Privacy Policy

1.Introduction

99r789 ("the Platform", "we", "us", "our") operates the online gaming information and services platform accessible at https://99r789.cam. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure and protection of personal data submitted by users ("you", "the User") in connection with your use of the Platform.

We take data privacy seriously. Our platform is designed to be English-language and primarily serves users based in Pakistan. While Pakistan does not yet have a comprehensive standalone data protection statute equivalent to international frameworks such as the EU General Data Protection Regulation (GDPR), we apply data minimisation, purpose limitation and security principles consistent with internationally recognised privacy standards.

This Privacy Policy should be read alongside our Terms & Conditions, which set out the broader contractual framework governing your use of 99r789.

2.Definitions

For the purposes of this Privacy Policy:

3.Data We Collect

99r789 collects personal data that you provide directly, data generated through your use of the Platform, and in some cases data received from third-party partners involved in payment processing, identity verification or fraud prevention. We collect only the data necessary for the stated purposes below.

3.1 Registration & Account Data

• Full legal name;
• Date of birth;
• Email address;
• Country and city of residence (e.g., Karachi, Lahore, Islamabad);
• Chosen username and encrypted password;
• Mobile number (where provided or required).

3.2 Identity Verification (KYC) Data

• Government-issued identity document — Pakistani CNIC or passport image;
• Proof of address document where applicable;
• Selfie or liveness check image submitted through the secure verification portal;
• Payment method confirmation details.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records (amounts, dates, method references);
• Payment method type (e.g., bank transfer reference — method names such as Easypaisa or JazzCash used for context only; we do not store full wallet credentials);
• Account balance history and wagering activity records.

3.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system and browser version;
• Session duration, pages visited and feature interaction logs;
• Cookie and tracking data (see Clause 8).

3.5 Communications Data

• Support ticket content and correspondence with customer service;
• Feedback, complaints and dispute-related communications.

4.How We Use Your Data

99r789 uses your personal data for the following purposes:

We do not use your personal data to make solely automated decisions that produce significant legal effects on you without the option of human review, except where permitted by applicable law.

5.Legal Basis for Processing

We process your personal data on the following legal bases, consistent with internationally recognised data protection principles:

• Contractual Necessity: Processing required to fulfil the contract with you — account creation, transaction processing and customer support.
• Legal Obligation: Processing required to comply with applicable law — KYC, AML, fraud prevention and regulatory reporting obligations.
• Legitimate Interests: Processing necessary for our legitimate business interests — platform security, fraud detection, analytics and service improvement — where these interests are not overridden by your rights.
• Consent: Where we rely on your consent — for example, for non-essential cookies or certain marketing communications — you may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6.Data Sharing & Disclosure

99r789 does not sell, rent or trade your personal data to third parties for their own marketing purposes. We may share personal data with third parties only in the following circumstances:

• Service Providers: Third-party data processors engaged to support Platform operations — including KYC verification providers, payment processing partners, fraud-prevention vendors and hosting infrastructure providers. All processors are bound by data processing agreements requiring confidentiality and security standards consistent with this policy.
• Legal & Regulatory Authorities: Where required by law, court order or regulatory demand — including disclosures required under anti-money laundering obligations. We will inform you of such disclosures where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets, personal data held by 99r789 may be transferred to the successor entity. You will be notified of any such transfer and the privacy terms applicable thereafter.
• With Your Consent: In circumstances not covered above, we will seek your explicit consent before sharing your personal data with any third party.

7.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 legal, regulatory or contractual obligations. The following general retention principles apply:

• Active Accounts: Personal data is retained for the duration of the account relationship and for a reasonable period thereafter to handle any disputes, chargebacks or regulatory inquiries.
• KYC Documents: Identity documents are retained in accordance with applicable AML regulations and the operator's licensing requirements — typically a minimum of five (5) years from the date of account closure or last transaction, whichever is later.
• Transaction Records: Financial transaction data is retained for a minimum period as required by applicable financial regulations — typically five (5) to seven (7) years.
• Support Communications: Customer support records are retained for a minimum of three (3) years from the date of the last communication, or longer if related to an unresolved dispute.
• Closed Accounts: Where an account is closed voluntarily, data is retained for the minimum legally required period before secure deletion or anonymisation is applied.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

8.Cookies & Tracking Technologies

The 99r789 Platform uses cookies and similar tracking technologies to operate core Platform functionality, improve user experience and conduct anonymised analytics. Cookies are small data files stored on your device.

8.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function — session authentication, security tokens and load balancing. These cannot be disabled without impacting core functionality.
• Functional Cookies: Remember your preferences — language settings, session duration preferences and interface personalisation.
• Analytics Cookies: Anonymised data on page visits, session duration and feature usage — used to improve Platform performance and content. No individual user is identifiable from this data.
• Security Cookies: Used for fraud detection, bot prevention and account security purposes.

8.2 Managing Cookies

You can control non-essential cookies through your browser settings or the Platform's cookie preference panel where available. Disabling certain cookies may affect Platform functionality. Your consent to non-essential cookies will be requested where required and can be withdrawn at any time.

9.Data Security

99r789 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and our servers;
• Encrypted storage of sensitive data including passwords (hashed and salted) and identity documents;
• Access controls limiting data access to authorised personnel only, on a need-to-know basis;
• Regular security assessments and vulnerability monitoring of Platform infrastructure;
• Two-factor authentication options for user accounts;
• Incident response procedures for data breach detection, containment and notification.

10.Your Data Rights

Subject to applicable law and the specific circumstances of your request, you have the following rights regarding your personal data held by 99r789:

• 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 longer a lawful basis for retention — subject to legal and regulatory retention obligations;
• Right to Restrict Processing: Request that we limit how we use your data in certain circumstances;
• Right to Data Portability: Where technically feasible and legally applicable, receive your personal data in a structured, commonly used format;
• Right to Object: Object to processing based on legitimate interests, including profiling;
• Right to Withdraw Consent: Withdraw consent for consent-based processing at any time without affecting prior lawful processing.

To exercise any of these rights, submit a request to our support team. We will respond within a reasonable timeframe and in accordance with applicable legal requirements. We may request proof of identity before processing your request to protect against unauthorised data access.

11.International Data Transfers

The 99r789 Platform may be operated from, or use service providers based in, jurisdictions outside Pakistan. As a result, your personal data may be transferred to and processed in countries that may have different data protection laws from those applicable in Pakistan.

Where such transfers occur, we implement appropriate safeguards to ensure your personal data continues to receive a level of protection consistent with this Privacy Policy, including contractual clauses with data processors requiring compliance with applicable data protection standards.

By using the Platform, you acknowledge and consent to the transfer of your data as described in this clause, subject to the safeguards described above.

12.Children's Privacy

The 99r789 Platform is strictly for adults aged 18 and above — or the higher minimum age required by the applicable operator/license jurisdiction. We do not knowingly collect personal data from any individual under the applicable minimum age.

If you believe that a minor has registered on the Platform or submitted personal data, please contact us immediately at the address in Clause 14. Upon verification, we will take steps to delete the relevant data and close the account without delay.

13.Policy Amendments

99r789 reserves the right to update this Privacy Policy at any time. The "Last Updated" date at the top of this page reflects the most recent revision. Where changes are material, we will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect.

Your continued use of the Platform after any update to this Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should discontinue use of the Platform and may contact us to request account closure.

14.Contact Us

For any questions, concerns or requests relating to this Privacy Policy or your personal data, please contact the 99r789 support team. All data-related requests should be clearly marked as such.

Support Email (plain text — not a link):
[email protected]

Support is available in English. Urdu assistance may be available as an additional option — check the support section of the Platform for current availability. We aim to acknowledge data-related requests within a reasonable timeframe and to resolve them in accordance with applicable requirements.