Privacy Policy — 2agam

1. Introduction

This Privacy Policy ("Policy") is issued by 2agam ("we", "us" or "our"), the operator of the website located at https://2agam.cam (the "Platform"). It describes how we collect, use, disclose, store and protect personal data relating to users ("you" or "your") of the Platform and associated services.

By accessing or using the Platform — including registering an account, placing a bet, submitting identity verification documents or contacting our support team — you acknowledge that you have read and understood this Policy and consent to the data practices described herein. This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy.

If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately and may request account closure by contacting support.

2. Definitions

For the purposes of this Policy, the following terms have the meanings assigned below:

• "Account" — the personal registered account maintained by a User on the Platform.
• "Data Controller" — the entity that determines the purposes and means of processing personal data; in this context, 2agam.
• "Data Processor" — a third party that processes personal data on behalf of 2agam under a contractual arrangement.
• "Data Subject" — any identified or identifiable natural person whose personal data is processed; in this context, a User.
• "KYC" — Know Your Customer; the identity and age verification process applied to User accounts.
• "Personal Data" — any information relating to an identified or identifiable natural person, including names, identification numbers, location data, online identifiers and financial information.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Sensitive Personal Data" — a subset of personal data that warrants heightened protection, including identity document numbers, biometric data and financial records.

3. Personal Data We Collect

We collect the following categories of personal data from or about you:

3.1 Identity & Contact Data

• Full legal name as it appears on your identity document;
• Date of birth;
• Nationality and country of residence;
• Email address and, where provided, telephone number;
• Copies of identity documents submitted for KYC purposes, which for Pakistani users may include a valid CNIC (Computerised National Identity Card) or passport.

3.2 Financial Data

• Payment method details required to process deposits and withdrawals (stored only in tokenised form where technically feasible);
• Transaction history, including deposit amounts in PKR, withdrawal requests and bonus credits;
• Source-of-funds information where requested for AML compliance purposes.

3.3 Account & Activity Data

• Account login credentials (passwords stored in hashed form only);
• Betting and gaming history;
• Bonus participation and wagering records;
• Responsible gambling tool settings, including deposit limits and self-exclusion requests.

3.4 Technical & Usage Data

• IP address, browser type and version, device type and operating system;
• Pages visited, session duration and navigation patterns on the Platform;
• Cookies and similar tracking data (see Section 10);
• Geolocation data derived from your IP address.

3.5 Communications Data

• Records of correspondence with our support team via email or live chat;
• Responses to surveys or feedback requests, where voluntarily provided.

4. How We Collect Your Data

We collect personal data through the following means:

• Direct provision — data you submit during registration, KYC verification, deposit/withdrawal requests, support interactions or survey responses;
• Automated technologies — cookies, web beacons, server logs and analytics tools that collect technical and usage data as you interact with the Platform;
• Third-party sources — identity verification service providers, fraud detection agencies and, where applicable, payment processors who share data with us for transactional or compliance purposes.

5. Data Processing & Purpose

The table below sets out the principal purposes for which we process your personal data and the corresponding data categories involved.

Purpose	Data Categories
Account registration and management	Identity & Contact, Account & Activity
Identity verification (KYC) and age confirmation	Identity & Contact (including CNIC / passport)
Processing deposits, withdrawals and bonus credits in PKR	Financial, Account & Activity
Fraud prevention and anti-money laundering (AML) compliance	Identity & Contact, Financial, Technical & Usage
Responsible gambling monitoring and tool enforcement	Account & Activity
Customer support and dispute resolution	Identity & Contact, Communications, Account & Activity
Platform performance analysis and improvement	Technical & Usage
Sending account notifications and service updates	Identity & Contact, Communications
Compliance with legal and regulatory obligations	All categories, as required

6. Legal Basis for Processing

Where applicable data protection law requires us to identify a legal basis for processing, we rely on the following grounds:

• Contractual necessity — processing required to perform our contract with you, including account management, transaction processing and service delivery;
• Legal obligation — processing required to comply with applicable law, including KYC, AML, tax reporting and regulatory requirements;
• Legitimate interests — processing carried out in pursuit of 2agam's legitimate business interests, including fraud prevention, platform security and analytics, where those interests are not overridden by your rights;
• Consent — where we have obtained your explicit consent, such as for optional marketing communications. Consent may be withdrawn at any time by contacting support.

7. Data Sharing & Disclosure

2agam does not sell, rent or trade your personal data to third parties. We may share your data with the following categories of recipient only to the extent necessary for the stated purpose:

• Identity verification providers — third-party KYC service providers engaged to verify CNIC, passport or other identity documents submitted by Pakistani users;
• Payment processors — entities involved in facilitating deposits and withdrawals. References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on the Platform are for user familiarity only; none of these institutions endorse gambling on this Platform. Actual payment processing arrangements depend on the operator's live cashier configuration;
• Fraud and AML screening services — agencies that assist in detecting and preventing fraudulent transactions and money laundering activity;
• Technology and hosting providers — infrastructure, cloud storage and analytics service providers operating under contractual data processing agreements with 2agam;
• Legal and regulatory authorities — law enforcement agencies, courts, regulators or other authorities when disclosure is required by applicable law or valid legal process;
• Corporate transactions — in the event of a merger, acquisition or sale of assets, your data may be transferred to the acquiring entity subject to equivalent privacy protections.

8. International Data Transfers

The Platform and its associated infrastructure may be located outside Pakistan. As a result, your personal data may be transferred to and processed in jurisdictions other than your own. Where such transfers occur, 2agam takes reasonable steps to ensure that recipient jurisdictions or entities provide an adequate level of protection for personal data, consistent with the standards described in this Policy.

Users who have concerns about international data transfers are encouraged to contact our support team for further information about the specific safeguards in place.

9. Data Retention

We retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including compliance with our legal, regulatory, accounting and reporting obligations. The following general retention principles apply:

• Active accounts — data is retained for the duration of the account relationship and for a reasonable period thereafter;
• Closed accounts — identity, financial and transaction records are typically retained for a minimum of five (5) years following account closure to comply with AML and regulatory requirements. This period may be extended where required by law;
• Support communications — retained for a period sufficient to resolve disputes and meet statutory obligations, generally three (3) years;
• Technical and usage logs — retained for up to twelve (12) months for security and analytics purposes, after which they are anonymised or deleted.

10. Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They are widely used to make websites function correctly, improve performance and provide usage analytics to operators.

10.2 Cookies Used by 2agam

• Strictly necessary cookies — essential for the Platform to function, including session authentication and security tokens. These cannot be disabled without impairing Platform functionality;
• Performance and analytics cookies — collect anonymous information about how users interact with the Platform, helping us identify areas for improvement;
• Functional cookies — remember your preferences such as language settings, PKR currency display and responsible gambling tool configurations;
• Targeting and personalisation cookies — used to deliver content and promotions that are relevant to your activity on the Platform, where applicable.

10.3 Managing Cookies

You can manage or disable cookies through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use certain features of the Platform, including account login. Most modern browsers offer detailed cookie management controls in their privacy or security settings menu.

11. Your Data Rights

Subject to applicable law, you may have the following rights in respect of your personal data. To exercise any of these rights, please contact us using the details in Section 16.

We will respond to rights requests within a reasonable timeframe, typically within thirty (30) days. In complex cases, this period may be extended by a further two months, with prior notification.

12. Security Measures

2agam implements a range of technical and organisational measures designed to protect your personal data against unauthorised access, accidental loss, disclosure, alteration or destruction. These include:

• HTTPS/TLS encryption for all data transmitted between your device and the Platform;
• Hashed storage of passwords — plain-text passwords are never stored;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular security assessments and monitoring of Platform infrastructure;
• Contractual data security obligations imposed on all third-party processors.

13. Children's Privacy

The Platform is strictly for adults aged 18 or older — or the higher minimum required by the operator or license jurisdiction. We do not knowingly collect personal data from individuals below the applicable minimum age. If you believe a minor has registered an account or provided personal data to us, please notify our support team immediately. Upon verification, we will take appropriate steps to remove the data and close the account.

14. Third-Party Links & Services

The Platform may reference or link to third-party services, payment providers or informational resources. 2agam is not responsible for the privacy practices of external websites or third-party services. This Policy applies solely to data processed by 2agam through the Platform. We encourage you to review the privacy policies of any third-party services you use in connection with your account.

15. Policy Amendments

We reserve the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements or Platform features. When material changes are made, we will publish the updated Policy on this page with a revised effective date and, where reasonably practicable, notify registered users via the email address associated with their account.

Your continued use of the Platform following the publication of an updated Policy constitutes your acceptance of those changes. We encourage you to review this page periodically to stay informed of how we protect your data.

16. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or to the processing of your personal data, please contact the 2agam Privacy Team through the following channels. Email addresses are provided as plain text only — please do not send sensitive documents through unsecured channels.

• Privacy & Data Enquiries: [email protected]
• General Enquiries: [email protected]
• Live Chat: Available during platform hours via the in-platform chat widget. Please do not share sensitive personal data through live chat.

For related information, please review our Terms & Conditions, Responsible Gambling Policy and FAQ.