate technical and organisational security measures.

All financial transactions on we222 are processed exclusively in Pakistani Rupees (PKR) through regulated Pakistani payment channels. we222 does not store full payment credentials such as complete bank account numbers or JazzCash/EasyPaisa PINs on its own servers. Payment data is transmitted directly to the relevant payment processor using encrypted channels.

we222 retains transaction records — including deposit amounts, withdrawal amounts, timestamps, and payment method references — for a minimum period required by our gaming licence and AML obligations. These records may be disclosed to regulatory authorities upon lawful request.

we222 uses cookies and similar tracking technologies to operate the Platform, maintain your session, and understand how the Platform is being used. The following categories of cookies are used:

we222 does not use advertising cookies, behavioural tracking cookies, or third-party remarketing pixels. You can manage cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent the Platform from functioning correctly.

we222 retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable legal, regulatory, and licence obligations. The following general retention periods apply:

• Account & Identity Data: Retained for the duration of your active account relationship with we222, plus a minimum of five (5) years following account closure, in accordance with our gaming licence AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction for AML compliance and financial record-keeping purposes.
• Responsible Gaming Data: Self-exclusion and cooling-off records are retained indefinitely to prevent circumvention of player protection measures. Other responsible gaming data is retained for five (5) years post-account closure.
• Support Communications: Retained for three (3) years from the date of the last communication, or longer if the communication relates to an unresolved complaint or legal matter.
• Analytical & Usage Data: Anonymised aggregated data may be retained indefinitely. Non-anonymised usage logs are deleted or anonymised within twelve (12) months.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised in accordance with we222's data disposal procedures.

we222 implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Key security measures include:

• TLS encryption for all data in transit between your device and we222 servers
• AES-256 encryption for sensitive data at rest, including identity documents and payment references
• Strict role-based access controls ensuring that staff can only access personal data relevant to their specific job function
• Multi-factor authentication requirements for all we222 staff accessing systems that store player personal data
• Regular third-party penetration testing and security audits of the Platform and its infrastructure
• Automated intrusion detection and anomaly monitoring systems
• Documented incident response procedures with defined notification timelines in the event of a data breach

You also play an important role in protecting your own data. Please use a strong, unique password for your we222 account, enable any available two-factor authentication, and never share your login credentials with any other person. If you suspect your account has been compromised, contact we222 support immediately.

As a we222 player, you have the following rights in relation to your personal data. To exercise any of these rights, please contact the we222 support team using the details in Section 14. we222 will respond to all valid data rights requests within thirty (30) calendar days.

• Right of Access: You have the right to request a copy of all personal data we222 holds about you, together with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may also update certain account details directly through your account settings.
• Right to Erasure: 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. Please note that we222 may be required to retain certain data for legal and regulatory compliance purposes even after an erasure request.
• Right to Restrict Processing: You may request that we222 temporarily suspend processing of your personal data in certain circumstances, for example while the accuracy of data is being contested.
• Right to Data Portability: You have the right to receive a copy of personal data you have provided to we222 in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing of your personal data where we rely on legitimate interests as the legal basis, and where your individual circumstances justify such objection.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

The we222 platform is strictly restricted to individuals aged 21 and above. we222 does not knowingly collect, store, or process personal data relating to individuals under the age of 21. CNIC-based age verification is a mandatory step in our account registration and KYC process specifically to prevent underage access.

If we222 determines or is notified that personal data has been collected from a person under the age of 21, the relevant account will be immediately closed, any deposited funds returned via the original payment method, and all associated personal data securely deleted from our systems, subject only to any mandatory record-keeping obligations under our AML and gaming licence requirements.

If you are a parent or guardian and believe that a person under 21 in your care has registered a we222 account, please contact us immediately at the details provided in Section 14. we222 will investigate and act on such reports without delay.

As we222 operates under an international gaming licence, some of the third-party service providers we work with — including cloud infrastructure and game providers — may process personal data in jurisdictions outside Pakistan. Where such international transfers occur, we222 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that described in this Privacy Policy.

Safeguards used for international transfers include:

• Binding contractual data processing agreements with all third-party recipients that impose data protection obligations consistent with internationally recognised standards
• Restricting international transfers to service providers located in jurisdictions that maintain adequate data protection frameworks
• Ongoing review and audit of third-party data processors to verify continued compliance with agreed data protection standards

we222 does not transfer personal data — including CNIC documents or Pakistani payment account details — to any overseas third party for commercial or marketing purposes. All international data flows are strictly limited to operational necessity.

we222 may update this Privacy Policy from time to time to reflect changes in our data practices, service offerings, or applicable legal and regulatory requirements. The date of the most recent update is displayed at the top of this page.

Where changes are material — for example, where we introduce a new category of data collection or a new purpose for processing — we222 will notify registered players via email prior to the changes taking effect. For non-material changes, the updated Privacy Policy will be published on this page and your continued use of the Platform after the update date will constitute acknowledgement of the revised policy.

we222 recommends that you review this Privacy Policy periodically to stay informed about how we are protecting your personal data. If you have any concerns about a change to this Privacy Policy, please contact us before continuing to use the Platform.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we222 handles your personal data, please contact our dedicated support team. Our team is available 24 hours a day, 7 days a week.

Email: [email protected]

Live Chat: Available directly within your we222 account dashboard following login. Live chat is recommended for time-sensitive privacy matters including suspected unauthorised account access or urgent data rights requests.

When submitting a privacy-related request, please include your registered account username and CNIC reference so that we can verify your identity and process your request without unnecessary delay. we222 aims to acknowledge all privacy-related contact within 48 hours and to provide a substantive response within 30 calendar days.