Privacy Policy — 99pak Data Commitment

99pak is an online casino and sports betting platform operating at 99pak.bet, serving primarily English-speaking users in Pakistan. 99pak operates under an international gaming licence and is committed to complying with applicable data protection principles governing the handling of personal data for its user base.

For the purposes of this Privacy Policy, 99pak acts as the data controller — meaning we determine the purposes and means by which your personal data is processed. Where we engage third-party service providers to process data on our behalf, those providers act as data processors and are bound by written data processing agreements that restrict their use of your data strictly to the services they provide to 99pak.

Questions about this policy or how your data is handled can be directed to 99pak's support team via live chat, available 24/7, or by email at [email protected] (plain text — not a clickable link).

99pak collects personal data through several distinct channels. The nature of data collected depends on your interaction with the platform:

Data You Provide Directly: When you create a 99pak account, you provide identity and contact information including your full name, date of birth, email address, and phone number. During KYC verification, you may be asked to submit a government-issued identification document such as a CNIC or passport. When making deposits or withdrawals, you provide financial account details relevant to your chosen payment method — JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, or a USDT wallet address.

Data Collected Automatically: When you access 99pak, our systems automatically collect technical data including your IP address, device identifiers, browser type, operating system version, and session activity timestamps. This data is used primarily for security monitoring, fraud prevention, and platform performance analysis. It is not used to build advertising profiles for third parties.

Data From Third Parties: In limited circumstances, 99pak may receive data about you from third parties — for example, identity verification data returned by our KYC service provider following a document check, or payment confirmation data returned by a payment gateway following a deposit transaction. In each case, the third party's own privacy policy governs their collection of your data, and 99pak processes only the data passed to us for the specific purpose of that verification or transaction.

99pak uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your 99pak account; processing login sessions; and enabling you to access the sportsbook, casino lobby, cashier, and responsible gaming tools.
• Identity & Age Verification: Conducting KYC checks to verify that you are 21 years of age or older and that your identity matches the details provided during registration. This is a regulatory obligation under 99pak's international gaming licence.
• Payment Processing: Facilitating deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT, and processing withdrawal requests to your registered payment method in PKR or USDT.
• Fraud Prevention & AML Compliance: Monitoring transaction patterns, login behaviour, and betting activity to detect and prevent fraud, money laundering, and abuse of promotional offers. This includes automated screening and, where flagged, manual review by our compliance team.
• Responsible Gaming: Monitoring your usage patterns to identify potential signs of problem gambling behaviour, and enabling responsible gaming tools — deposit limits, session timers, cooling-off periods, and self-exclusion — to function correctly on your account.
• Customer Support: Handling support requests submitted via live chat or email, maintaining records of support interactions for quality assurance, and resolving disputes related to your account or bets placed.
• Marketing Communications: Sending promotional offers, bonus notifications, PSL cricket betting specials, and platform updates — but only where you have provided explicit consent and only until you withdraw that consent.
• Platform Improvement: Aggregated, anonymised usage data is analysed to understand how members interact with the 99pak platform, which features are most used, and where improvements can be made. This analysis does not identify individual users.

99pak processes your personal data on the following legal grounds:

• Contractual Necessity: Processing your identity data, contact data, and financial data is necessary for 99pak to perform its obligations under the Member Agreement — operating your account, processing bets, and handling deposits and withdrawals.
• Legal Obligation: KYC verification, AML monitoring, and certain record-keeping requirements are mandatory under the obligations imposed by 99pak's international gaming licence. Processing your data for these purposes is a legal obligation 99pak cannot waive.
• Legitimate Interest: Security monitoring, fraud detection, platform analytics, and support quality management are processed on the basis of 99pak's legitimate interest in operating a safe, secure, and fair gaming platform. These interests are balanced against your privacy rights and do not override them.
• Consent: Marketing communications are sent only where you have given explicit, freely given, and informed consent. You may withdraw consent at any time by updating your preferences in account settings or by contacting support. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

99pak shares personal data with third parties only in the following defined circumstances:

• KYC & Identity Verification Providers: Your identity documents and personal details may be shared with licensed third-party KYC providers for document verification and database screening. These providers are contractually prohibited from using your data for any purpose beyond the verification service they provide to 99pak.
• Payment Gateway Providers: Transaction data is shared with payment processors — including mobile money operators and bank transfer facilitators — to the extent necessary to process your deposit or withdrawal. 99pak does not retain raw payment credentials after a transaction is complete.
• Game Software Providers: When you play a casino game supplied by a third-party provider within the 99pak lobby, a session token and necessary account data may be passed to that provider to enable gameplay. Game providers are licensed and operate under their own data processing obligations.
• Regulatory & Law Enforcement Authorities: 99pak may be legally required to disclose member data to regulatory bodies, law enforcement agencies, or courts of competent jurisdiction. Such disclosures are made only in response to valid legal requests and to the minimum extent required by law.
• Fraud Prevention Networks: In cases of suspected fraud, money laundering, or match-fixing, 99pak may share relevant data with industry fraud prevention networks and other licensed gaming operators as part of cross-operator due diligence programmes.

All third parties with whom 99pak shares personal data are required to maintain appropriate technical and organisational security measures and to process data only for the purposes for which it was shared.

99pak uses cookies and similar tracking technologies on its website. Cookies are small text files placed on your device that help the platform function correctly, remember your preferences, and analyse how the site is used.

The following categories of cookies are used by 99pak:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in, anti-fraud cookies that detect suspicious activity, and cookies that maintain your responsible gaming settings. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred deposit method, and odds format. These improve your experience but are not essential to platform operation.
• Analytics Cookies: Used to understand how members navigate the 99pak platform — which pages are visited, which games are opened, and where users typically exit. This data is aggregated and anonymised. 99pak uses analytics cookies only with your consent.
• Marketing Cookies: Used to deliver relevant promotional content within the 99pak platform based on your activity. 99pak does not place third-party advertising cookies for external advertising networks. Marketing cookies operate within the 99pak environment only.

99pak retains your personal data only for as long as is necessary for the purposes for which it was collected, subject to any longer retention periods required by law or regulatory obligation.

• Active Account Data: Identity, contact, and financial data is retained for the duration of your active membership with 99pak.
• Post-Closure Retention: Following account closure — whether voluntary or initiated by 99pak — we are required to retain KYC documentation, transaction records, and AML compliance data for a minimum period stipulated under our international gaming licence. This period is typically five to seven years from the date of account closure.
• Support Interactions: Live chat transcripts and email correspondence are retained for a period of three years to support dispute resolution and regulatory audit requirements.
• Marketing Data: Where you have consented to marketing, your preferences and campaign interaction history are retained until you withdraw consent, after which they are deleted or anonymised within 30 days.
• Technical & Log Data: Server logs, IP records, and session data are retained for a rolling 12-month period for security monitoring purposes, after which they are automatically purged.

When data is no longer required and no legal retention obligation applies, 99pak securely deletes or anonymises it using industry-standard data destruction methods.

99pak implements a layered approach to data security that reflects the sensitivity of the personal and financial data it handles on behalf of Pakistani members. Our technical and organisational security measures include:

• SSL/TLS Encryption: All data in transit between your browser or device and 99pak's servers is encrypted using TLS 1.2 or higher. The 99pak website operates exclusively over HTTPS.
• Access Controls: Personal data is accessible only to 99pak personnel with a demonstrated need to access it for their role. Access is managed via role-based permissions and logged for audit purposes.
• Payment Security: 99pak does not store raw payment credentials. Transactions via JazzCash, EasyPaisa, and bank transfers are processed through PCI-DSS compliant payment infrastructure operated by our payment partners.
• Intrusion Detection: 99pak's technical infrastructure includes real-time monitoring for unusual access patterns, automated alerts for potential security incidents, and a defined incident response procedure.
• Staff Training: 99pak personnel with access to personal data receive training on data protection obligations and the specific procedures applicable to their role.

You also play a role in keeping your account secure. Use a strong, unique password for your 99pak account and do not share your login credentials with anyone. 99pak will never ask for your password through live chat, email, or any other channel.

As a 99pak member, you have the following rights with respect to your personal data. To exercise any of these rights, contact 99pak's support team via live chat or at [email protected]. We will respond to all rights requests within 30 days.

• Right of Access: You may request a copy of the personal data 99pak holds about you, along with information about how it is being used.
• Right to Rectification: If any personal data held by 99pak is inaccurate or incomplete, you have the right to request that it be corrected. For identity data, correction may require submission of updated KYC documentation.
• Right to Erasure: Subject to legal retention obligations, you may request deletion of your personal data. Where a legal retention period applies — such as AML record-keeping — we will explain which data must be retained and for how long.
• Right to Restrict Processing: You may request that 99pak temporarily restrict processing of your data while the accuracy of the data or the legitimacy of the processing is being assessed.
• Right to Data Portability: You may request a structured, machine-readable copy of personal data you have provided to 99pak, to the extent technically feasible.
• Right to Object: You may object to processing carried out on the basis of legitimate interest, including profiling for responsible gaming monitoring, subject to 99pak's overriding regulatory obligations.
• Right to Withdraw Consent: Where processing is based on consent — specifically marketing communications — you may withdraw consent at any time without affecting your account access or the lawfulness of prior processing.

The 99pak platform is strictly an adults-only service. The minimum age to register and use 99pak is 21 years. 99pak does not knowingly collect personal data from individuals under the age of 21.

Where 99pak has reason to believe that a registered member is below the age of 21, the account will be suspended immediately. Any deposits made by an underage user will be refunded to the original payment method where possible, and all associated gameplay activity will be voided. KYC documentation confirming age will be required before any account suspension is lifted.

99pak strongly encourages parents and guardians in Pakistan to use parental control software to restrict minor access to online gaming platforms. Resources on parental control tools are available from major Pakistani internet service providers and device manufacturers.

99pak is an internationally licensed platform. Your personal data may be processed or stored on servers located outside Pakistan, including in the jurisdiction where 99pak's gaming licence is held and in the countries where our technology and KYC service providers operate.

Where personal data is transferred outside Pakistan, 99pak takes steps to ensure that an adequate level of protection is applied to that data, consistent with the principles set out in this Privacy Policy. These steps may include:

• Executing standard contractual clauses between 99pak and the receiving entity, requiring the recipient to apply data protection standards equivalent to those applicable to 99pak.
• Transferring data only to recipients in jurisdictions that maintain equivalent data protection frameworks under 99pak's licensing obligations.
• Applying additional technical safeguards such as encryption and access controls to data transferred to third-party processors.

By registering on 99pak and accepting this Privacy Policy, you acknowledge that your personal data may be transferred to and processed in countries outside Pakistan in accordance with the safeguards described in this section.

99pak reserves the right to update or amend this Privacy Policy at any time. Changes may be necessary to reflect updates to applicable law, regulatory guidance issued by licensing authorities, changes to our platform's features, or improvements to our data handling practices.

When a material change is made to this Privacy Policy, 99pak will notify registered members via the email address associated with their account and/or via a prominent notice displayed on the 99pak platform at next login. The updated policy will also be published at 99pak.bet/privacy-policy with a revised effective date shown at the top of the document.

Your continued use of the 99pak platform following notification of a material policy change constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should cease use of the platform and contact our support team to arrange account closure.

For any questions, clarifications, or concerns regarding this Privacy Policy or the manner in which 99pak handles your personal data, please reach out to our support team through live chat or at [email protected] — available 24 hours a day, 7 days a week.