2jbe Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 2jbe ("we", "us", "our"), the operator of the website at https://2jbe.cam, collects, uses, stores, shares and protects personal data in connection with your use of the 2jbe platform (the "Platform").

2jbe is an online gaming information and entertainment platform primarily serving Pakistani users and delivered in the English language. The Platform provides editorial content, guides and commentary relating to online sports betting, live casino products, slot game mechanics and responsible gambling. 2jbe does not directly operate gambling services, accept wagers or hold user funds.

By accessing or using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not consent, please discontinue use of the Platform immediately.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject").
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this case, 2jbe.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller under written instruction.
• "User" means any individual who accesses or interacts with the Platform.
• "Cookies" means small text files placed on a user's device by a website to store preference and session information.
• "Anonymised Data" means data from which all identifying information has been irreversibly removed such that the data subject can no longer be identified.

3 Data Controller

For the purposes of applicable data protection legislation, the Data Controller in respect of personal data processed through the 2jbe Platform is:

For all enquiries relating to data protection and this Privacy Policy, please contact us using the details provided in Section 16 of this Policy.

4 Categories of Data We Collect

4.1 Data You Provide Directly

Where the Platform includes interactive features such as contact forms or support enquiry mechanisms, we may collect the following data that you provide voluntarily:

• Name and email address (where submitted through a contact or enquiry form);
• Content of any message or enquiry submitted to us;
• Any other information you choose to provide in free-text fields.

4.2 Technical & Usage Data Collected Automatically

When you access the Platform, certain technical information is collected automatically by our servers and analytics tools:

• Device and browser data: device type, operating system, browser type and version, screen resolution;
• Network data: IP address, approximate geographic location derived from IP (country/city level only), internet service provider;
• Usage data: pages visited, time spent on each page, referral URL, navigation patterns, clicks and interactions;
• Session data: session identifiers, timestamps and session duration;
• Cookie data: data stored and retrieved via cookies and similar tracking technologies as described in Section 7.

4.3 Data We Do Not Collect

2jbe does not collect payment card details, bank account information, national identity numbers or any sensitive financial data. As an informational platform that does not process transactions, we have no basis or need to collect such information.

5 How We Collect Personal Data

Personal data is collected through the following mechanisms:

• Direct submission: when you voluntarily submit data through a contact form, enquiry form or any other interactive feature on the Platform;
• Automatic collection: via server logs, analytics software and cookies when you browse the Platform (see Section 7);
• Third-party analytics: we may use privacy-conscious analytics tools that process aggregated, anonymised usage data to help us understand how users interact with the Platform — without identifying individuals;
• Support correspondence: if you contact us by email, we will retain a record of that correspondence and any personal data contained within it for the purpose of responding to your query.

6 Purposes of Processing & Legal Basis

The table below sets out the purposes for which we process personal data and the corresponding lawful basis for each:

• Platform operation and content delivery: Delivering the Platform's informational content to you — Lawful basis: Legitimate interests (providing the service you have accessed).
• Security monitoring: Detecting and preventing fraud, abuse, unauthorised access and other malicious activity — Lawful basis: Legitimate interests (protecting the Platform and its users).
• Analytics and platform improvement: Understanding how users navigate the Platform to improve content, structure and user experience — Lawful basis: Legitimate interests (improving our service); anonymised where technically feasible.
• Responding to enquiries: Processing data submitted in contact forms to respond to your questions or requests — Lawful basis: Consent (you submitted the form) and/or Legitimate interests (responding to a service-related query).
• Legal compliance: Fulfilling obligations under applicable law, including data protection legislation — Lawful basis: Legal obligation.

7 Cookies & Tracking Technologies

2jbe uses cookies and similar technologies to operate certain platform features, analyse usage patterns and improve user experience. By continuing to use the Platform after being presented with a cookie notice, you consent to our use of cookies in accordance with this Policy.

7.1 Types of Cookies Used

• Essential cookies: Strictly necessary for the Platform to function. These cannot be disabled without impairing basic functionality (e.g., session management, security tokens).
• Analytics cookies: Used to collect aggregated, anonymised data about how visitors use the Platform — which pages are most visited, how long users stay, and where they navigate from. This helps us improve the Platform experience.
• Preference cookies: Store user preferences such as language settings or display configurations.

7.2 Managing Cookies

You can control and manage cookies through your browser settings. Most modern browsers allow you to block, delete or receive alerts before a cookie is stored. Please note that disabling certain categories of cookies may affect the functionality of parts of the Platform.

Instructions for managing cookies in major browsers are available in their respective help documentation. Disabling essential cookies may prevent you from accessing certain Platform features.

8 Data Sharing & Disclosure

2jbe does not sell, rent or otherwise transfer your personal data to third parties for commercial purposes. We may share personal data only in the following limited circumstances:

• Service providers and data processors: We engage trusted third-party service providers (such as hosting providers, analytics platforms and email delivery services) who process personal data on our behalf strictly in accordance with our written instructions and applicable data protection law. Such processors are contractually bound to maintain appropriate security standards.
• Legal obligations: We may disclose personal data where required to do so by applicable law, court order, governmental authority or regulatory requirement.
• Protection of rights: We may disclose personal data where necessary to protect the rights, property or safety of 2jbe, its users or the general public — for example, in connection with fraud prevention or security investigations.
• Business transfer: In the event of a merger, acquisition, restructuring or sale of assets, personal data may be transferred to the successor entity. We will provide notice of any such transfer and any resulting changes to this Policy.

We do not share personal data with gambling operators, payment processors or advertising networks for the purpose of targeting or profiling without explicit consent.

9 International Data Transfers

As an internet-based platform, data processed by 2jbe may be stored on or transferred to servers located outside of Pakistan. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place to protect your personal data, consistent with the requirements of applicable data protection legislation.

These safeguards may include:

• Transferring data only to countries that provide an adequate level of data protection;
• Using standard contractual clauses or equivalent mechanisms approved under applicable data protection frameworks;
• Applying additional technical and organisational measures where required.

By using the Platform, you acknowledge that your data may be processed in jurisdictions outside Pakistan, where data protection laws may differ from those in your country of residence.

10 Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable law. The following retention principles apply:

• Contact and enquiry data: Retained for a period sufficient to resolve your enquiry and maintain a reasonable record of correspondence, typically no longer than 24 months from last interaction, unless a longer period is required by law.
• Analytics data: Aggregated, anonymised analytics data may be retained indefinitely as it no longer constitutes personal data. Session-level identifiable data is retained only for the period necessary for the analytical purpose, then anonymised or deleted.
• Server log data: Typically retained for a limited operational period (e.g., up to 90 days) for security and technical purposes, after which logs are purged or anonymised.
• Legal compliance data: Data retained to meet legal obligations is kept for the period required by the relevant law or regulation.

When data is no longer required, it is securely deleted or anonymised using industry-standard methods.

11 Data Security

2jbe takes the security of your personal data seriously and implements appropriate technical and organisational measures to protect it against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your browser and the Platform;
• Restricted access controls — personal data is accessible only to authorised personnel who require it for their specific role;
• Regular review of our security practices and infrastructure;
• Use of reputable, security-audited hosting providers.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal data using commercially reasonable means, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will take appropriate steps in accordance with applicable law, which may include notifying affected users where required.

12 Your Data Rights

Subject to applicable law and reasonable identity verification, you may exercise the following rights in relation to personal data held by 2jbe:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data where there is no overriding lawful basis for continued retention.
• Right to Restriction of Processing: Request that we restrict processing of your personal data in certain defined circumstances.
• Right to Data Portability: Receive personal data you have provided to us in a structured, machine-readable format where technically feasible and where processing is based on consent or contract.
• Right to Object: Object to processing based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact us at the details provided in Section 16. We will respond to all legitimate requests within a reasonable timeframe, and in any event within the period prescribed by applicable law. We reserve the right to verify your identity before processing any data subject request.

13 Children's Privacy

The 2jbe Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect personal data from individuals under the age of 18.

If you are a parent or guardian and believe that your child has provided personal data to us, please contact us immediately at the address in Section 16 and we will take prompt steps to delete such data from our records.

Where we become aware that personal data has been collected from a person under the applicable minimum age, we will take immediate steps to delete that data and, where appropriate, to restrict that individual's access to the Platform.

14 Additional Notice for Pakistani Users

2jbe's primary audience consists of users based in Pakistan, including users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. The following additional context is provided for Pakistani users:

14.1 Applicable Law

Pakistan does not currently have a comprehensive federal personal data protection law equivalent to the EU's General Data Protection Regulation (GDPR). The Personal Data Protection Bill has been under consideration but, as of the effective date of this Policy, had not been enacted into law. 2jbe applies internationally recognised data protection principles as described in this Policy, regardless of the formal legal position in Pakistan.

14.2 Payment Method References

Where 2jbe content references familiar Pakistani payment services — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — these references are made solely for informational context. 2jbe does not process transactions through these services and does not receive or transmit financial data in connection with them. No personal financial data relating to these payment services is collected by 2jbe.

14.3 Gambling Legal Context

The legal status of online gambling in Pakistan is regulated by the Prevention of Gambling Act 1977, among other applicable provisions. 2jbe does not advise on the legality of gambling for Pakistani users. Users are responsible for ensuring their own compliance with applicable local, provincial and national laws before engaging with any gambling service referenced on or linked from this Platform.

15 Amendments to This Policy

2jbe reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law or platform functionality. When we make material changes, we will update the "Effective Date" at the top of this page.

Your continued use of the Platform following the publication of any revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed of how we handle your personal data.

Where changes are particularly significant, we may take additional steps to bring them to your attention, though we are under no obligation to provide individual notification of every update.

16 Contact Us

For any questions, concerns or requests regarding this Privacy Policy or the processing of your personal data, please contact the 2jbe data protection team using the following details:

We will acknowledge receipt of your request promptly and respond substantively within the timeframe required by applicable law. For data subject rights requests, we may need to verify your identity before processing the request, and we reserve the right to decline requests that are manifestly unfounded or excessive.

This Privacy Policy was last updated on 1 January 2026 and supersedes all previous versions. 2jbe reserves the right to amend this Policy at any time. Please check this page regularly for the most current version.