2jbut Privacy
Policy

This Privacy Policy ("Policy") describes how 2jbut ("we", "us", "our", "the Platform") collects, processes, stores, shares, and protects the personal data of individuals ("you", "the Player", "the User") who access or use any part of the 2jbut platform, including the website, mobile interface, customer support channels, and any associated digital services.

This Policy applies to all current and former registered players, individuals who have initiated but not completed registration, and visitors who browse the 2jbut website without creating an account. It covers personal data collected both online and offline — for example, data submitted through our customer support email.

2jbut operates primarily for the benefit of players based in Pakistan. All data practices described in this Policy are aligned with internationally recognised data protection standards, including principles derived from the General Data Protection Regulation (GDPR) framework, which we adopt as our baseline standard of care regardless of strict jurisdictional requirement.

2jbut collects personal data in the following categories. We only collect information that has a clear, legitimate purpose related to operating your account and our platform.

2jbut collects your personal data through the following channels and mechanisms:

• Direct submission: Data you actively provide during registration, KYC verification, deposit/withdrawal requests, support interactions, and promotional opt-ins.
• Automated collection: Technical and usage data collected automatically when you access the platform via cookies, server logs, and analytics tools. See Section 8 for full cookie details.
• Third-party verification: During KYC and AML checks, we may receive identity verification data from licensed identity verification service providers who cross-reference your submitted documents against official databases.
• Payment processors: Transaction confirmation data from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT network confirmations are received by our systems to credit your account balance.
• Fraud prevention partners: We may receive flagged risk signals from our licensed fraud detection partners when unusual activity is detected on your account. This data is used solely for account security purposes.

2jbut processes your personal data only when there is a clear legal basis for doing so. The table below outlines our primary processing purposes and the legal basis that justifies each:

• Account creation and management — Contractual necessity. Without this data, we cannot operate your account or deliver the services you have contracted us to provide.
• Identity and age verification — Legal obligation. We are required by anti-money laundering regulations and our licensing obligations to verify that all players are who they say they are and are at least 21 years of age.
• Processing deposits and withdrawals — Contractual necessity. Financial data is required to receive your deposits and send your withdrawals accurately and securely.
• Customer support delivery — Contractual necessity and legitimate interest. We retain support communications to resolve disputes, improve service quality, and maintain an accurate record of account interactions.
• Fraud prevention and security — Legitimate interest. Monitoring for unusual account activity protects both you and 2jbut from financial crime and unauthorised access.
• Responsible gaming compliance — Legal obligation and legitimate interest. We are required to monitor player behaviour for signs of problem gambling and to act on self-exclusion requests within legally mandated timeframes.
• Platform improvement and analytics — Legitimate interest. Anonymised or aggregated usage data helps us improve the platform experience for all Pakistani players.
• Promotional communications — Consent. We will only send you promotional emails or SMS messages if you have explicitly opted in to receive them. You may withdraw consent at any time.

2jbut does not sell your personal data. We share personal data only in the following limited and controlled circumstances:

• Licensed payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and our USDT processing partner receive only the minimum transaction data required to process your specific deposit or withdrawal.
• KYC and identity verification providers: Your identity documents are shared with our licensed verification partner solely to confirm your identity and age for regulatory compliance purposes.
• Game content providers: Third-party slot, live dealer, and table game providers receive a pseudonymous player identifier and bet/win data to operate their games on our platform. They do not receive your name, contact details, or financial information.
• Regulatory and law enforcement authorities: We are legally required to disclose certain information — particularly AML-relevant transaction data — to relevant financial intelligence units and regulatory bodies upon lawful request. We will notify you of such disclosures where we are legally permitted to do so.
• What we never do: We never share your data with third-party marketers, data brokers, social media platforms for advertising purposes, or any entity that would use your information for purposes unrelated to the delivery of 2jbut services.

All third-party service providers who receive your personal data are bound by strict data processing agreements that prohibit any use of your data outside the specific purpose for which it was shared.

2jbut retains your personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law and our licensing obligations. The following retention periods apply:

• Account data and identity documents: Retained for the duration of your active account plus a minimum of five (5) years following account closure, as required by AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by financial record-keeping regulations.
• Customer support communications: Retained for three (3) years from the date of the final communication in a support thread.
• Technical and usage data (logs): Retained for twelve (12) months in identifiable form, after which it is anonymised and may be retained indefinitely for statistical purposes.
• Self-exclusion records: Retained permanently to ensure that players who have self-excluded cannot be re-registered in violation of their exclusion request.
• Legal hold: Where your data is subject to a legal hold, investigation, or regulatory inquiry, we will retain relevant data beyond the standard retention period until the matter is resolved.

2jbut implements a comprehensive, layered security architecture to protect your personal data from unauthorised access, alteration, disclosure, or destruction. Our security measures include but are not limited to:

• AES-256 encryption at rest for all stored personal and financial data, with TLS 1.3 encryption for all data in transit between your device and 2jbut servers.
• Role-based access controls ensuring that 2jbut staff can only access the specific data required to fulfil their job function. Customer support agents cannot access your full financial data; finance staff cannot access your game history without proper authorisation.
• Multi-factor authentication requirements for all internal staff accessing systems that hold player personal data.
• Regular third-party penetration testing and vulnerability assessments of our platform infrastructure, conducted by independent cybersecurity specialists.
• 24/7 automated intrusion detection and anomaly monitoring on all servers holding personal data, with immediate incident response protocols triggered on any suspected breach.
• In the event of a personal data breach that poses a risk to your rights and freedoms, 2jbut will notify affected players without undue delay and in accordance with applicable regulatory notification requirements.

2jbut uses cookies and similar tracking technologies to operate the platform, remember your preferences, and understand how players use our services. Below is a transparent breakdown of the cookies we use:

You can manage your cookie preferences at any time through the cookie settings panel accessible from the footer of any 2jbut page, or by adjusting your browser's cookie settings directly. Note that disabling performance or preference cookies may affect your experience on the platform.

As a 2jbut player, you have the following rights over your personal data. 2jbut is committed to honouring these rights promptly and without unnecessary barriers.

2jbut is strictly an adult platform. Our services are not directed at, and are not intended to be used by, any person under the age of 21. We do not knowingly collect personal data from individuals under 21 years of age.

As part of our registration process, all players are required to confirm that they are aged 21 or above. We also conduct mandatory age verification as part of our KYC process, which requires submission of a valid government-issued ID document confirming date of birth. Any account found to belong to a person under the age of 21 will be immediately suspended, all pending withdrawals frozen pending investigation, and any winnings may be forfeited in accordance with our Terms & Conditions.

The 2jbut platform integrates with a number of third-party service providers to deliver the full range of features available to Pakistani players. Each provider operates under its own privacy policy in addition to the data processing agreements we hold with them. Key categories of third-party services include:

• Game content providers: Providers of slot games, live dealer tables, and virtual casino products. These providers receive pseudonymous session data only — no personally identifiable information is shared unless strictly required by the game provider's licensing obligations.
• Payment service providers: JazzCash, EasyPaisa, HBL Pay, UBL Digital, Meezan Bank, and our USDT processing partner. Each processes your financial data under their own regulated privacy and security standards in addition to our contractual requirements.
• Identity verification services: Our licensed KYC partner processes your identity documents on our behalf. They are prohibited from using your data for any purpose other than the specific identity check requested by 2jbut.
• Cloud infrastructure providers: 2jbut's servers are hosted on enterprise-grade cloud infrastructure. Our hosting provider processes data strictly as a data processor acting on our instructions and has no independent right to use your data.
• Links and embedded content: The 2jbut platform does not currently embed third-party widgets or social media plugins that would allow those third parties to collect data about you independently. If this changes, this Policy will be updated accordingly.

In the course of operating the 2jbut platform and delivering services to Pakistani players, some of your personal data may be transferred to, and processed in, countries outside Pakistan. This occurs primarily when data is processed by our cloud infrastructure provider or when identity verification is conducted by an international KYC provider.

Where such transfers occur, 2jbut ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy. Safeguards may include:

• Standard Contractual Clauses (SCCs) or equivalent contractual protections with the receiving entity.
• Transfers only to jurisdictions that maintain an adequate level of data protection as recognised by relevant international standards.
• Binding corporate rules where transfers occur within a corporate group subject to a unified data protection framework.

You may request further information about the specific safeguards in place for international transfers of your personal data by contacting us at the address provided in Section 14.

2jbut reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or our platform services. When we make material changes to this Policy, we will:

• Post the updated Policy on this page with a revised "Last Reviewed" date prominently displayed at the top of the page.
• Send a notification to your registered 2jbut email address if the changes materially affect your data rights or our processing purposes.
• Display an in-platform notification prompting you to review and acknowledge the updated Policy on your next login where required by applicable law.

Your continued use of the 2jbut platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you should discontinue use and contact us to arrange account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 2jbut, please contact our Data Protection team using the details below. All privacy-related correspondence is handled by our dedicated compliance team and not routed through general customer support queues.

If you are not satisfied with our response to a privacy concern, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction. We will cooperate fully with any such investigation.