Privacy Policy — 2bat

Section 01

Introduction

This Privacy Policy ("Policy") sets out how 2bat ("2bat", "we", "us", "our"), the operator of the online betting and casino information platform accessible at 2bat.cam, collects, processes, stores, shares and protects the personal data of individuals ("Users", "you", "your") who access or use our services.

2bat is an English-language platform serving users across Pakistan, including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We recognise that our users trust us with their personal information when they register accounts, make deposits and engage with our sports betting and casino content. That trust is something we take seriously.

This Policy is intended to comply with applicable data protection obligations and to give you clear, honest information about how your data is used. It should be read alongside our Terms & Conditions and Responsible Gambling policy, which together constitute the full framework governing your use of the 2bat platform.

Section 02

Definitions

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, phone number, IP address and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure and deletion.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, 2bat is the Data Controller.
• "Data Processor" means any third party that processes Personal Data on behalf of 2bat under our instruction and pursuant to a data processing agreement.
• "KYC Data" means identity and address verification documentation collected as part of the Know Your Customer process, including government-issued ID, proof of address and source of funds information.
• "Cookies" means small text files placed on your device by the platform to support core functionality, remember preferences and analyse usage behaviour.
• "Platform" means the 2bat website at 2bat.cam and all associated pages, features and services.
• "Third Party" means any individual or organisation other than you and 2bat.

Section 03

Data Controller

2bat is the Data Controller in respect of the Personal Data collected and processed through the Platform. As Data Controller, we determine what data is collected, for what purposes it is used and how long it is retained.

Where we engage Third Party Data Processors to assist in delivering our services — for example, payment processing infrastructure, identity verification providers or analytics services — we ensure that such processors are bound by contractual obligations that require them to handle your data securely and only for the purposes we authorise.

If you have questions about how your personal data is handled or wish to exercise any of your rights under this Policy, please contact us using the details in Section 16.

Section 04

Data We Collect

We collect the following categories of personal data in the course of providing the Platform and its services:

4.1 Registration and Account Data

• Full name, date of birth and gender (for age and identity verification);
• Email address and, where provided, mobile phone number;
• Username and encrypted password;
• Residential address, city and country of residence;
• Preferred language and currency settings.

4.2 Identity Verification (KYC) Data

• Copy of government-issued photo identification (national identity card, passport or driving licence);
• Proof of address documentation;
• Source of funds documentation where requested by our compliance team;
• Facial verification data where required by our identity verification provider.

4.3 Financial and Transactional Data

• Deposit and withdrawal transaction records including amounts, dates and payment method identifiers;
• Payment method details such as partial account numbers or wallet identifiers (we do not store full payment card numbers);
• Transaction history and account balance records.

4.4 Betting and Gaming Activity Data

• Bet history, game play records, stakes, outcomes and winnings;
• Responsible gambling limit settings and self-exclusion records;
• Session duration and login frequency data.

4.5 Technical and Device Data

• IP address and approximate geolocation derived therefrom;
• Device type, operating system and browser version;
• Cookie identifiers and session tokens;
• Platform usage logs, error logs and performance data.

4.6 Communications Data

• Support ticket contents and chat logs;
• Email correspondence with our support team;
• Records of any marketing preference selections or opt-out requests.

Section 05

How We Collect Your Data

We collect personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or update your account preferences.
• Automatically — through cookies, session tracking and server log files when you access and navigate the Platform.
• From third-party verification services — where we use specialist identity verification providers to assist with KYC checks, those providers may supply us with verification status information derived from their own data sources.
• From payment processors — transaction confirmation data and, where applicable, fraud-risk signals provided by payment processing partners in connection with your deposits and withdrawals.

Section 06

Purposes of Processing & Legal Basis

We process personal data only where we have a lawful basis to do so. The table below describes the primary purposes for which we process your data and the corresponding legal basis applied:

Where processing is based on your consent — for example, marketing communications — you may withdraw that consent at any time by updating your communication preferences in your account settings or by contacting our support team. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Section 07

Data Sharing & Third-Party Disclosure

We do not sell your personal data to third parties. We share personal data only in the following limited circumstances and always subject to appropriate data protection safeguards:

7.1 Service Providers and Data Processors

We engage trusted third-party service providers to assist in the delivery of our services, including payment processing infrastructure, identity verification and KYC services, platform hosting and cloud infrastructure, fraud detection and security monitoring, and customer support tooling. These providers act as Data Processors under our instruction and are contractually required to process your data only for the purposes we specify and to maintain appropriate security standards.

7.2 Legal and Regulatory Obligations

We may disclose your personal data to competent authorities, regulators, law enforcement agencies or courts where we are legally required to do so, or where disclosure is necessary to protect our legal rights, comply with a legal process, or prevent fraud or other criminal activity.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of the 2bat business, personal data held by us may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the applicable privacy arrangements through the Platform or by email.

7.4 Consent-Based Sharing

We will share your personal data with any other third party only with your explicit prior consent, which you may withdraw at any time.

Section 08

International Data Transfers

In the course of operating the Platform and using third-party service providers, your personal data may be transferred to and processed in countries outside of Pakistan. Some of these jurisdictions may not have data protection laws equivalent to those applicable in Pakistan.

Where such transfers occur, we take appropriate steps to ensure that your personal data is afforded an equivalent level of protection, including by entering into contractual arrangements with receiving parties that impose data protection obligations consistent with this Policy.

If you have questions about the safeguards applied to international transfers of your data, please contact us at the details provided in Section 16.

Section 09

Data Retention

We retain your personal data for as long as is necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law or regulatory obligation.

The following general retention principles apply:

• Active account data is retained for the duration of your account's active status and for a period following account closure as required by anti-money laundering (AML) regulations and our licensing obligations.
• KYC documentation is retained for a minimum period as mandated by applicable regulatory requirements, typically five years from the end of the business relationship.
• Transaction records are retained for the period required to comply with financial record-keeping obligations under applicable law.
• Responsible gambling records, including self-exclusion history and limit settings, are retained to comply with our responsible gambling obligations and to prevent circumvention of exclusion orders.
• Support communications are retained for a reasonable period for quality assurance and dispute resolution purposes.
• Technical and analytics data is generally retained in aggregated or anonymised form after a reasonable operational period.

Upon expiry of the applicable retention period, data is securely deleted or rendered permanently anonymous such that it can no longer be attributed to you as an identifiable individual.

Section 10

Cookies & Tracking Technologies

The 2bat Platform uses cookies and similar tracking technologies to support essential functionality, improve user experience and analyse how the Platform is used. This section explains the types of cookies we deploy.

You can manage or disable non-essential cookies through your browser's settings. Note that disabling functional or analytics cookies may affect your experience on the Platform but will not prevent you from accessing core services. We do not deploy cookies for the purposes of third-party advertising or cross-site tracking for commercial profiling.

Section 11

Your Rights as a Data Subject

Subject to applicable data protection law and any overriding legal obligations (such as AML retention requirements), you have the following rights in relation to your personal data held by 2bat:

To exercise any of these rights, please contact us at [email protected]. We will respond to verified requests within a reasonable timeframe in accordance with applicable obligations. We may need to verify your identity before processing a rights request to prevent unauthorised disclosure or deletion of data.

Section 12

Children's Privacy

The 2bat Platform is strictly intended for adults aged 18 or older — or such higher minimum age as required by the applicable operator or license jurisdiction. We do not knowingly collect personal data from individuals under the minimum age requirement.

If we become aware or reasonably suspect that personal data has been collected from an individual below the minimum age, we will take immediate steps to delete that data and close the associated Account. We reserve the right to request proof of age at any point during the registration process or Account lifecycle.

If you believe that a minor may have registered an Account or provided us with their personal data, please notify us immediately at [email protected].

Section 13

Security Measures

We implement a range of technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest within our database infrastructure;
• Role-based access controls limiting staff access to personal data to those with a legitimate operational need;
• Two-factor authentication support for Account access;
• Automated fraud and anomaly detection systems monitoring Account activity for irregular patterns;
• Regular security assessments and penetration testing of Platform infrastructure;
• Incident response procedures to address data breaches or security events promptly.

While we apply industry-standard security practices, no transmission of data over the internet or electronic storage system can be guaranteed as completely secure. Users are responsible for maintaining the security of their own Account credentials and for notifying us promptly of any suspected unauthorised access.

Section 14

Third-Party Links & Services

The Platform may contain references to or integrations with third-party services — for example, payment infrastructure providers or identity verification services used during the KYC process. These third parties have their own privacy policies and data handling practices, which are independent of this Policy.

We are not responsible for the privacy practices or content of any third-party services accessed in connection with your use of the Platform. We encourage you to read the privacy policies of any third-party service you interact with.

Payment provider names referenced on this Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are cited as familiar Pakistani payment references only. Any data processing they conduct is governed by their own privacy terms and applicable regulation, not by this Policy.

Section 15

Updates to This Privacy Policy

We reserve the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements or our data processing practices. Any material changes will be communicated to you via the Platform and, where we hold your contact information, by email.

The "Last Updated" date at the top of this Policy will be revised whenever changes are made. Your continued use of the Platform following notification of a revised Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically to stay informed about how we protect your personal data.

Section 16

Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or to the processing of your personal data by 2bat, please contact our support team through the following channels. All privacy-related enquiries are handled in English; Urdu-language assistance is available on request.

We aim to acknowledge all privacy-related requests within a reasonable period and to resolve them as promptly as our legal obligations allow. For requests involving data access, correction or deletion, we may need to verify your identity before proceeding.