dewi21 Privacy Policy

1 Introduction

dewi21 ("we", "us", "our") operates the online casino and sports betting platform accessible at dewi21.ws (the "Platform"). We are committed to protecting the privacy and personal data of all players, visitors, and users who interact with the dewi21 Platform, particularly our Pakistani players from Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and across Pakistan.

This Privacy Policy sets out in full the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

By accessing the dewi21 Platform, registering an Account, making a deposit, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2 Data Controller

For the purposes of applicable data protection legislation, dewi21 — the operator of the dewi21 Platform at dewi21.ws — acts as the Data Controller in respect of personal data collected through the Platform.

As Data Controller, dewi21 determines the purposes and means of processing your personal data. If you have any questions about how your data is handled, or wish to exercise any of your rights described in Section 12, you may contact us at:

3 Data We Collect

3.1 Registration and Account Data

When you create a dewi21 Account, we collect the following personal information:

• Full legal name (as it appears on your CNIC or passport);
• Date of birth (for mandatory 21+ age verification);
• Pakistani CNIC number or passport number (for KYC verification);
• Residential address in Pakistan (city, street, postal code);
• Email address;
• Mobile phone number.

3.2 Financial and Payment Data

To process PKR deposits and withdrawals, we collect payment-related information including:

• JazzCash or EasyPaisa account identifiers;
• Bank account details for HBL, UBL, Meezan Bank, or other supported Pakistani banks;
• Raast payment ID where applicable;
• Transaction amounts, dates, and reference numbers;
• Debit card details (processed via our secure payment provider — dewi21 does not store full card numbers).

3.3 Identity Verification Documents

As part of our KYC (Know Your Customer) and AML (Anti-Money Laundering) obligations, we may collect and retain copies of:

• Pakistani CNIC (front and back);
• Valid passport;
• Proof of address (utility bill, bank statement);
• Selfie or live photo for biometric identity confirmation where required.

3.4 Technical and Device Data

When you access the dewi21 Platform, we automatically collect certain technical data, including:

• IP address and approximate geographic location;
• Device type, operating system, and browser version;
• Session start and end times;
• Pages and game titles accessed;
• Referring URLs (if you arrived from another page).

3.5 Gaming and Betting Activity

We maintain logs of your gaming and betting activity on the Platform, including game results, bet amounts, deposit and withdrawal history, bonus activity, and responsible gaming tool usage. These logs are maintained for regulatory compliance, dispute resolution, and responsible gaming monitoring purposes.

3.6 Communications Data

When you contact dewi21 support, respond to promotional communications, or submit feedback, we retain records of those communications including the content, date, and your contact details at the time of the communication.

4 How We Collect Data

dewi21 collects personal data through the following channels:

• Directly from you — when you register an Account, complete KYC verification, make deposits or withdrawals, contact customer support, or participate in promotions;
• Automatically — through cookies, log files, and similar tracking technologies when you browse or use the dewi21 Platform (see Section 8 for full details);
• From third-party identity verification providers — dewi21 may use accredited third-party KYC services to verify CNIC and passport data against official databases;
• From payment processors — JazzCash, EasyPaisa, and our banking partners may share transaction confirmation data with dewi21 to facilitate deposits and withdrawals;
• From fraud prevention services — dewi21 uses third-party fraud detection tools that may provide risk scores and flags based on device fingerprinting and behavioural analysis.

5 Legal Basis for Processing

dewi21 processes your personal data only where a valid legal basis exists. The following table summarises the primary legal bases we rely on:

6 How We Use Your Data

dewi21 uses the personal data we collect for the following purposes:

• Account creation and management — to register your dewi21 Account, maintain your profile, and manage your balance in PKR;
• Identity and age verification — to confirm you are 21 or older and to verify your identity as required by our international gaming operating licence;
• Payment processing — to execute PKR deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and debit cards, and to process withdrawal requests to your verified payment method;
• Fraud and AML compliance — to detect, investigate, and prevent fraudulent activity, money laundering, and other financial crimes on the Platform;
• Responsible gaming — to monitor gaming behaviour for indicators of problem gambling and to administer self-exclusion, deposit limits, cooling-off periods, and session time limits;
• Customer support — to respond to your queries, complaints, and requests in a timely and effective manner;
• Bonuses and promotions — to assess your eligibility for promotions, credit bonus funds, and monitor wagering requirement completion;
• Platform improvement — to analyse usage patterns and improve the dewi21 Platform, including its game library, payment flows, and user interface;
• Legal compliance — to comply with applicable laws, regulatory requirements, court orders, and law enforcement requests;
• Marketing communications — to send promotional emails and notifications about dewi21 offers, new games, and PSL cricket betting markets, where you have consented to receive such communications.

7 Data Sharing

7.1 Service Providers

dewi21 shares personal data with carefully selected third-party service providers who assist us in operating the Platform. These providers are contractually bound to process your data only in accordance with dewi21's instructions and applicable data protection law. Categories of service providers include:

• KYC and identity verification providers;
• Payment processors (JazzCash, EasyPaisa, banking partners);
• Fraud detection and cybersecurity providers;
• Cloud infrastructure and hosting providers;
• Third-party game suppliers (Evolution Gaming, Pragmatic Play, and other certified providers);
• Email and customer communications platforms;
• Analytics and platform optimisation services.

7.2 Regulatory and Law Enforcement Disclosure

dewi21 may disclose personal data to regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, where necessary to comply with our AML obligations, or where we are legally compelled to disclose by a court order or equivalent legal instrument.

7.3 Business Transfers

In the event that dewi21 or its operating entity undergoes a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. dewi21 will notify affected users via the Platform or email in advance of any such transfer occurring.

7.4 No Sale of Personal Data

dewi21 does not sell, rent, lease, or otherwise trade your personal data to any third party for commercial or marketing purposes. Your data is an asset held in trust for the purpose of delivering the dewi21 service to you — nothing more.

8 Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow the website to recognise your device on subsequent visits and remember certain preferences or session information. dewi21 uses cookies and similar technologies (such as local storage and session storage) to operate and improve the Platform.

8.2 Types of Cookies We Use

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse non-essential cookies, delete existing cookies, or be notified when a cookie is being set. Please note that disabling certain cookies may affect the functionality of the dewi21 Platform — for example, disabling session cookies may prevent you from staying logged in.

9 Data Retention

dewi21 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and our international gaming licence obligations. The general retention periods applicable to key categories of data are as follows:

• Account and registration data — retained for the duration of your Account, plus a minimum of 5 years following Account closure, in compliance with AML record-keeping requirements;
• KYC and identity documents — retained for a minimum of 5 years from the date of verification or Account closure, whichever is later;
• Financial transaction records — retained for a minimum of 5 years in compliance with AML and financial record-keeping obligations;
• Gaming activity logs — retained for a minimum of 3 years for dispute resolution and responsible gaming purposes;
• Customer support communications — retained for 3 years from the date of the final communication in each support thread;
• Marketing consent records — retained for 3 years from the date of last marketing communication or opt-out, whichever is later.

Where retention beyond these periods is required by a specific legal obligation, court order, or ongoing investigation, dewi21 will retain the relevant data until that obligation or proceeding concludes.

10 International Data Transfers

dewi21 is operated under an international gaming licence and may use service providers located outside of Pakistan. As a result, your personal data may be transferred to and processed in countries other than Pakistan, including countries within the European Economic Area and other jurisdictions that have established data protection frameworks.

Where we transfer personal data internationally, dewi21 takes appropriate steps to ensure that your data receives an adequate level of protection consistent with applicable data protection standards. These steps may include:

• Transferring data only to jurisdictions deemed to have an adequate level of data protection by relevant authorities;
• Using standard contractual clauses approved for international data transfers;
• Implementing contractual data processing agreements with all third-party service providers that handle your data.

11 Security

dewi21 employs a range of industry-standard technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL encryption — all data transmitted between your device and the dewi21 Platform is encrypted in transit using TLS 1.2 or higher;
• Encryption at rest — sensitive data including identity documents and payment details are stored in encrypted form on our servers;
• Access controls — access to personal data within dewi21's systems is restricted to authorised personnel on a strict need-to-know basis;
• Two-factor authentication — available for player Accounts to add an additional layer of login security;
• Regular security audits — dewi21 conducts periodic security reviews and penetration testing of the Platform;
• Fraud monitoring — continuous automated monitoring for suspicious activity, unusual login patterns, and anomalous transaction behaviour.

Despite these measures, no method of transmission over the internet or method of electronic storage is completely secure. dewi21 cannot guarantee the absolute security of your data. In the event of a data breach that is likely to result in a risk to your rights and freedoms, dewi21 will notify affected players in accordance with applicable legal requirements.

12 Your Rights

Subject to applicable data protection law, you have the following rights in respect of your personal data held by dewi21:

• Right of Access — you have the right to request a copy of the personal data we hold about you, free of charge, subject to a reasonable timeframe for fulfilment;
• Right to Rectification — you have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure — you may request deletion of your personal data in certain circumstances, subject to our legal retention obligations described in Section 9;
• Right to Restriction of Processing — you may request that we restrict the processing of your personal data in certain defined circumstances, for example where you contest the accuracy of the data or where processing is unlawful;
• Right to Data Portability — where processing is based on your consent or contractual necessity and is carried out by automated means, you have the right to receive your data in a structured, commonly used, machine-readable format;
• Right to Object — you have the right to object to processing of your personal data where dewi21 relies on legitimate interests as its legal basis, unless dewi21 can demonstrate compelling legitimate grounds that override your interests;
• Right to Withdraw Consent — where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

13 Children & Minors

The dewi21 Platform is strictly restricted to individuals who are 21 years of age or older. dewi21 does not knowingly collect personal data from any person under the age of 21. Age verification is conducted as part of the Account registration and KYC process for all players.

If dewi21 discovers that personal data has been collected from an individual under 21 years of age, the Account will be immediately suspended, all associated data will be quarantined, and any funds held will be dealt with in accordance with our Terms & Conditions and applicable law. The personal data of underage individuals will be deleted upon completion of the investigation, except where retention is required for legal or regulatory purposes.

14 Third-Party Links

The dewi21 Platform may contain links to third-party websites, payment portals, or game provider interfaces. These third-party sites and services have their own privacy policies, and dewi21 has no control over and accepts no responsibility for their privacy practices or content.

This Privacy Policy applies solely to the dewi21 Platform at dewi21.ws. We strongly recommend that you review the privacy policies of any third-party services you access in connection with your use of dewi21.

15 Changes to This Policy

dewi21 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, dewi21 will publish the updated Privacy Policy on this page with a revised "Last Reviewed" date, and may notify registered players by email.

Your continued use of the dewi21 Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. We recommend reviewing this page periodically to stay informed of any changes.

16 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by dewi21, please get in touch with our Privacy Team using the details below: