2jey Privacy Policy — Your Personal Data, Your Rights, and Our Obligations

2jey ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of every individual who visits, registers on, or otherwise interacts with the 2jey platform at 2jey.net (the "Platform"). This Privacy Policy is issued in accordance with 2jey's obligations under its international gaming licence and applicable data protection standards, and it governs all personal data processing activities conducted by 2jey in connection with the operation of the Platform.

This Privacy Policy applies to all 2jey account holders, prospective registrants, and visitors to the Platform, including players accessing 2jey from Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Quetta, and all other locations across Pakistan and internationally. By creating a 2jey account or otherwise using the Platform, you acknowledge that you have read this Privacy Policy, understand its contents, and consent to the data processing activities described herein to the extent that consent forms the applicable legal basis for such processing.

For the purposes of this Privacy Policy, 2jey — the entity operating the 2jey platform — acts as the Data Controller in respect of all personal data collected from and about users of the Platform. As Data Controller, 2jey determines the purposes and means of processing your personal data and bears responsibility for ensuring that all processing activities are conducted lawfully, fairly, and transparently.

Where 2jey engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification providers, and cloud infrastructure operators), those third parties act as Data Processors and are contractually bound by data processing agreements that require them to process personal data only on 2jey's documented instructions and in compliance with applicable data protection law.

2jey collects personal data that is necessary for the lawful operation of the Platform, including the provision of gaming services, processing of financial transactions, compliance with regulatory obligations, and the delivery of customer support. The categories of personal data 2jey collects are set out below.

2jey does not collect sensitive personal data categories such as biometric identifiers, health data, racial or ethnic origin, religious beliefs, or political opinions, except to the extent that identity verification documents provided by you may incidentally contain such information.

2jey collects personal data through the following mechanisms:

• Direct Provision by You: Information you provide during account registration, identity verification, deposit or withdrawal requests, customer support interactions, or completion of any form, survey, or questionnaire on the 2jey Platform.
• Automated Technical Collection: Data collected automatically as you interact with the Platform, including IP addresses, device identifiers, session logs, cookies, and behavioural analytics generated by your navigation of the Platform's pages and game lobby.
• Payment Processor Data: Transaction data provided by payment processors — including JazzCash, EasyPaisa, and banking institutions — in connection with deposit and withdrawal processing. This data is transmitted securely and used solely for transaction management and compliance purposes.
• Third-Party KYC Providers: Where 2jey engages a third-party identity verification service to assist with Know Your Customer obligations, that provider may supply supplementary verification data relating to your identity from its own databases, subject to its own terms and privacy practices.
• Third-Party Analytics and Marketing Partners: Aggregated, non-personally identifiable data may be received from analytics platforms to help 2jey understand platform usage patterns. No personal data is received from third-party marketing partners in a form that directly identifies individual users.

2jey processes your personal data only where a valid legal basis exists for doing so. The primary purposes for which 2jey processes personal data, together with the applicable legal basis for each, are as follows:

1. Account Registration and Platform Access: Processing is necessary for the performance of the contract between you and 2jey (i.e., your 2jey account agreement). Without processing identity and contact data, 2jey cannot create or maintain your account.
2. Payment Processing and Financial Transactions: Processing is necessary for contract performance and for compliance with 2jey's legal obligations under its gaming licence, including anti-money laundering and financial crime prevention requirements.
3. Identity Verification (KYC): Processing is necessary for compliance with legal obligations imposed on 2jey by its gaming licence, including mandatory Know Your Customer procedures, age verification, and source-of-funds verification.
4. Fraud Prevention and Platform Security: Processing is necessary for the purposes of 2jey's legitimate interests — specifically, the prevention of financial crime, fraudulent account activity, and platform security breaches that could harm both 2jey and its legitimate users.
5. Responsible Gaming Monitoring: Processing is necessary for compliance with responsible gaming obligations under 2jey's gaming licence, including the monitoring of player activity for signs of problem gambling behaviour and the enforcement of self-imposed limits.
6. Customer Support: Processing is necessary for the performance of the contract between you and 2jey, enabling 2jey to respond to queries, resolve disputes, and provide the support services to which you are entitled as a 2jey account holder.
7. Promotional Communications: Processing of contact data for the purpose of sending promotional emails or SMS communications is based on your consent, which you may withdraw at any time by updating your notification preferences in the 2jey account settings or by contacting the support team.
8. Regulatory Reporting: Processing is necessary for compliance with reporting obligations to 2jey's licensing authority and, where required by law, to relevant governmental or regulatory bodies.

2jey does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. Personal data may be shared with carefully selected third parties only in the circumstances described below, and always subject to appropriate contractual data protection safeguards.

• Payment Service Providers: Financial data is shared with payment processors — including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT processing infrastructure — solely for the purpose of executing deposit and withdrawal transactions initiated by you. Each payment processor operates under its own privacy policy and regulatory obligations.
• Identity Verification Providers: Identity data and verification documents may be shared with accredited third-party KYC service providers engaged by 2jey to fulfil its regulatory identity verification obligations. These providers are bound by data processing agreements and are prohibited from using your data for any purpose other than the verification services they perform for 2jey.
• Game Software Providers: Gaming data including session identifiers may be shared with 2jey's licensed game software providers where necessary for the technical operation of their games within the 2jey platform. These providers do not receive your identity or financial data.
• Technology and Infrastructure Providers: Technical data is processed by cloud hosting, platform security, and analytics service providers engaged by 2jey under contractual data processing agreements that prohibit use of the data beyond the specific services rendered to 2jey.
• Regulatory Authorities: 2jey may be required to disclose personal data to its licensing authority, governmental bodies, or law enforcement agencies in response to lawful requests, court orders, or regulatory enquiries. 2jey will comply with such requests to the extent required by Applicable Law and will notify you of any such disclosure where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, sale of substantially all assets, or corporate restructuring involving 2jey, personal data held by 2jey may be transferred to the acquiring entity. You will be notified of any such transfer and its implications via prominent on-platform notification or email in advance of the transfer taking effect where practicable.

The 2jey Platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure user experience. A cookie is a small text file stored on your device by your web browser when you visit the Platform. Cookies do not contain executable code and cannot carry viruses or malware.

2jey uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These cookies manage your login session, maintain your account authentication state, remember your language preferences, and enable core security functions such as CSRF protection. These cookies cannot be disabled without materially impairing the functionality of the 2jey Platform.
• Performance and Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate and interact with the Platform. This data is used by 2jey to identify performance bottlenecks, optimise page load times, and improve the overall user experience. These cookies do not identify you personally.
• Functional Cookies: Used to remember your preferences — such as your preferred game categories, display settings, and notification preferences — so that these settings persist between sessions without you needing to re-configure them each time you log in to 2jey.
• Targeting and Advertising Cookies: Where 2jey uses these cookies to deliver relevant promotional content or to measure the effectiveness of marketing activity, they are used only with your consent, which you may withdraw at any time by updating your cookie preferences. These cookies do not result in your personal data being sold or transferred to advertisers.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in to or using the 2jey Platform effectively.

2jey retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, and no longer than is required by 2jey's legal and regulatory obligations. The following retention periods apply as general guidance; specific retention periods may be extended where required by Applicable Law, ongoing regulatory enquiry, or active legal proceedings.

• Active Account Data: Personal data associated with an active 2jey account is retained for the duration of the account relationship and for a minimum period of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements under 2jey's gaming licence.
• Identity Verification Documents: KYC documentation — including copies of CNIC, passport, utility bills, and payment method verification — is retained for a minimum of five (5) years following account closure, or longer if required by regulatory direction.
• Transaction Records: Financial transaction records, including deposit and withdrawal histories denominated in PKR, are retained for a minimum of five (5) years in compliance with financial crime prevention record-keeping obligations.
• Gaming Records: Game history, bet records, and session logs are retained for a minimum of five (5) years following account closure and may be retained longer where relevant to an open dispute, regulatory enquiry, or responsible gaming investigation.
• Communications Records: Customer support transcripts and email correspondence are retained for a minimum of three (3) years following the closure of the relevant support interaction.
• Marketing Consent Records: Records of consent to receive promotional communications are retained for the duration of the account relationship and for one (1) year following account closure or withdrawal of consent, as evidence of the basis on which marketing was conducted.

At the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any identifiable individual.

2jey implements robust technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures are reviewed and updated regularly to reflect evolving security standards and the nature of the data processed.

• All data transmitted between your device and the 2jey Platform is encrypted using 256-bit Transport Layer Security (TLS/SSL) — the same encryption standard used by major international banking institutions.
• Personal data stored within 2jey's systems is encrypted at rest using industry-standard encryption algorithms. Database access is restricted to authorised personnel on a strict need-to-know basis, with access controls enforced through role-based access management systems.
• 2jey's systems are monitored continuously for unusual access patterns, potential intrusion attempts, and anomalous activity. Automated alerting triggers immediate investigation of any detected security event.
• Employee access to personal data is governed by internal data protection policies and staff receive mandatory data protection training as part of the 2jey onboarding process and through annual refresher programmes.
• 2jey maintains an incident response procedure that includes player notification protocols in the event of a personal data breach that carries a risk of harm. Where a notifiable breach occurs, 2jey will notify affected players and relevant regulatory authorities within the timeframes required by Applicable Law.
• Third-party vendors with access to personal data are subject to security due diligence assessments before engagement and are contractually required to maintain security standards that are equivalent to or greater than those maintained by 2jey.

Subject to the conditions and limitations imposed by Applicable Law, you hold the following rights in respect of your personal data processed by 2jey. To exercise any of these rights, please contact 2jey's data privacy team using the contact information provided in Section 14. 2jey will acknowledge your request within five (5) business days and endeavour to fulfil it within thirty (30) days, subject to any legal extensions.

Where 2jey discovers or has reasonable grounds to believe that personal data has been collected from a person under the age of 21 — whether through misrepresentation at registration or otherwise — 2jey will take immediate action to close the associated account, return any real-money balance to the registered payment method, and permanently delete all personal data associated with the underage individual from its systems, subject only to any mandatory regulatory retention obligations relating to the detection of the underage access itself.

Parents and guardians who believe that a minor under their care has created a 2jey account or provided personal data to the Platform should contact 2jey's support team immediately. 2jey will investigate and take corrective action as rapidly as possible upon receipt of such a report.

As a platform operating under an international gaming licence and using globally distributed technology infrastructure, 2jey may transfer personal data across international borders in the course of its operations. Such transfers occur, for example, when data is processed by cloud infrastructure providers whose server infrastructure is located outside Pakistan.

Where personal data is transferred to a jurisdiction that does not provide a level of data protection equivalent to that required under 2jey's licensing framework, 2jey ensures that appropriate safeguards are in place to protect your personal data. These safeguards may include the use of standard contractual clauses, binding corporate rules, or other legally recognised transfer mechanisms that impose data protection obligations on the recipient of the data that are equivalent to those under which 2jey itself operates.

By using the 2jey Platform, you acknowledge that your personal data may be transferred to and processed in countries outside Pakistan, and that 2jey will take all reasonably practicable steps to ensure that such transfers are conducted in compliance with applicable data protection standards.

2jey reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, technological developments, regulatory requirements, or for any other operational reason. The most current version of this Privacy Policy will always be available at 2jey.net/privacy-policy and will display the date on which it was most recently updated.

Where any amendment to this Privacy Policy is material — meaning it substantially changes how we collect, use, or share your personal data — 2jey will notify registered account holders via email or through a prominent on-platform notification in advance of the amended policy taking effect. For non-material amendments, your continued use of the 2jey Platform following the updated policy's publication date constitutes your acceptance of the revised terms.

We encourage you to review this Privacy Policy periodically, particularly if you are a long-term 2jey account holder, to stay informed about how 2jey protects and manages your personal data. If you have any concerns about a change to this Privacy Policy, please contact the 2jey data privacy team as described in Section 14 before continuing to use the Platform.

If you have any question about this Privacy Policy, wish to exercise any data subject right described in Section 10, wish to report a suspected privacy breach, or have any concern about how 2jey handles your personal data, please contact the 2jey data privacy team using the details below. The email address is provided as plain text only and is not a clickable link.

• Data Privacy Email (plain text — not a link): [email protected]
• Subject Line: Please mark any data privacy enquiry with "Privacy Request" in the subject line to ensure it is directed to the appropriate team member promptly.
• Live Chat: The 2jey live chat facility — accessible 24/7 from within the Platform after logging in — can also be used to raise data privacy questions. Support is available in English and Urdu.
• Response Timeline: 2jey acknowledges all data privacy enquiries within five (5) business days and aims to provide a substantive response within thirty (30) calendar days of receipt, subject to any legally permitted extensions for complex requests.