21com Privacy Policy — How We Keep Your Data Safe

1. Who We Are

21com is an online gaming platform accessible at 21com.win, providing slots, bingo, live casino games, and cricket-season entertainment to adult players in Pakistan. When this Privacy Policy refers to "21com", "we", "us", or "our", it means the platform and its operating team responsible for processing your personal data.

This Privacy Policy applies to all individuals who visit, register on, or interact with the 21com platform — whether through a desktop browser, mobile browser, or any other access method. By using 21com, you agree to the data practices described in this document. This policy is intended to be read alongside our Terms and Conditions, which govern the overall player agreement.

2. Data We Collect

The personal information we collect falls into the following categories, each tied to a specific operational purpose:

We do not collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information as part of our standard account operations.

3. How We Collect Your Data

Your information reaches us through several channels during your time with 21com:

• Direct registration: When you create your account, you voluntarily provide your name, mobile number, email address, and date of birth. This is the primary source of your identity and contact data.
• Identity verification: When you submit a CNIC, passport scan, or other KYC document to complete verification before your first withdrawal, we collect and store the relevant identity fields.
• Payment transactions: Each time you initiate a PKR deposit or withdrawal via JazzCash, Easypaisa, Raast, bank transfer, or card, our payment processing systems record the transaction details necessary to complete and reconcile the payment.
• Platform activity: As you navigate the platform, play games, claim bonuses, and interact with features, our systems automatically log usage and gaming data tied to your account session.
• Cookies and device signals: Our platform uses cookies and similar tracking technologies to recognise your device, maintain your session, and gather aggregated usage statistics. See Section 7 for full details.
• Support interactions: If you contact our support team via live chat or email, we retain a record of those conversations to maintain service quality and resolve any future related queries.

4. How We Use Your Data

Every use of your personal data at 21com is tied to a legitimate operational purpose. We do not process data speculatively or without a clear reason. The main purposes are:

4.1 Account Operations

Your identity and contact data are used to create and maintain your player account, send you login verification codes, notify you about important account events such as successful withdrawals or security alerts, and allow you to recover access if you are locked out.

4.2 Payment Processing

Financial data is processed solely to execute your PKR deposit and withdrawal requests through your chosen payment channel — JazzCash, Easypaisa, Raast, bank transfer, or card. Transaction records are retained for financial reconciliation and dispute resolution.

4.3 Identity Verification & Fraud Prevention

We use identity documents and technical data such as IP address and device fingerprint to verify that you are who you say you are, that you are 18 or older, and that your account is not being accessed from a flagged or suspicious source. This protects both you and the integrity of the platform.

4.4 Responsible Gaming

Your gaming activity data — session duration, wager frequency, deposit patterns — is monitored by our responsible gaming systems. If unusual patterns emerge that may indicate problematic play, our team may reach out proactively. You can also use this data yourself via the account dashboard to review your own activity.

4.5 Platform Improvement

Aggregated and anonymised usage data helps us understand how players navigate 21com, which game categories are popular during cricket season and PSL, where players encounter friction, and how to improve the overall experience. This analysis does not involve identifying individual users.

4.6 Promotions & Bonuses

When you opt in to receive promotional communications, we use your email address and gaming preferences to send relevant bonus offers, reload promotions, and cricket-season event notifications. You can unsubscribe from marketing messages at any time without affecting your account status.

5. Payment Data & PKR Transactions

Payment data deserves special attention because it directly relates to your finances. Here is exactly how 21com handles PKR transaction information:

• Your JazzCash wallet number, Easypaisa account, IBAN, or card details are used exclusively to process your requested transactions. They are not stored in our main application database in raw form — payment channel credentials are handled through secure payment gateway integrations.
• Transaction IDs, amounts in PKR, timestamps, and payment channel identifiers are retained in your account ledger for the purposes of dispute resolution, withdrawal verification, and financial audit trails.
• We require that the name on your payment account matches your verified 21com account name. This is an anti-money laundering control, not an unnecessary data collection measure.
• 21com does not share your financial data with any party beyond the payment processor required to complete your specific transaction. Your bank or mobile money provider will have their own privacy policies governing their side of the transaction.

6. Data Sharing

21com does not sell your personal data. We share it only in the following limited and necessary circumstances:

6.1 Payment Processors

To execute PKR transactions, we pass the minimum necessary financial data to the relevant payment gateway — for example, to complete a JazzCash disbursement or verify an Easypaisa deposit. These processors operate under strict data handling agreements and use your data only to complete the transaction.

6.2 Identity Verification Providers

KYC document verification may involve a third-party identity verification service that cross-checks your submitted CNIC or passport details against authoritative records. This service processes your documents under confidentiality terms and does not retain your data beyond the verification cycle.

6.3 Game Providers

Some games on 21com are delivered by third-party studios. These providers may receive anonymised session identifiers to facilitate game loading, RNG certification, and jackpot tracking. They do not receive your name, contact details, or payment information.

6.4 Legal & Compliance Requirements

If 21com receives a valid legal demand — such as a court order or regulatory disclosure requirement — we may be required to share specific account data with the requesting authority. We will notify you of any such disclosure where legally permitted to do so.

6.5 Business Transfers

In the event of a merger, acquisition, or asset sale involving 21com, player account data may be transferred to the acquiring entity. You will be notified of any material change in data controller before it takes effect, and your rights under this policy will be preserved.

7. Cookies & Tracking Technologies

21com uses cookies and similar technologies to make the platform work properly and to improve your experience. Here is what each type does:

• Essential cookies: Required for the platform to function. These keep you logged in during your session, maintain your game state, and enable secure payment flows. They cannot be disabled without breaking core platform features.
• Functional cookies: Remember your language preference, currency display (PKR), and game lobby filters so you do not have to reset them on every visit.
• Analytics cookies: Collect anonymised data about how players navigate the platform — which sections are visited most, where sessions drop off, and how new features are received. This data is aggregated and does not identify you personally.
• Security cookies: Support fraud detection by helping our systems recognise your usual device and flag logins from unfamiliar locations or browser configurations.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will affect platform functionality. Third-party analytics tools used on 21com process data under their own privacy terms and handle only anonymised, aggregated metrics.

8. Data Security

Protecting your personal data is a technical and operational priority at 21com. The security measures we have in place include:

• TLS encryption on all data in transit between your browser or app and our servers.
• Encrypted storage for sensitive fields including password hashes, identity document metadata, and payment reference data.
• Access controls that limit which team members can view personal data, based on job function and operational need.
• Regular security reviews of our platform infrastructure and third-party integrations.
• Automatic session timeouts after periods of inactivity to protect accounts on shared devices.
• Two-step verification options available to players who want an additional layer of login security.

9. Data Retention

We keep your personal data only for as long as it is needed to fulfil the purpose for which it was collected, or as required by applicable legal and financial record-keeping obligations. In practice:

• Active account data is retained for the duration of your account's active status plus a period following closure to cover any pending disputes or regulatory requirements.
• Transaction records including PKR deposits and withdrawals are retained for a minimum period consistent with standard financial audit requirements.
• KYC documents submitted for identity verification are retained for the legally required period and then securely deleted.
• Support chat logs and email correspondence are retained for a defined period to enable follow-up on unresolved issues, after which they are purged.
• If you request account deletion, we will remove or anonymise your personal data within a reasonable period, subject to any legal obligations that require us to retain certain records.

10. Your Rights

As a player using 21com, you have the following rights over your personal data. To exercise any of these, contact our support team with your account-registered email address and the specific request:

• Right of access: You can request a copy of the personal data we hold about you.
• Right to rectification: If any of your personal data is inaccurate or incomplete, you can ask us to correct it. For contact details, you can update these directly in your account profile.
• Right to erasure: You can request deletion of your account and associated personal data. Note that certain financial and identity records may need to be retained for a defined period even after account closure.
• Right to restrict processing: In certain circumstances, you can ask us to limit how we use your data while a dispute or query is being resolved.
• Right to data portability: You can request your account data in a structured, machine-readable format where technically feasible.
• Right to object: You can opt out of receiving marketing communications at any time. Withdrawal of marketing consent does not affect your account status or access to the platform.

11. Minors & Age Protection

21com is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 18. Age verification is a required step in our account registration and withdrawal process specifically to enforce this restriction.

If we discover or are notified that a minor has managed to register an account, we will immediately suspend that account, delete the associated personal data as far as legally permissible, and void any transactions associated with the account. Parents or guardians who believe a minor has accessed 21com should contact our support team immediately.

12. Updates to This Privacy Policy

21com may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable standards. When we make material changes, we will notify registered players via email or an in-platform notice before the updated policy takes effect.

The "Last reviewed" date at the top of this page reflects the most recent version. Continued use of 21com after a policy update constitutes your acknowledgement of the revised terms. If you have concerns about any update, you can contact our support team or, if you do not accept the changes, request account closure and withdrawal of your PKR balance.