Privacy Policy
How par99 Handles Your Data

This Privacy Policy (hereinafter "Policy") is issued by par99 ("par99", "we", "us", "our") and applies to all personal data collected, processed and stored in connection with your use of the par99 platform available at https://par99.cam ("Platform"), including any associated mobile applications, features, promotions or customer support services.

par99 is an English-language online betting and casino information platform serving adult users across Pakistan and other jurisdictions where access is lawful. We recognize that the privacy and security of your personal information is of fundamental importance, and we are committed to processing it lawfully, fairly and transparently in accordance with this Policy and applicable data protection legislation.

This Policy should be read alongside our Terms and Conditions, which are incorporated herein by reference. In the event of a conflict between this Policy and the Terms and Conditions regarding data privacy matters, this Policy shall prevail.

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

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, identification number, location data, email address, financial information and online identifiers.
• "Processing" — Any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" — The entity that determines the purposes and means of processing personal data. par99 acts as the Data Controller in respect of user data collected through the Platform.
• "Data Processor" — A third party that processes personal data on behalf of par99, under par99's instructions and in accordance with contractual data processing obligations.
• "Consent" — A freely given, specific, informed and unambiguous indication of the data subject's wishes by which they signify agreement to the processing of their personal data.
• "Data Subject" — The individual whose personal data is being processed — in the context of this Policy, the registered User of the par99 Platform.
• "KYC" — Know Your Customer — the identity and age verification process required to activate full Account functionality.

par99 is the Data Controller responsible for your personal data collected through this Platform. As Data Controller, par99 determines why your data is collected and how it is used. par99 operates the Platform under its applicable licensing jurisdiction and is responsible for compliance with data protection obligations under the laws of that jurisdiction.

par99 is not a Pakistani entity, is not licensed or regulated by any Pakistani authority, and does not claim to operate under Pakistan's data protection framework specifically. However, par99 voluntarily adopts internationally recognized data protection principles — including data minimization, purpose limitation and security by design — to protect the interests of all users including those accessing from Pakistan.

par99 collects personal data through the following channels and in the following categories:

When you use the Platform, par99 automatically collects certain technical and behavioral data, including:

• IP address and approximate geolocation (country/city level);
• Device type, operating system and browser version;
• Session duration, pages visited, betting and gaming activity patterns;
• Login timestamps and access logs;
• Cookie and tracking technology data as further described in Section 10.

par99 may receive personal data about you from third-party sources in limited circumstances, including: identity verification service providers (during KYC); fraud detection and anti-money laundering screening services; payment processors confirming transaction status; and analytics service providers aggregating anonymized usage data.

par99 processes your personal data only for the following specified, lawful purposes:

• Account Management: Creating, maintaining and managing your registered Account, including authentication and account security.
• KYC & Age Verification: Verifying your identity and confirming that you meet minimum age requirements and are not on applicable exclusion registers.
• Transaction Processing: Processing deposits, withdrawals, and maintaining accurate account balance records in PKR and other supported currencies.
• Fraud Prevention & AML: Detecting, investigating and preventing fraudulent activity, money laundering, terrorist financing and other unlawful acts.
• Legal & Regulatory Compliance: Meeting obligations under applicable licensing conditions, anti-money laundering legislation and responsible gambling requirements.
• Customer Support: Responding to inquiries, complaints, responsible gambling requests and account issues submitted via live chat or email.
• Service Improvement: Analyzing anonymized usage patterns to improve platform performance, UI/UX, and the quality of available markets and games.
• Responsible Gambling: Monitoring account activity to identify potential problem gambling behaviors and to deliver appropriate responsible gambling interventions where indicated.
• Direct Marketing: Sending promotional communications by email or other agreed channels — only where you have opted in and subject to your right to opt out at any time.

par99 relies on the following legal bases for processing personal data, consistent with internationally recognized data protection frameworks:

• Contractual Necessity: Processing required to fulfill the services described in the Terms and Conditions — including account creation, transaction processing and KYC — is necessary for the performance of the contract between you and par99.
• Legal Obligation: Certain processing activities — including identity verification, anti-money laundering checks and record keeping — are required to comply with applicable legal and regulatory obligations in par99's operating jurisdiction.
• Legitimate Interests: par99 processes certain data on the basis of its legitimate interests in preventing fraud, maintaining platform security and improving service quality, provided such processing does not override your fundamental rights and freedoms.
• Consent: Where processing is based on consent — for example, for direct marketing communications — you retain the right to withdraw consent at any time without affecting the lawfulness of prior processing.

par99 shares personal data with carefully selected third-party service providers who process data on our behalf as Data Processors, including: identity verification and KYC providers; payment processing partners; fraud detection and AML screening services; IT infrastructure and cloud hosting providers; customer support platform operators; and analytics service providers. All Data Processors are contractually bound to process personal data only in accordance with par99's instructions and applicable data protection obligations.

Pakistani users commonly use payment services including Easypaisa, JazzCash, Raast, and bank transfers via institutions such as HBL, UBL, Meezan Bank and Bank Alfalah. Where a user initiates a transaction through a payment channel, relevant transaction data may be shared with the corresponding payment processor as necessary to complete the transaction. This does not constitute an endorsement by these providers of par99 or of gambling activities. These payment providers are referenced as familiar payment infrastructure for Pakistani users only.

par99 may disclose personal data to competent authorities, law enforcement bodies or regulatory agencies where required to do so by applicable law, court order, or regulatory directive — or where par99 determines that such disclosure is necessary to prevent or investigate fraud, money laundering or other criminal activity.

par99 does not sell, rent, auction or otherwise transfer your personal data to third parties for their own independent marketing or commercial purposes under any circumstances.

par99 retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations.

• Active Accounts: Personal data is retained for the duration of the Account's active status and for a minimum period thereafter as required by applicable anti-money laundering and licensing regulations — typically five (5) years following account closure, in line with standard regulatory requirements in gambling license jurisdictions.
• KYC Documentation: Identity verification documents are retained for the period required by applicable AML legislation and licensing conditions, which typically ranges from five to seven years from the end of the business relationship.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years to support regulatory reporting, audit, and dispute resolution obligations.
• Support Communications: Customer support records are retained for a period necessary to resolve any related complaints or disputes, and for a reasonable period thereafter.
• Marketing Data: Where consent for marketing has been withdrawn, associated personal data used solely for that purpose is deleted within a reasonable period following the withdrawal of consent.

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

par99 implements a range of technical and organizational security measures designed to protect personal data against unauthorized access, accidental loss, destruction or disclosure. These measures include, but are not limited to:

• SSL/TLS encryption for all data transmissions between the user's device and the Platform;
• Encryption of sensitive data at rest using industry-standard algorithms;
• Role-based access controls limiting internal access to personal data to authorized personnel only;
• Two-factor authentication (2FA) available to all Users for account login;
• Intrusion detection systems and regular vulnerability assessments;
• Pseudonymization of data used for analytics and internal testing purposes;
• Staff training on data protection obligations and incident response procedures.

Cookies are small text files placed on your device when you visit a website. par99 uses cookies and similar tracking technologies — including local storage objects and session identifiers — to operate the Platform, remember your preferences, analyze usage patterns and deliver relevant content.

• Strictly Necessary Cookies: Essential for the Platform to function — session management, authentication, security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options and responsible gambling limits you have set.
• Analytics Cookies: Collect anonymized data on how users navigate the Platform to help us improve performance and content quality. No personally identifiable information is shared with analytics providers.
• Marketing Cookies: Where you have opted in, these cookies help deliver relevant promotional content aligned with your Platform activity. You may opt out at any time through your account settings.

You may configure your browser to block or delete cookies at any time. Please note that disabling strictly necessary cookies may impair the functionality of the Platform or prevent you from accessing certain features. For instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

Subject to applicable data protection law, you hold the following rights in respect of your personal data held by par99. You may exercise any of these rights by contacting us at [email protected]. We will acknowledge your request within a reasonable timeframe and respond substantively within thirty (30) calendar days of receipt, subject to any legally permitted extensions.

The par99 Platform is strictly restricted to adults aged 18 years or older — or the higher minimum age required by the operator's license jurisdiction. par99 does not knowingly collect, store or process personal data belonging to any individual under the applicable minimum age.

All registrations are subject to age verification as part of the KYC process. If par99 discovers or is notified that personal data belonging to a minor has been collected, that data will be deleted immediately and the associated Account will be closed without delay. Any winnings or bonuses associated with such an Account will be voided, and any deposits will be returned in accordance with applicable legal requirements.

As par99 operates internationally, your personal data may be transferred to, and stored on, servers located in countries other than Pakistan. This includes the jurisdiction in which par99 holds its operating license and the locations of third-party service providers used to operate the Platform.

Where personal data is transferred internationally, par99 takes appropriate steps to ensure that such transfers are protected by adequate safeguards — including contractual clauses binding Data Processors to equivalent data protection standards — to protect your data in transit and at the destination.

By using the Platform, you acknowledge and consent to such international transfers of your personal data as described in this Policy. If you have concerns about international data transfers, you may contact us using the details in Section 15.

par99 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our data processing activities, or the services offered through the Platform. Material changes to this Policy will be communicated to registered Users by email or through a prominent notification on the Platform at least fourteen (14) days before the changes take effect, except where immediate amendment is required by law or regulatory directive.

The "Last Updated" date displayed at the top of this Policy reflects the date of the most recent revision. Continued use of the Platform after the effective date of any amended Policy constitutes acceptance of the revised terms. We encourage you to review this Policy periodically.

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or have a concern about how par99 handles your personal data, please contact our support team using the details below. All privacy-related requests are handled in English.

When submitting a data subject rights request, please include sufficient information to enable us to verify your identity, including your registered email address and Account username. We will not process data subject rights requests that cannot be authenticated to a valid Account.