Privacy Policy

1Introduction

2jbut ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you access or use the 2jbut platform, available at https://2jbut.cam (the "Platform"), and sets out your rights in relation to that data.

This policy applies to all users of the Platform, including visitors, registered account holders and anyone who interacts with our support services. By accessing the Platform or creating an account, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

We take our obligations under applicable data protection law seriously. If you are located in a jurisdiction with specific data protection legislation, those additional rights may apply to you and we will honour them to the best of our ability.

2Definitions

In this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, postal address, date of birth, financial details and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this case, 2jbut.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller under a formal data processing agreement.
• "KYC" means Know Your Customer — the identity and age verification process required to comply with applicable regulations.
• "Cookie" means a small text file placed on your device by the Platform to store session or preference data.
• "Platform" means the 2jbut website, mobile interface, applications and all associated services at https://2jbut.cam.

3Data Controller

For the purposes of applicable data protection legislation, the Data Controller responsible for your personal data is 2jbut, the operator of the Platform at https://2jbut.cam.

If you have any questions about how your data is handled, or wish to exercise any of your data rights, please contact us using the details in Section 17 (Contact Us).

4Personal Data We Collect

4.1 Data You Provide Directly

When you register an account, use the Platform, contact support or participate in promotions, you may provide us with:

• Full legal name and date of birth
• Email address and account password (stored in hashed form)
• Residential address (where required for KYC or AML purposes)
• Identity documents: CNIC (Computerised National Identity Card), passport or other government-issued ID
• Phone number (where collected for account security or verification)
• Payment account details used for deposits and withdrawals (e.g., bank account numbers, mobile wallet identifiers for services such as Easypaisa or JazzCash — provided as references only; these providers do not endorse gambling)
• Selfie or liveness check images submitted during KYC
• Communications with our support team via live chat or email

4.2 Data We Collect Automatically

When you access or use the Platform, we automatically collect certain technical and usage data:

• IP address and approximate geographic location derived from it
• Device type, operating system and browser version
• Pages visited, features used and session duration
• Betting and gaming activity logs (game played, stakes, outcomes — for account management and responsible gambling monitoring)
• Login timestamps and session identifiers
• Cookie and similar tracking technology data (see Section 10)

4.3 Data from Third Parties

In limited circumstances, we may receive personal data about you from third parties, including:

• Identity verification service providers used to assist with KYC checks
• Fraud prevention and AML screening services
• Payment processors confirming transaction status

5Lawful Basis for Processing

We process your personal data only where we have a lawful basis to do so. The table below summarises the primary bases we rely on:

6How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• Account Management: Creating, maintaining and securing your account; processing login and session activity.
• Transaction Processing: Handling deposits, processing withdrawal requests and maintaining an accurate transaction history.
• Identity Verification: Conducting KYC checks to verify your identity, age and payment ownership in compliance with applicable AML requirements.
• Responsible Gambling: Monitoring betting and gaming activity patterns to identify signs of problem gambling and proactively offering responsible gambling tools such as deposit limits, session reminders and self-exclusion.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, multi-accounting, money laundering and other prohibited conduct.
• Customer Support: Responding to queries, resolving disputes and providing assistance via live chat and email.
• Platform Improvement: Analysing usage patterns (in aggregated or pseudonymised form where possible) to improve Platform performance, features and content.
• Legal Compliance: Meeting our obligations under applicable law, including responding to lawful requests from regulatory or law enforcement authorities.
• Promotional Communications: Where you have opted in, sending relevant offers, promotions and updates. You may opt out at any time.

7Sharing Your Personal Data

7.1 We Do Not Sell Your Data

We will never sell, rent or trade your personal data to third parties for commercial or advertising purposes. Any data sharing is limited to what is necessary for the Platform to function and to comply with our legal obligations.

7.2 Third-Party Service Providers

We may share personal data with trusted third-party service providers who process data on our behalf under formal data processing agreements, including:

• Identity verification and KYC providers
• Payment processors and gateway providers
• Fraud prevention and AML screening services
• Cloud hosting and data storage providers
• Customer support platform providers
• Analytics providers (where data is pseudonymised or aggregated)

All such providers are contractually required to process your data only as instructed, maintain appropriate security measures and not use your data for their own purposes.

7.3 Legal and Regulatory Disclosure

We may disclose personal data to competent authorities, regulators or law enforcement agencies where required by law, court order or regulatory requirement, or where necessary to protect the rights, property or safety of 2jbut, our users or others.

7.4 Payment Provider References

Where you choose to transact using a payment method, your transaction data is shared with the relevant payment processor as necessary to complete the transaction. The mention of payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah is for contextual reference only. None of these providers endorse gambling or have a special relationship with 2jbut beyond standard payment processing.

8KYC & Verification Data

Identity verification data — including CNIC/passport images, selfie photographs and proof-of-address documents — is treated with the highest level of care and subject to the following specific conditions:

• Documents are uploaded exclusively through our secure HTTPS verification portal. Never send identity documents via unsecured chat, email or messaging apps.
• KYC documents are accessible only to authorised members of our Trust & Safety team who have a legitimate operational need to review them.
• KYC data is retained for the period required by applicable AML and regulatory obligations, typically a minimum of five years from the date of account closure or the date of the last transaction, whichever is later.
• Documents must not be altered, obscured or falsified in any way. Submission of fraudulent documents constitutes a criminal offence and will be reported to relevant authorities.

9Payment Data

Payment data — including bank account numbers, mobile wallet identifiers and transaction amounts — is processed in accordance with applicable payment security standards. We do not store full card numbers or sensitive authentication data on our own servers. Payment transactions are processed through PCI-DSS compliant payment processors.

Payment identifiers (such as a registered mobile number associated with a wallet service) are used solely to verify payment ownership during KYC and to process deposits and withdrawals. They are not used for marketing or shared with any party other than the relevant payment processor.

10Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the Platform. They allow the Platform to remember your session, preferences and certain settings between visits.

10.2 Types of Cookies We Use

10.3 Managing Cookies

You can manage or delete cookies through your browser settings at any time. Please note that disabling essential cookies may impair the functionality of the Platform, including your ability to log in or maintain a session. We do not use third-party advertising or behavioural targeting cookies without your explicit consent.

11Data Retention Periods

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with our legal obligations and to resolve any disputes. The following general retention guidelines apply:

• Account data: Retained for the duration of your account and for a minimum period of five years following account closure, in accordance with AML regulatory requirements.
• KYC / identity documents: Retained for a minimum of five years from the date of account closure or last transaction, whichever is later, or longer if required by applicable law.
• Transaction records: Retained for a minimum of five years from the date of the transaction for AML and financial record-keeping purposes.
• Support communications: Retained for a reasonable period following resolution to handle any follow-up queries or disputes.
• Analytics data: Aggregated or pseudonymised analytics data may be retained for longer periods; it is not traceable to individual users after anonymisation.

When data is no longer required and no legal retention obligation applies, it is securely deleted or irreversibly anonymised.

12Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or alteration. These measures include:

• HTTPS/TLS encryption for all data transmitted between your device and the Platform.
• Encrypted storage of passwords (hashed and salted — never stored in plain text).
• Access controls limiting personal data access to authorised personnel with a legitimate need.
• Regular security reviews and vulnerability assessments.
• Secure KYC document handling via dedicated verification infrastructure.

13International Data Transfers

The Platform is operated internationally and your personal data may be processed and stored in jurisdictions outside Pakistan. Where such transfers occur, we ensure that appropriate safeguards are in place, such as contractual data protection clauses or processing within jurisdictions deemed adequate by applicable data protection standards.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in countries outside of Pakistan. We take all reasonably practicable steps to ensure that such transfers are conducted securely and that recipient processors maintain appropriate data protection standards.

14Minors

The Platform is strictly intended for adults aged 18 or over (or the higher minimum age required by the applicable operator or license jurisdiction). We do not knowingly collect personal data from individuals under the minimum age. If we become aware that a minor has provided personal data or created an account, we will take immediate steps to close the account and delete the associated data.

15Your Data Rights

Depending on the data protection laws applicable in your jurisdiction, you may have the following rights in relation to your personal data:

• Right of Access (Subject Access Request): You have the right to request a copy of the personal data we hold about you. We will respond within a reasonable timeframe, typically within 30 days.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data held about you.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where: it is no longer necessary for the original purpose; you withdraw consent and there is no other lawful basis; or we have processed it unlawfully. Note: where legal retention obligations apply (e.g., AML requirements), we cannot fully erase data within the mandatory retention period.
• Right to Restrict Processing: You may request that we restrict processing of your data in certain circumstances, such as where you contest its accuracy or object to processing.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests, including for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds.
• Rights in Relation to Automated Decision-Making: Where decisions are made about you solely by automated means and have a legal or similarly significant effect, you have the right to request human review of that decision.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to Lodge a Complaint: If you believe we have handled your data unlawfully, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

To exercise any of the rights listed above, please contact us using the details in Section 17. We may ask you to verify your identity before processing your request.

16Changes to This Privacy Policy

We reserve the right to update or amend this Privacy Policy at any time. Where changes are material, we will provide reasonable notice by posting the updated policy on the Platform and updating the "Last Updated" date at the top of this page. In some cases, we may provide additional notice via email to registered account holders.

Your continued use of the Platform after any changes take effect constitutes your acceptance of the revised Privacy Policy. If you do not agree with changes, you should stop using the Platform and may close your account in accordance with the account closure process in our Terms & Conditions.

17Contact Us

For any questions, concerns or requests relating to this Privacy Policy or your personal data, please contact us via the following channels. Note: all contact methods below display information as plain text — they are not clickable links.

• Email: [email protected]
• Live Chat: Available 24/7 through the Platform interface
• Response Time: We aim to acknowledge data rights requests within 5 business days and provide a full response within 30 days

For general platform support, bonus queries or withdrawal assistance, please visit our FAQ page.

For information about responsible gambling tools and self-exclusion, please visit our Responsible Gambling page.