22wind Privacy Policy

1 Data Controller

22wind ("we", "us", "our") acts as the data controller in respect of all personal data collected through the 22wind platform. For any questions or requests relating to this Privacy Policy or your personal data, please contact us at [email protected]. 22wind operates as an offshore online gaming platform serving the Bangladesh market. Where data protection law applies to our processing activities, we are committed to upholding the principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

2 Personal Data We Collect

22wind collects personal data through several channels: directly from you when you register and use your account, automatically through your use of the platform, and from third parties involved in payment processing. The categories of personal data we collect include:

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, health information, or political opinions, except where this is incidentally provided by a player in the course of a responsible gaming self-exclusion request, in which case it is treated with the highest level of confidentiality and used only for the purpose of protecting that player.

3 How We Use Your Personal Data

22wind uses your personal data only for legitimate, specified purposes. The primary purposes for which we process your data are as follows:

• Account registration and management: To create and maintain your 22wind player account, verify your identity, and manage your account settings and preferences.
• Transaction processing: To facilitate deposits and withdrawals in BDT via bKash, Nagad, Rocket, and Upay, and to maintain accurate financial records of all transactions associated with your account.
• Customer support: To respond to your queries, complaints, and requests, including responsible gaming requests, and to maintain a record of our communications for quality and compliance purposes.
• Regulatory and legal compliance: To satisfy our anti-money-laundering (AML) obligations, Know Your Customer (KYC) requirements, fraud prevention obligations, and any other applicable legal or regulatory duty imposed on 22wind as an offshore gaming operator.
• Platform security and integrity: To detect, investigate, and prevent fraudulent activity, collusion, bonus abuse, account takeover attempts, and other activities that violate our Terms & Conditions or that may harm other players or the platform.
• Responsible gaming: To monitor player behaviour for indicators of problem gambling, to enforce self-exclusion requests, deposit limits, and cooling-off periods that you have requested, and to contact you if we identify patterns of play that suggest potential harm.
• Marketing communications: To send you promotional offers, bonus notifications, and updates about new games and features on 22wind — but only where you have opted in to receive such communications. You may opt out at any time by contacting support.
• Product improvement: To analyse aggregated usage data and improve the 22wind platform, game selection, user interface, and payment experience for Bangladesh players.

22wind does not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human review, except for standard fraud-detection screening which may temporarily flag an account for manual review.

4 Legal Basis for Processing

22wind processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account and provide gaming services.
• Legal obligation: Processing required to comply with applicable AML, KYC, and fraud prevention obligations binding on 22wind.
• Legitimate interests: Processing for fraud detection, platform security, responsible gaming monitoring, and product analytics, where these interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, which requires your explicit opt-in and which you may withdraw at any time.

5 Sharing Your Personal Data

22wind does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share your data only in the following limited circumstances:

• Payment processors: We share the minimum necessary financial data with bKash, Nagad, Rocket, Upay, and their banking partners (including Dutch-Bangla Bank and other relevant institutions) solely to process your deposit and withdrawal transactions.
• Game software providers: Game providers such as Pragmatic Play, Evolution Gaming, Spribe, Ezugi, NetEnt, and Microgaming may receive anonymised or pseudonymised session data required to deliver their game titles within the 22wind platform. These providers do not receive your identity or contact data.
• Technology and infrastructure partners: Third-party service providers who host our servers, provide our platform software, or deliver our content delivery network (CDN) infrastructure may process your technical data as data processors acting under our instruction and bound by data processing agreements.
• Fraud and AML compliance: We may share data with third-party identity verification services, fraud screening databases, or relevant authorities where we are required or permitted to do so for the purpose of preventing money laundering or fraud.
• Legal authorities: We may disclose your personal data to law enforcement, regulatory bodies, or courts where we are compelled to do so by applicable law, a court order, or a legitimate legal process.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 22wind's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

6 Cookies and Tracking Technologies

22wind uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device when you visit 22wind.vip. We use the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies that keep you logged in and security cookies that help protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Analytics cookies: Used to collect anonymised information about how players navigate 22wind.vip — which pages are visited most frequently, how long sessions last, and where players encounter errors. This data is used in aggregate form to improve the platform experience.
• Preference cookies: Used to remember your account preferences such as language settings and notification preferences, so you do not need to reconfigure them on every visit.

22wind does not currently use third-party advertising cookies or behavioural profiling cookies that track your activity across sites outside of 22wind.vip. You may manage cookie settings through your browser. Please note that disabling strictly necessary cookies will impair your ability to log in and use the platform.

7 Data Retention

22wind retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy or as required by applicable law. The general retention periods that apply are:

• Active account data: Retained for the duration of your registration plus a minimum of five (5) years following account closure, to meet AML and fraud investigation obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in line with standard financial record-keeping requirements applicable to offshore gaming operators.
• KYC verification documents: Retained for five (5) years following account closure or, if longer, for the period required by any applicable AML regulation.
• Support communications: Retained for two (2) years from the date of the last communication, to allow for follow-up on unresolved issues or disputes.
• Marketing consent records: Retained until you withdraw your consent or for three (3) years after your last interaction with a marketing communication, whichever is earlier.
• Analytics data: Anonymised and aggregated analytics data may be retained indefinitely, as it no longer constitutes personal data once identifiers have been removed.

When your personal data is no longer required, 22wind will securely delete or anonymise it in accordance with our internal data disposal procedures.

8 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 us at [email protected] with your full name, registered mobile number, and a clear description of your request. We will respond within 30 calendar days.

• Right of access: You may request a copy of the personal data 22wind holds about you.
• Right to rectification: You may request correction of any personal data that is inaccurate or incomplete.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected and where 22wind has no overriding legal obligation to retain it.
• Right to restrict processing: You may request that 22wind restricts the processing of your personal data in certain circumstances, such as while an accuracy dispute is being resolved.
• Right to data portability: Where technically feasible and where processing is based on your consent or on contract, you may request that your data be provided in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You may object to processing based on legitimate interests, including profiling for responsible gaming monitoring, subject to 22wind's overriding obligation to protect player welfare.

Please note that certain rights may be subject to limitations where 22wind is required to retain or process data to comply with a legal obligation or to establish, exercise, or defend legal claims.

9 Data Security Measures

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and 22wind servers.
• Encrypted storage of sensitive account and financial data at rest.
• Role-based access controls ensuring that 22wind personnel can access only the personal data necessary for their specific job function.
• Regular security audits and vulnerability assessments of the 22wind platform infrastructure.
• Two-factor authentication options available to all registered players to protect account access.
• Secure data disposal procedures for data that has reached the end of its retention period.

While 22wind applies industry-standard security practices, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights, 22wind will notify affected players as promptly as reasonably practicable.

You are also responsible for the security of your own account. Use a strong, unique password for your 22wind account and do not share your login credentials with anyone. 22wind support staff will never ask for your password.

10 Children and Age Verification

22wind is strictly a 21+ platform. We do not knowingly collect personal data from individuals under the age of 21. During registration, all players are required to confirm that they are aged 21 or above. Where 22wind has reasonable grounds to believe that a player may be under the age of 21, the account will be suspended pending age verification. If age verification confirms that the player is under 21, the account will be permanently closed, all bets will be voided, and any deposited funds will be returned to the originating payment method.

If you believe that a minor may have registered on 22wind using false information, please contact us immediately at [email protected].

11 International Data Transfers

As an offshore platform, 22wind may store and process your personal data on servers located outside Bangladesh. Where personal data is transferred internationally, 22wind takes steps to ensure that equivalent protections apply, including the use of contractual data processing agreements with all third-party service providers who handle personal data on our behalf. By using the 22wind platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Bangladesh.

12 Changes to This Privacy Policy

22wind may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform features. When material changes are made, registered players will be notified via a notice displayed upon login or via the contact details associated with their account. The updated policy will be identified by a revised effective date at the top of this page.

We encourage all players to review this Privacy Policy periodically. Your continued use of the 22wind platform after the effective date of any update constitutes your acceptance of the revised policy. The current version is always available at 22wind.vip/privacy-policy.

13 Contact and Complaints

For any privacy-related queries, data subject requests, or complaints about how 22wind handles your personal data, please contact our support team:

• Email: [email protected]
• Response time: Within 5 business days for general queries; within 30 calendar days for formal data subject requests.
• Languages accepted: English.

If you are not satisfied with 22wind's response to your privacy complaint, you may have the right to escalate the matter to a relevant data protection authority or supervisory body in your jurisdiction. 22wind will cooperate fully with any such authority in the resolution of a complaint.