Privacy Policy

This Privacy Policy (the "Policy") sets out how 92pkr9 (the "Platform", "we", "us" or "our"), operating at https://92pkr9.cam, collects, uses, discloses, stores and protects personal data relating to individuals who access or use the 92pkr9 website and its associated services (collectively, the "Services").

By registering an Account, depositing funds, placing wagers or otherwise using the Services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with the terms of this Policy, you must not use the Services.

This Policy applies to all users of the Platform, including visitors, registered users and former users whose data is retained in accordance with our Retention Policy (see Section 9). This Policy should be read alongside our Terms & Conditions.

For the purposes of this Policy, the following terms have the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, CNIC number, email address, phone number, IP address, device identifiers and financial information.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For the Services, the Data Controller is 92pkr9.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller, such as a payment service provider or KYC verification vendor.
• "KYC Data" — identity verification documents and associated information submitted by a user for the purpose of satisfying Know Your Customer requirements, including CNIC scans, passport copies, selfies and proof-of-address documents.
• "Cookies" — small text files placed on a user's device by a web server for the purpose of tracking session state, preferences and analytics.
• "Special Category Data" — categories of data that warrant enhanced protection under internationally recognised frameworks, including data revealing racial or ethnic origin, health, biometric or genetic information.

92pkr9 collects the following categories of personal data from or about you:

We do not intentionally collect Special Category Data (such as health, biometric or genetic data) beyond what is incidentally present in KYC document submissions (e.g., a photograph). Where a selfie or liveness check is required for KYC, this is processed solely for identity verification purposes and is not used for any other profiling or identification function.

We collect personal data through the following channels:

• Direct submission: Information you provide when registering an Account, completing KYC verification, making a deposit or withdrawal, contacting customer support or responding to promotions;
• Automated collection: Technical and usage data collected automatically when you access the Site, including via cookies, web beacons, server logs and similar tracking technologies;
• Third-party sources: Identity verification data returned by KYC and AML service providers following document submission; fraud-detection signals from payment processors; geolocation data from IP-address resolution services;
• Payment processors: Transaction reference data and confirmation signals from payment intermediaries, including those facilitating transfers through channels familiar to Pakistani users. Such references are informational only and do not imply those providers endorse the Platform.

92pkr9 processes personal data on one or more of the following legal bases, consistent with internationally recognised data protection principles:

• Contractual necessity: Processing required to perform the contract between you and 92pkr9 — including account creation, payment processing, game delivery and customer support;
• Legal obligation: Processing required to comply with applicable law, including AML obligations, KYC requirements and operator licence conditions;
• Legitimate interests: Processing carried out in pursuit of 92pkr9's legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring and service improvement, provided such interests are not overridden by your rights and freedoms;
• Consent: Processing based on your freely given, specific and informed consent, such as marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

92pkr9 processes your personal data for the following specific purposes:

1. Account registration and management — creating, maintaining and administering your Account, including password resets and preference management;
2. Identity and age verification (KYC) — confirming your identity, verifying that you meet the minimum age requirement (18+, or the higher minimum required by the operator/licence jurisdiction) and satisfying AML obligations;
3. Payment processing — facilitating deposits and withdrawals in PKR or other accepted currencies, verifying payment instruments and preventing fraudulent transactions;
4. Responsible gambling monitoring — tracking usage patterns to identify potential problem gambling behaviour, enforcing deposit and loss limits, and administering self-exclusion;
5. Customer support — responding to enquiries, resolving disputes and improving service quality;
6. Security and fraud prevention — detecting, investigating and preventing fraudulent, abusive or illegal activity;
7. Legal and regulatory compliance — meeting our obligations under the operator licence, AML frameworks and any other applicable regulatory requirements;
8. Platform improvement and analytics — analysing aggregated and anonymised usage data to enhance platform performance, user experience and game offerings;
9. Marketing communications — where you have provided consent, sending promotional materials, bonus notifications and platform updates. You may opt out at any time.

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis.

92pkr9 does not sell your personal data. We may share your data with the following categories of recipients strictly on a need-to-know basis and subject to appropriate data-processing agreements:

• KYC and identity verification providers — third-party services that assist with document verification, age verification and liveness checks;
• Payment processors and financial intermediaries — entities involved in processing deposits and withdrawals, including payment gateway operators. References to services familiar to Pakistani users (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are contextual only and do not imply those providers endorse or support gambling;
• Fraud prevention and AML service providers — platforms that assist with transaction monitoring, suspicious-activity detection and compliance reporting;
• Technology and infrastructure providers — cloud hosting, content delivery and software vendors who process data as Data Processors under strict contractual terms;
• Regulatory and law enforcement authorities — where required by applicable law, court order or regulatory instruction, or where disclosure is reasonably necessary to protect the safety or rights of 92pkr9 or third parties;
• Professional advisers — legal counsel, auditors and compliance consultants, subject to professional confidentiality obligations.

92pkr9 operates internationally and may transfer personal data to countries outside Pakistan. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place, consistent with internationally recognised data protection standards, including:

• Binding contractual clauses or data processing agreements with recipient entities;
• Transfers to jurisdictions that the Platform's operating authority has deemed to provide an adequate level of data protection;
• Where required, obtaining explicit consent to international transfer from affected data subjects.

By using the Services, you acknowledge that your data may be processed on servers located outside Pakistan. If you require further information about the safeguards applicable to any specific international transfer, contact us at [email protected].

92pkr9 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that renders it impossible to re-identify the data subject.

92pkr9 uses cookies and similar technologies (including web beacons and local storage) to operate the Platform, maintain user sessions, remember preferences and gather analytics data. The following cookie categories are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without materially impairing your use of the Services.
• Functional cookies: Store user preferences such as language settings, display options and session context. Disabling these may reduce Platform functionality.
• Analytics cookies: Collect aggregated, anonymised data about how users interact with the Platform (pages visited, session duration, navigation paths) to help us improve performance. These do not identify individual users.
• Security cookies: Assist in detecting and preventing fraudulent activity, including cross-site request forgery (CSRF) tokens and device fingerprinting signals.

92pkr9 does not use cookies for the purpose of retargeting or cross-site behavioural advertising to third-party platforms.

92pkr9 implements technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration or destruction. These measures include, but are not limited to:

• TLS/SSL encryption for all data transmitted between your device and the Platform;
• Encrypted storage of sensitive data at rest, including KYC documents and payment records;
• Role-based access controls ensuring that Platform staff can only access personal data relevant to their specific function;
• Audit logging of access to sensitive data categories;
• Regular security assessments and penetration testing of Platform infrastructure;
• Multi-factor authentication requirements for administrative access to Platform systems.

Subject to applicable law and the conditions described in this Policy, you have the following rights in relation to your personal data held by 92pkr9:

To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request", your registered username and a description of your request. We will respond within 30 days. Where requests are complex or numerous, we may extend this period by an additional 30 days, with notice.

92pkr9 may need to verify your identity before fulfilling a data rights request to ensure that data is not disclosed to an unauthorised party. We will not charge a fee for reasonable requests.

KYC verification — which includes date-of-birth confirmation and identity document submission — serves as our primary mechanism for enforcing the minimum age requirement. This is one of the core reasons KYC completion is mandatory prior to withdrawal processing.

92pkr9 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or operational requirements. Material changes will be communicated to registered users via email notification or a prominent in-Platform notice at least 7 days before the changes take effect, unless immediate amendment is required by law or by urgent security considerations.

The "Last Updated" date at the top of this page is revised with each material amendment. Continued use of the Services after the effective date of any amendment constitutes acceptance of the updated Policy. If you do not accept the updated Policy, you must close your Account and cease using the Services before the effective date.

We encourage you to review this Policy periodically. Archived versions of prior policies are available upon request by contacting [email protected].

For any questions, concerns or requests relating to this Privacy Policy or to the personal data we hold about you, please contact 92pkr9 using the details below. All privacy-related correspondence must be in English. We aim to acknowledge all queries within 5 business days and to provide a substantive response within 30 days.

When submitting a data request by email, please include your registered username and a clear description of your query or request. Do not include your full password, OTP codes or CNIC number in the email body — these will never be requested by 92pkr9 in email correspondence.