21com Privacy Policy — Your Data, Your Rights

1 Who We Are

21com is an online sports betting and gaming platform operating at 21com.pro. The platform offers sports betting on cricket (including Pakistan Super League and international T20 matches), football, esports and other markets, alongside live casino and slot games.

When this policy refers to "21com," "we," "us" or "our," it means the platform operating at 21com.pro. When it refers to "you" or "your," it means any individual using the platform — whether as a registered account holder or an unregistered visitor.

Questions about this policy or how your data is handled can be directed to the support team at [email protected]. We aim to respond to data-related enquiries within a reasonable timeframe.

2 Data We Collect

The information we collect about you depends on how you interact with 21com. Below is a breakdown of the main categories:

Category	Examples	When Collected
Registration Data	Full name, date of birth, email address, mobile number, password	At account registration
Verification Data	CNIC copy, selfie/photo ID, proof of address, proof of payment method	When identity verification is requested
Financial Data	Deposit and withdrawal amounts, transaction dates, payment method type (JazzCash, Easypaisa, Raast, bank account details)	When making deposits or withdrawals
Gaming Activity	Bets placed, games played, session durations, win/loss records	Continuously during platform use
Technical Data	IP address, device type, operating system, browser, app version	Automatically on each visit or login
Communications	Support chat logs, emails sent to support, feedback submitted	When you contact support
Marketing Preferences	Opt-in status for promotional emails, SMS or push notifications	At registration or updated in account settings

Data You Provide vs Data We Collect Automatically

Some data — like your name, mobile number and CNIC — you provide directly. Other data — like your IP address, device information and browsing behaviour on the platform — is collected automatically through cookies, server logs and tracking technologies. The cookies section below explains this in more detail.

3 How We Use Your Data

We use the data we collect for specific, legitimate purposes. Here is a plain-English breakdown of exactly how your information is used on 21com:

• Account Management: To create and maintain your account, process logins, manage your balance and provide access to all platform features.
• Identity Verification: To confirm your age (18+) and identity before allowing withdrawals or when required by our risk and security processes.
• Payment Processing: To process your PKR deposits and withdrawals through JazzCash, Easypaisa, Raast, bank transfer and card payments. Your payment details are passed to regulated payment processors for this purpose.
• Customer Support: To respond to your queries, resolve disputes, investigate account issues and provide assistance when you contact us.
• Responsible Gaming: To monitor gaming patterns and identify behaviour that may indicate problem gambling, so that we can apply responsible gaming tools where appropriate and fulfil our duty of care.
• Security and Fraud Prevention: To detect and prevent fraud, money laundering, duplicate accounts, bonus abuse and other prohibited activity outlined in the Terms and Conditions.
• Platform Improvement: To analyse how players use the platform, identify technical issues and make improvements to the website and mobile app experience.
• Marketing Communications: If you have opted in, to send you promotions, bonus offers and platform updates relevant to your activity. You can opt out at any time through account settings or by contacting support.
• Legal Compliance: To retain transaction records and account data as required for financial record-keeping and compliance with applicable regulations.

We do not use your data for any purpose beyond what is described in this policy without first informing you and, where required, obtaining your consent.

4 Legal Basis for Processing

Every time we process your personal data, we do so on a recognised legal basis. The main bases we rely on are:

• Contract Performance: Processing necessary to provide the services you have signed up for — account management, payments, betting and gaming services.
• Legitimate Interests: Processing for fraud prevention, platform security, abuse detection and improving user experience — where our interests do not override your rights and freedoms.
• Legal Obligation: Retaining transaction records and identity data where required for financial and compliance purposes.
• Consent: For optional activities such as marketing communications, where we rely on your explicit opt-in. You can withdraw consent at any time.

5 Sharing Your Data

We do not sell your personal data. We do share data with certain third parties where necessary to operate the platform. These are:

Payment Processors

To process your PKR deposits and withdrawals, transaction data is shared with payment service providers including those facilitating JazzCash, Easypaisa, Raast, bank transfers and card payments. These providers process your data under their own privacy and security standards.

Game Providers

When you play casino or slot games on 21com, your gameplay data (session information, bets, results) is shared with the third-party game studios providing those games. This is required for the games to function and for disputes to be resolved. Game providers do not receive your personal identification data.

Identity Verification Services

To verify your identity and age, your CNIC and identification documents may be processed by a third-party verification service. These services are bound by strict data handling obligations.

Platform Infrastructure

Our website and application are hosted on third-party server infrastructure. Technical data such as your IP address and session logs may be processed by our hosting and security providers as part of normal platform operation.

Legal and Regulatory Requirements

We may disclose your data to relevant authorities where legally required — for example, in response to a formal legal request or to report suspected financial crime. We do not make such disclosures voluntarily or beyond what is legally required.

6 Cookies and Tracking Technologies

21com uses cookies and similar tracking technologies to operate the platform, improve performance and, where you have consented, personalise your experience. Here is what you need to know:

Essential Cookies

These cookies are required for the platform to function. They maintain your login session, remember your account preferences and ensure that security checks work correctly. These cannot be disabled without breaking core platform functionality.

Analytics Cookies

We use analytics tools to understand how players navigate the platform — which pages are most visited, where users encounter issues and how long sessions typically last. This data is aggregated and not tied to your personal identity. It helps us improve the platform experience over time.

Performance Cookies

These cookies help the platform load faster and run more reliably by remembering technical settings and caching appropriate content. They do not track personal activity.

Marketing Cookies

If you have opted in to marketing communications, we may use cookies to understand which promotional content resonates with you on the platform. Marketing cookies are only active where you have provided consent and can be withdrawn at any time.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will affect your ability to log in and use the platform normally.

7 Data Retention

We retain your personal data for as long as your account is active and for a period after closure as required for legal, financial and dispute resolution purposes. The general retention periods are:

• Account and identity data: Retained for the life of your account and for a defined period after closure, in line with financial record-keeping requirements.
• Transaction records: Deposit, withdrawal and betting transaction records are retained for an extended period after account closure for financial compliance purposes.
• Support communications: Records of support interactions are retained to assist with dispute resolution and to improve service quality.
• Technical logs: IP address and access logs are retained for a shorter period and used primarily for security monitoring and fraud detection.
• Marketing data: Opt-in status and communication preferences are retained until you withdraw consent or close your account, whichever comes first.

When data is no longer required, it is securely deleted or anonymised. If you close your account and wish to confirm how long specific data will be retained, contact support and we will provide details relevant to your account.

8 Your Rights Over Your Data

As a 21com account holder, you have the following rights in relation to your personal data. To exercise any of these rights, contact support at [email protected] with your request:

9 Data Security

Protecting the data you entrust to us is something we take seriously. The following security measures are in place across the 21com platform:

• Encryption: Data transmitted between your device and our platform is encrypted using industry-standard TLS/SSL protocols. Account passwords are stored in hashed form and are not accessible in plain text.
• Access Controls: Internal access to player data is restricted to staff with a legitimate operational need. Access is logged and monitored.
• Payment Security: Full payment credentials (card numbers, wallet PINs) are not stored by 21com directly. Payment processing is handled by regulated third-party processors who maintain their own security certifications.
• Session Security: Active sessions are monitored for unusual activity. Suspicious login attempts may trigger additional verification steps.
• Your Responsibility: The security of your account also depends on you. Keep your password confidential, do not share your login credentials and contact support immediately if you suspect your account has been accessed without your permission.

While we take all reasonable technical and organisational measures to protect your data, no online system can guarantee absolute security. If you become aware of any security concern related to your account, please report it to support without delay.

10 Children's Privacy

The 21com platform is strictly for adults aged 18 years and above. We do not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and believe that a minor has created an account on 21com, please contact support immediately so the account can be reviewed and closed.

As part of our registration process, all users confirm they are 18 or older. We conduct age verification for withdrawals and may request verification at other stages. Any account found to belong to a person under 18 will be closed and any associated data handled in accordance with applicable rules.

11 Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in how we operate, changes in the services we offer, or changes in applicable requirements. When we make material updates, we will notify registered account holders via the email address on their account.

The updated policy will be published on this page with a revised "Last Updated" date at the top. We recommend reviewing this page periodically if you are an active user of the platform. Your continued use of 21com after an updated policy has been published constitutes your acknowledgement of the changes.

If you disagree with changes to this policy, you should stop using the platform and contact support to discuss your options, including closing your account.

12 Contact Us

If you have any questions about this Privacy Policy, want to exercise your data rights, or have a concern about how your information is being handled, contact the 21com support team:

• Email: [email protected] — data-related requests are typically acknowledged within 2 business days.
• FAQ: Common questions about accounts, payments and platform rules are answered in the FAQ section.

For concerns about responsible gaming or to request account controls such as deposit limits or self-exclusion, visit the Responsible Gaming page or contact support directly.

For general platform terms, see the Terms and Conditions page.