92ab Privacy Policy — How We Handle Your Data

This Privacy Policy ("Policy") describes how the operator of the 92ab platform ("92ab", "Operator", "We", "Us") collects, processes, stores, and protects the personal data of users ("You", "User", "Player") who access the 92ab platform via 92ab.cam and any associated subdomains, mobile applications, or digital services provided under the 92ab brand.

92ab is committed to safeguarding the personal information of all its users, including those accessing the Platform from Pakistan and other jurisdictions. We recognise that privacy is a fundamental right and we take our obligations as a data processor seriously.

By registering an account on 92ab, visiting the Platform, or using any of our products and services, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with the practices described in this Policy, you must immediately discontinue your use of the Platform.

For the purposes of this Policy, the following terms carry the meanings assigned below:

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, email address, phone number, date of birth, financial details, and device identifiers.
• "Processing" — Any operation performed on Personal Data, whether or not by automated means, including collection, storage, use, disclosure, erasure, and destruction.
• "Data Controller" — The entity that determines the purposes and means of processing Personal Data. For this Platform, the Operator acts as Data Controller.
• "Data Processor" — A third party that processes Personal Data on behalf of the Data Controller under a contractual arrangement.
• "Consent" — Freely given, specific, informed, and unambiguous agreement by the User to the processing of their Personal Data for a stated purpose.
• "Cookie" — A small text file placed on a User's device by the Platform for identification, session management, analytics, or personalisation purposes.
• "KYC" — Know Your Customer verification procedures required to confirm a User's identity and comply with applicable regulatory requirements.
• "Platform" — The 92ab website, mobile application, and all associated digital services accessible via 92ab.cam.

92ab collects Personal Data through several channels. The categories of data we may collect are described below:

3.1 Data You Provide Directly

• Full legal name and date of birth
• Email address and phone number
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar)
• Government-issued identification documents (CNIC, passport) submitted during KYC verification
• Proof of address documents submitted during KYC
• Payment method details, including mobile wallet references (e.g., Easypaisa, JazzCash) and bank account information (e.g., HBL, UBL, Meezan Bank, Bank Alfalah), used solely for processing deposits and withdrawals
• Correspondence you send to our support team via live chat or email
• Preferences and settings you configure within your account

3.2 Data Collected Automatically

• IP address, device type, operating system, and browser type
• Session activity data, including pages visited, time spent, and features used
• Betting and gaming history, including stakes placed, game types, and outcomes
• Login timestamps and access patterns
• Cookie and tracking data as described in Section 9

3.3 Data from Third Parties

• Identity and fraud-prevention data from third-party KYC verification providers
• Payment verification data from payment processing partners
• Where permitted, publicly available information used for fraud detection

92ab processes your Personal Data only for specific, documented purposes. The table below summarises how we use your data:

92ab does not use your Personal Data for purposes other than those listed above without first informing you and, where required, obtaining your consent. We do not sell, rent, or commercially transfer your Personal Data to third parties for their own marketing purposes under any circumstances.

We process your Personal Data on one or more of the following legal grounds:

• Contractual Necessity: Processing required to provide the services described in our Terms & Conditions, including account management, payment processing, and customer support.
• Legal Obligation: Processing necessary to comply with applicable laws and regulatory requirements, including identity verification, anti-money laundering obligations, and responsible gambling compliance.
• Legitimate Interests: Processing for purposes that serve our genuine business interests — such as fraud prevention, platform security, and service improvement — provided those interests do not override your fundamental privacy rights.
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent — primarily for optional marketing communications. You may withdraw consent at any time by adjusting your account notification preferences or contacting our support team.

92ab shares your Personal Data only in limited, controlled circumstances. We do not sell your data. The categories of recipients with whom we may share your data are as follows:

• Payment Processors and Banking Partners: To facilitate deposits and withdrawals through the payment methods available in our cashier. These partners receive only the data necessary to process the specific transaction.
• KYC and Identity Verification Providers: Third-party services engaged to verify the identity documents you submit during account verification. These providers are bound by contractual data protection obligations.
• Fraud Prevention and Security Services: Specialised providers used to detect and prevent fraudulent activity, including multi-accounting, payment fraud, and account takeover attempts.
• Gaming Content and Technology Providers: Platform infrastructure and game providers may receive anonymised or pseudonymised session data necessary to deliver their services. They do not receive your identity documents or payment details.
• Legal and Regulatory Authorities: Where required by Applicable Law, court order, or regulatory directive, we may disclose Personal Data to competent authorities. We will inform you of any such disclosure unless legally prohibited from doing so.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of the Operator's business, your Personal Data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

92ab retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, or as required by Applicable Law, whichever is longer. The following general retention principles apply:

• Active Account Data: Retained for the duration of your active account relationship with 92ab, plus any applicable post-closure retention period required by law.
• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure, in line with standard anti-money laundering and financial record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years following the date of each transaction.
• Support Correspondence: Retained for a minimum of three (3) years following the closure of each support ticket or dispute.
• Marketing Consent Records: Retained for the duration of your marketing consent and for a reasonable period thereafter to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, your Personal Data will be securely deleted or anonymised in a manner that prevents reconstruction of your individual identity.

92ab implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL (Secure Sockets Layer) encryption for all data transmitted between your device and the Platform
• Encrypted storage of sensitive personal and financial data at rest
• Role-based access controls limiting internal access to Personal Data on a strict need-to-know basis
• Regular security assessments and vulnerability testing of Platform infrastructure
• Strict contractual data protection obligations imposed on all third-party processors and service providers
• Internal data breach response procedures with defined notification timelines

While we take every reasonable step to protect your data, no electronic transmission over the internet is entirely secure. You acknowledge that you transmit information to the Platform at your own risk. You are responsible for maintaining the security of your account credentials and should notify 92ab support immediately if you suspect any unauthorised access to your account.

The 92ab Platform uses cookies and similar tracking technologies to operate core platform functionality, analyse user behaviour, and improve the overall experience. The categories of cookies we use are as follows:

You can manage your cookie preferences through your browser settings. Most modern browsers allow you to refuse or delete cookies. Note that disabling strictly necessary cookies will impair core Platform functionality, including account login and payment processing. For detailed instructions on managing cookies, refer to your browser's help documentation.

Subject to Applicable Law and the Operator's licence jurisdiction requirements, you may hold one or more of the following rights in respect of your Personal Data. To exercise any of these rights, contact our support team through the channels listed in Section 15.

• Right of Access: You may request a copy of the Personal Data we hold about you and information about how it is processed.
• Right to Rectification: You may request correction of any Personal Data we hold that is inaccurate or incomplete.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to Restriction of Processing: You may request that we restrict the processing of your Personal Data in certain defined circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: Where technically feasible and legally required, you may request your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your Personal Data carried out on the basis of legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

The 92ab Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable jurisdiction or the Operator's licence conditions. We do not knowingly collect, process, or store Personal Data relating to minors.

As part of our registration and KYC process, we take reasonable steps to verify the age of all users before granting access to real-money gambling features. Where we discover that a minor has accessed the Platform or provided Personal Data, we will immediately close the associated account, void any transactions, and delete the minor's data as promptly as technically possible.

If you are a parent or legal guardian and believe that your child has registered an account or submitted Personal Data to 92ab, please contact our support team immediately at the details provided in Section 15.

Given the global nature of online platform operations, your Personal Data may be transferred to and processed in countries outside your country of residence — including countries that may not offer the same level of data protection as your home jurisdiction.

Where such international transfers are necessary, 92ab ensures that appropriate safeguards are in place to protect your data, including:

• Contractual data protection clauses with receiving entities that impose equivalent data protection standards
• Transfer only to jurisdictions recognised as providing adequate data protection by the relevant regulatory authority
• Encryption of data in transit and at rest during international transfers

By using the 92ab Platform, you acknowledge that your Personal Data may be transferred internationally as described in this section.

The 92ab Platform may contain references or contextual mentions of third-party services, including payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, and Bank Alfalah. These are referenced as familiar local payment options for Pakistani users and their appearance on the Platform does not constitute a partnership, endorsement, or data-sharing arrangement beyond what is strictly necessary to process your transactions.

Each third-party service provider operates under its own independent privacy policy. 92ab is not responsible for the privacy practices, data collection, or security standards of any third party. We encourage you to review the privacy policies of any third-party service you interact with in connection with Platform use.

The 92ab Platform does not contain links to external websites. All navigation remains within the 92ab domain.

92ab reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or Platform functionality. Changes will be effective upon publication on the Platform, evidenced by a revised "Last Updated" date at the top of this document.

For material changes that significantly affect how we process your Personal Data, we will endeavour to notify registered Users via the email address associated with their account and/or via a notice displayed upon login, providing reasonable advance notice before the changes take effect.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you disagree with any changes, you must discontinue your use of the Platform and may request account closure as described in Section 15.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your Personal Data, you may contact the 92ab data team through the following channels:

• Live Chat: Available 24/7 directly on the Platform. This is the recommended channel for prompt responses to account-related privacy queries.
• Email: [email protected] — Please include "Privacy Request" in your subject line to ensure your enquiry is routed to the appropriate team.
• Support Language: English and Urdu. All formal data rights requests should be submitted in English where possible to avoid processing delays.

When submitting a data rights request, please provide your registered email address and a clear description of your request. We may ask for additional verification to confirm your identity before processing the request, consistent with our obligation to protect your data from unauthorised access by third parties.