Privacy Policy for 22wind Players

1. Data We Collect

22wind collects personal data from players through several channels, including account registration, identity verification, financial transactions, gameplay activity, and communications with our support team. The categories of personal data we collect are set out below.

1.1 Registration Data

When you create a 22wind account, we collect the information you provide in the registration form. This includes your full legal name, date of birth, email address, mobile telephone number, and residential address. This information is required to create and operate your account and to verify that you meet the eligibility criteria set out in our Terms & Conditions — including the requirement to be aged 18 or above.

1.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) process, 22wind may require you to provide copies of government-issued identity documents such as a National ID card, passport, or driving licence, as well as proof of address documents and proof of payment method ownership. KYC data is used solely for identity and age verification purposes and is handled with the highest level of security and confidentiality.

1.3 Financial Data

22wind collects financial information necessary to process deposits and withdrawals in ৳ BDT. Depending on the payment method you use — including bKash, Nagad, Rocket, Upay, Visa, or Mastercard — we may collect your mobile wallet number, card details (in tokenised form only), or bank account information. Full card numbers are never stored on 22wind's servers; payment card data is handled by our PCI-DSS compliant payment processing partners.

1.4 Gameplay and Transaction Data

We collect records of all bets placed, games played, winnings received, bonuses claimed, and financial transactions conducted on your account. This data is used for account management, dispute resolution, responsible gambling monitoring, and fraud prevention purposes.

1.5 Technical and Device Data

When you access 22wind, we automatically collect certain technical data from your device and browser. This includes your IP address, browser type and version, operating system, device identifiers, time zone, and pages visited on the platform. This information helps us maintain platform security, optimise user experience, and detect suspicious activity.

1.6 Communications Data

If you contact 22wind's support team by email or through the platform's messaging system, we retain records of those communications, including the content of messages and any attachments provided. These records are used to resolve queries, improve support quality, and maintain a record of player interactions.

2. How We Use Your Data

22wind uses the personal data it collects for specific, legitimate purposes. We do not use personal data for any purpose that is incompatible with those stated in this policy without first obtaining your explicit consent or as required by applicable law.

Purpose	Legal Basis	Data Used
Account creation and management	Contractual necessity	Registration data, KYC data
Age and identity verification	Legal obligation	KYC data, registration data
Processing deposits and withdrawals	Contractual necessity	Financial data, registration data
Fraud prevention and security monitoring	Legitimate interest	Technical data, transaction data, gameplay data
Responsible gambling monitoring	Legal obligation / legitimate interest	Gameplay data, transaction data
Customer support	Contractual necessity	Communications data, registration data
Marketing communications (opted-in players only)	Consent	Registration data, gameplay data
Platform analytics and improvement	Legitimate interest	Technical data, gameplay data (aggregated)

Where 22wind relies on your consent as the legal basis for processing — for example, to send you marketing emails or promotional notifications — you may withdraw that consent at any time by updating your communication preferences in your account settings or by contacting our support team at [email protected]. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to the withdrawal.

3. Data Sharing & Disclosure

22wind does not sell your personal data to any third party. However, in order to operate the platform effectively and comply with applicable legal obligations, we share certain data with carefully selected third-party service providers and, where required, with regulatory authorities.

3.1 Payment Processing Partners

To facilitate deposits and withdrawals in ৳ BDT, 22wind shares the minimum necessary financial data with our payment processing partners, including the operators of bKash, Nagad, Rocket, Upay, and card payment processors. These partners are contractually required to handle your data securely and to use it only for the purpose of processing the specific transaction requested.

3.2 Identity Verification Providers

22wind may engage third-party KYC and anti-money laundering (AML) service providers to assist with identity verification. These providers receive only the data necessary to perform the verification check and are prohibited from using that data for any other purpose.

3.3 Technology and Infrastructure Providers

22wind uses third-party cloud hosting, analytics, and cybersecurity services to operate and protect the platform. These providers may process technical and device data as part of their service delivery. All such providers are subject to data processing agreements that restrict their use of your data to the specific services they provide to 22wind.

3.4 Legal and Regulatory Disclosure

22wind may disclose your personal data to law enforcement agencies, regulatory bodies, or other authorised authorities where required to do so by applicable law, court order, or in connection with the investigation of fraud, money laundering, or other criminal activity. In such cases, 22wind will disclose only the minimum data required to satisfy the legal obligation.

3.5 Business Transfers

In the event that 22wind undergoes a merger, acquisition, or sale of all or part of its business assets, personal data held by the platform may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and of any changes to the applicable privacy terms before the transfer takes effect.

4. Cookies & Tracking

22wind uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain your session, and analyse how the site is used. The following categories of cookies are used on 22wind.app:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They enable core features such as session management, security token validation, and login state persistence. These cookies cannot be disabled without impairing your ability to use the platform.
• Functional Cookies: These cookies remember your preferences — such as your preferred language, display settings, and account options — so that you do not need to re-configure them on each visit.
• Analytical Cookies: 22wind uses anonymised analytical cookies to understand how players navigate and interact with the platform. This data is used in aggregate form to identify usability improvements and optimise the player experience. No individually identifiable data is shared with analytics providers.
• Security Cookies: These cookies support 22wind's fraud detection and account security systems. They help identify unusual access patterns and protect accounts from unauthorised access attempts.

You may manage cookie preferences through your browser settings. Note that disabling certain categories of cookies — particularly strictly necessary cookies — may significantly affect your ability to use 22wind. Continued use of the platform following acceptance of this policy constitutes consent to the use of cookies as described above.

5. Data Security Measures

22wind takes the security of your personal data seriously and employs a range of technical and organisational measures to protect it against unauthorised access, accidental loss, destruction, or disclosure. Our key security measures include:

• SSL/TLS Encryption: All data transmitted between your device and 22wind's servers is encrypted using industry-standard SSL/TLS protocols. You can verify this by checking for the padlock icon in your browser's address bar when accessing 22wind.app.
• Access Controls: Access to personal data within 22wind is restricted to authorised employees and contractors who require access to perform their job functions. All access is governed by role-based permissions and is subject to ongoing audit.
• Password Security: Player account passwords are stored using one-way cryptographic hashing algorithms. 22wind staff cannot view your password in plain text. You are responsible for choosing a strong, unique password and keeping it confidential.
• Penetration Testing: 22wind conducts regular security assessments and penetration testing of its platform infrastructure to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a data breach that poses a risk to player privacy, 22wind has procedures in place to contain the breach, assess its impact, notify affected players, and report to relevant authorities where required by law.

While 22wind takes all reasonable precautions to secure your data, no internet-based platform can guarantee absolute security. You play an important role in protecting your own data by keeping your login credentials confidential, using a strong password, and notifying 22wind immediately if you suspect unauthorised access to your account.

6. Data Retention Policy

22wind retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account Data: Personal data associated with an active 22wind account is retained for the duration of the account relationship and for a period of at least five years following account closure, in order to satisfy anti-money laundering record-keeping obligations.
• KYC and Verification Documents: Identity and address verification documents are retained for a minimum of five years from the date of account closure or the date of the most recent regulated transaction, whichever is later.
• Transaction Records: Records of all financial transactions, including deposits, withdrawals, and bets, are retained for a minimum of five years to support regulatory compliance and dispute resolution.
• Support Communications: Records of customer support interactions are retained for a period of three years from the date of the last interaction.
• Technical and Device Data: Log files and technical data are retained for up to twelve months and are then deleted or anonymised unless required for an ongoing security investigation.
• Marketing Data: Where you have opted in to marketing communications, your marketing preferences and associated data are retained until you withdraw consent or for a period of two years following your last engagement with a marketing communication, whichever comes first.

When personal data is no longer required, 22wind securely deletes or anonymises it in accordance with our internal data disposal procedures.

7. Your Privacy Rights

As a 22wind player, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team at [email protected]. We will respond to all valid requests within 30 days.

• Right of Access: You have the right to request a copy of the personal data that 22wind holds about you. We will provide this in a structured, commonly used format upon receipt of a verified request.
• Right to Rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update certain details — such as your email address or contact number — directly through your account settings.
• Right to Erasure: In certain circumstances, you have the right to request that 22wind delete your personal data. This right is subject to limitations where retention is required by law — for example, for anti-money laundering compliance purposes. We will inform you if a deletion request cannot be fulfilled in full and explain the reason.
• Right to Restrict Processing: You may request that 22wind restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where processing is unlawful but you prefer restriction over deletion.
• Right to Data Portability: Where processing is based on your consent or on a contract, you have the right to receive your personal data in a machine-readable format suitable for transfer to another service provider.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interest, including for direct marketing purposes. Where you object to marketing, we will cease processing your data for that purpose immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Please note that exercising certain rights — such as requesting erasure of your account data — may result in the closure of your 22wind account, as we may be unable to operate the account without the relevant data. We will always advise you of the practical consequences of any privacy rights request before proceeding.

8. Updates to This Policy

22wind reserves the right to update or revise this Privacy Policy at any time in response to changes in our data practices, applicable law, or operational requirements. When we make material changes to this policy, we will notify registered players by email to the address associated with their account, and we will update the effective date shown at the top of this page.

We encourage you to review this Privacy Policy periodically to stay informed about how 22wind protects your data. Your continued use of the platform following notification of a policy update constitutes your acceptance of the revised terms. If you do not agree with the updated policy, you should discontinue use of 22wind and request account closure.

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 22wind, please contact our dedicated privacy support team at [email protected]. We are committed to addressing all privacy-related enquiries promptly and transparently.