td222 Privacy Policy

This Policy applies to all personal data collected and processed in connection with your use of the td222 Platform, including but not limited to the td222 website at td222.ws, any associated mobile-optimised interfaces, customer support channels, email communications, and promotional materials.

td222 is the data controller for the personal data collected via the Platform. As data controller, td222 determines the purposes for which your personal data is processed and the means by which it is processed. Where td222 engages third-party service providers to process data on its behalf, those providers act as data processors under contractual obligations that require them to maintain confidentiality and implement appropriate security measures.

For all data protection enquiries, including subject access requests, correction requests, and deletion requests, you may contact the td222 data protection team at [email protected].

td222 collects the following categories of personal data:

td222 does not collect or process special categories of sensitive personal data (such as health data, biometric data, or political opinions) except where such data is voluntarily disclosed by a user in the context of a responsible gaming self-exclusion request or support interaction, in which case it is handled with heightened confidentiality.

td222 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions
• Automated technologies: Technical and usage data collected automatically when you access the td222 Platform, including via cookies, log files, and similar tracking technologies as described in Section 7
• Third-party verification providers: Identity and document verification services used to assist with KYC and anti-money laundering checks may return supplementary data about your identity documents
• Payment processors: Payment service providers including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank may share transaction confirmation data with td222 for the purpose of deposit and withdrawal processing
• Fraud prevention services: td222 may receive data from third-party fraud detection services to help identify suspicious account activity or financial crime

td222 processes your personal data only where a valid legal basis exists. The legal bases applicable to td222's data processing activities are as follows:

• Contractual necessity: Processing required to perform the contract between you and td222 — including account creation, payment processing, game facilitation, and customer support
• Legal obligation: Processing required for td222 to comply with applicable anti-money laundering, age verification, and regulatory reporting obligations
• Legitimate interests: Processing for the purposes of fraud prevention, platform security, responsible gaming monitoring, and improving the td222 Platform, where such interests are not overridden by your data protection rights
• Consent: Processing for marketing communications and non-essential cookies, where you have given express consent. You may withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal

td222 uses the personal data it collects for the following purposes:

• Creating, managing, and maintaining your td222 account
• Verifying your identity and age to ensure compliance with the 21+ minimum age requirement
• Processing deposits and withdrawals in PKR via supported payment methods including JazzCash, EasyPaisa, and local bank transfers
• Conducting KYC and anti-money laundering checks as required under applicable standards
• Delivering and improving the td222 Platform's games, sports betting services, and customer support functions
• Sending transactional communications including account notifications, deposit confirmations, withdrawal updates, and security alerts
• Sending promotional communications where you have consented to receive them — you may opt out at any time
• Monitoring gaming activity to enforce responsible gaming policies, including the detection of problem gambling indicators and the administration of self-exclusion and deposit limit tools
• Detecting, investigating, and preventing fraud, abuse, and prohibited conduct in accordance with the td222 Terms & Conditions
• Complying with legal and regulatory reporting obligations
• Resolving disputes, enforcing our agreements, and administering our Platform

td222 does not sell your personal data to any third party. td222 may share your personal data with the following categories of recipients, strictly for the purposes described:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment processors require transaction-level data to process deposits and withdrawals
• Identity verification providers: Third-party KYC and document verification services that assist td222 in verifying user identity and age
• Fraud prevention and security services: Services that help td222 detect and prevent fraudulent activity, money laundering, and account abuse
• IT and infrastructure providers: Cloud hosting, data storage, and platform infrastructure providers who process data on td222's behalf under strict data processing agreements
• Legal and regulatory authorities: Where required by applicable law, court order, or regulatory obligation, td222 may disclose personal data to competent authorities. td222 will notify affected users where legally permitted to do so
• Professional advisers: Legal, accounting, and auditing professionals bound by confidentiality obligations

All third-party recipients who process personal data on td222's behalf are required to maintain appropriate technical and organisational security measures and to process data only in accordance with td222's instructions.

td222 uses cookies and similar tracking technologies on its Platform. Cookies are small text files stored on your device that help td222 deliver a functional, personalised, and secure user experience. The categories of cookies used by td222 are as follows:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication cookies that keep you logged in to your td222 account. These cookies cannot be disabled without breaking core Platform functionality.
• Functional cookies: Store your preferences such as language selection and display settings to personalise your experience across sessions.
• Analytical cookies: Collect anonymised or aggregated usage data to help td222 understand how users interact with the Platform, identify usability issues, and prioritise improvements.
• Security cookies: Support fraud detection and account security functions, including CSRF protection and session integrity monitoring.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect the functionality of the td222 Platform. td222 does not use cookies to serve third-party advertising or to track your activity across external websites.

td222 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and td222 servers
• Encryption at rest for sensitive personal data fields including identity document data and financial account references
• Role-based access controls ensuring that only authorised td222 personnel can access personal data, and only to the extent necessary for their role
• Regular internal and external security assessments, penetration testing, and vulnerability scanning
• Incident response procedures that include notification obligations in the event of a data breach affecting your personal data
• Staff training on data protection obligations and security awareness

While td222 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your td222 account credentials. If you suspect that your account has been compromised, contact td222 support immediately at [email protected].

td222 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal and regulatory retention requirements. The following retention periods generally apply:

• Account data and transaction records: Retained for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements
• KYC documentation: Retained for a minimum of five (5) years from the date of the most recent transaction or account closure, whichever is later
• Customer support records: Retained for three (3) years from the date of the interaction, or longer where the matter relates to an ongoing dispute or legal claim
• Marketing consent records: Retained for as long as you remain subscribed and for a reasonable period thereafter to evidence the basis for communications sent
• Responsible gaming records: Self-exclusion records are retained indefinitely to prevent re-registration during or after an exclusion period
• Technical and usage logs: Retained for up to twelve (12) months for security and analytical purposes, after which they are anonymised or deleted

Following the expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised so that it can no longer be attributed to an identified or identifiable individual.

As a td222 user, you have the following rights in relation to your personal data. To exercise any of these rights, submit a written request to [email protected]. td222 will respond within thirty (30) days of receiving a verifiable request.

• Right of access: You may request a copy of the personal data that td222 holds about you, along with information about how it is used and with whom it is shared
• Right of rectification: You may request correction of any personal data that is inaccurate or incomplete
• 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, subject to overriding legal retention obligations
• Right to restriction of processing: You may request that td222 restrict the processing of your personal data in certain circumstances, for example while the accuracy of data is being contested
• Right to data portability: Where processing is based on your consent or contractual necessity and carried out by automated means, you may request a structured, machine-readable copy of the personal data you provided to td222
• Right to object: You may object to processing based on td222's legitimate interests or for direct marketing purposes at any time
• 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

td222 will not discriminate against you for exercising any of these rights. Identity verification may be required before a request is actioned in order to protect against fraudulent access to another person's data.

The td222 Platform is strictly for adults aged 21 years and over. td222 does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted at registration and may be repeated at td222's discretion during the account lifecycle.

If td222 discovers or is notified that a user account belongs to an individual under 21 years of age, that account will be immediately closed, all associated data will be handled in accordance with applicable legal requirements, and any funds in the account will be dealt with in accordance with the td222 Terms & Conditions.

If you believe that a minor has accessed the td222 Platform or provided personal data to td222, please contact [email protected] immediately so that appropriate action can be taken without delay.

td222 may transfer personal data to service providers and partners located outside Pakistan. Where such transfers occur, td222 takes appropriate steps to ensure that your data receives a level of protection consistent with internationally recognised data protection standards, including:

• Executing data processing agreements with all third-party processors that incorporate appropriate data protection obligations
• Ensuring that transfers to jurisdictions without equivalent data protection laws are governed by contractual safeguards that impose obligations on the recipient equivalent to those that apply to td222
• Applying encryption and access controls to data in transit and at rest regardless of the jurisdiction in which processing occurs

By using the td222 Platform, you acknowledge and consent to the transfer of your personal data to other jurisdictions as described in this Policy, where necessary for the provision of td222 services.

td222 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, the services we offer, or applicable legal requirements. When material changes are made, td222 will publish an updated version of this Policy on the td222 Platform with a revised effective date, and will endeavour to notify registered users by email where practicable.

Your continued use of the td222 Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically. If you disagree with any changes, you should cease using the Platform and may request account closure by contacting td222 support.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a complaint about how td222 has handled your personal data, please contact the td222 data protection team using the details below:

• Email: [email protected]
• Live Chat: Available 24/7 via the td222 Platform
• Languages: English and Urdu
• Response Time: td222 will acknowledge your request within 5 business days and provide a substantive response within 30 days

If you are not satisfied with td222's response to your privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction. td222 will cooperate fully with any such authority in the investigation of a complaint.

For matters related to responsible gaming data or self-exclusion, please also refer to the td222 Responsible Gaming Policy, which contains additional information about how gaming activity data is used to support player protection.