92pn Privacy Policy

01 Who We Are

92pn is an internationally licensed online casino and sports betting platform operating at 92pn.app. The platform is built specifically for Pakistani players and supports PKR transactions through local payment methods including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank.

For the purposes of this Privacy Policy, 92pn acts as the data controller — meaning we determine the purposes and means by which your personal data is collected and processed. Our data protection contact is reachable at [email protected].

This Privacy Policy applies to all personal data collected through the 92pn website, any associated mobile-optimised interfaces, customer support channels, and promotional communications issued by 92pn.

02 Personal Data We Collect

Depending on how you interact with the 92pn platform, we may collect the following categories of personal data:

Category	Examples	When Collected
Identity Data	Full legal name, date of birth, CNIC number, gender	Registration & KYC verification
Contact Data	Email address, mobile number, residential address	Registration & account updates
Financial Data	Bank account details, JazzCash/EasyPaisa number, transaction history	Deposits & withdrawals
Gaming Data	Bet history, game sessions, wins and losses, bonus usage	Active platform use
Technical Data	IP address, device type, browser, operating system, session timestamps	Any platform visit
Communications Data	Support chat logs, email correspondence, complaint records	Customer support interactions

03 How We Collect Your Data

92pn collects personal data through several means, all of which are described below for full transparency:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or filling in any platform form.
• Automated technologies: Technical data collected automatically when you visit the 92pn platform, including cookies, server logs, and session tracking tools that record device information and browsing behaviour on our site.
• Third-party sources: Identity and fraud-check data received from licensed KYC verification providers, financial data received from payment processors such as JazzCash and EasyPaisa, and fraud-screening data from compliance tools used to satisfy AML obligations.
• Publicly available sources: In limited circumstances, 92pn may cross-reference publicly available information to verify identity details or investigate compliance concerns.

04 Why We Use Your Data

92pn uses your personal data for the following specific purposes. We do not use data for any purpose beyond what is listed here without first obtaining your consent or updating this policy:

• Account management: To create, maintain, and secure your 92pn account, including password resets, profile updates, and session management.
• Identity verification (KYC): To verify that you are who you claim to be, that you meet the minimum age requirement of 21 years, and that your account is not being used fraudulently.
• Payment processing: To process PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, debit card, and USDT, and to maintain accurate financial records as required by our licensing obligations.
• Regulatory compliance: To meet Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and responsible gaming obligations imposed by our international gaming licence.
• Customer support: To handle queries, complaints, and account disputes, and to maintain records of such interactions for quality assurance purposes.
• Responsible gaming monitoring: To identify patterns of play that may indicate problem gambling behaviour and to apply self-exclusion or account restriction tools as appropriate.
• Platform improvement: To analyse aggregate, anonymised usage data to improve game selection, platform performance, and user experience.
• Marketing communications (opt-in only): To send you promotional offers, bonus alerts, and platform updates where you have expressly opted in to receive such communications.
• Fraud prevention & security: To detect and prevent unauthorised account access, bonus abuse, payment fraud, and other platform security threats.

05 Legal Basis for Processing

92pn processes your personal data on the following legal bases, depending on the specific purpose of processing:

• Contractual necessity: Processing required to fulfil our obligations to you under the 92pn Terms & Conditions — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with KYC, AML, CTF, and responsible gaming obligations imposed by our gaming licence and applicable laws.
• Legitimate interests: Processing for fraud prevention, platform security, and aggregate analytics, where our legitimate business interests are not overridden by your privacy rights.
• Consent: Processing for optional marketing communications, where you have given explicit, informed consent. You may withdraw this consent at any time without affecting any other aspect of your account.

06 Data Sharing & Third Parties

92pn does not sell, rent, or trade your personal data. We share data only where strictly necessary, with the following categories of trusted third parties:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card processing partners receive the minimum financial data necessary to process your transactions.
• KYC & identity verification providers: Licensed third-party verification services that confirm identity documents and screen against international sanctions and PEP (Politically Exposed Persons) lists.
• Game content providers: Third-party casino game studios and live dealer providers that supply games available on the 92pn platform may receive anonymised session data for game performance purposes.
• Regulatory authorities: Our licensing authority and any law enforcement or financial intelligence body with lawful jurisdiction to request data disclosure.
• IT and hosting providers: Secure cloud infrastructure and server management providers who process data on our behalf under strict data processing agreements.

All third parties with whom 92pn shares personal data are contractually bound to process that data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable data protection requirements.

07 International Data Transfers

As an internationally licensed platform, 92pn may transfer personal data to servers or third-party processors located outside Pakistan. Where such transfers occur, 92pn ensures that appropriate safeguards are in place — including standard contractual clauses, data processing agreements, or transfers to jurisdictions that maintain adequate data protection standards under our licensing framework.

By registering an account with 92pn, you acknowledge that your personal data may be transferred, stored, and processed in countries outside Pakistan in connection with the delivery of our services.

08 Data Retention

92pn retains personal data for as long as is necessary to fulfil the purposes set out in this Privacy Policy, subject to the following minimum retention periods required by our licensing and regulatory obligations:

• Account data and KYC records: Retained for a minimum of 5 years from the date of account closure, as required by AML and gaming licence compliance obligations.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction.
• Customer support records: Retained for a minimum of 3 years from the date of each interaction.
• Marketing consent records: Retained for the duration of your consent and for a period of 2 years following withdrawal of consent.
• Technical and session data: Retained for up to 12 months, after which it is aggregated or anonymised for analytics purposes.

Following the expiry of the applicable retention period, 92pn will securely delete or anonymise personal data in accordance with our internal data destruction procedures.

09 Cookies & Tracking Technologies

92pn uses cookies and similar tracking technologies to deliver, maintain, and improve the platform experience. The following categories of cookies are used:

• Essential cookies: Strictly necessary for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences such as language settings, currency display, and game history to personalise your experience on the 92pn platform.
• Analytics cookies: Collect anonymised data about how users navigate the platform — such as pages visited, session duration, and device type — to help us improve platform performance and usability.
• Marketing cookies (opt-in): Used only where you have consented, to deliver relevant promotional content and to measure the effectiveness of promotional campaigns.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies will affect your ability to use core platform features including account login and payment processing.

10 Your Data Rights

Subject to applicable law and our regulatory retention obligations, you have the following rights in relation to your personal data held by 92pn:

• Right of access: You may request a copy of the personal data 92pn holds about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data held in your account.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to restrict processing: You may request that we limit the processing of your data in certain circumstances — for example, while a dispute about accuracy is being resolved.
• Right to data portability: You may request your personal data in a structured, commonly used, machine-readable format where processing is based on consent or contract.
• Right to object: You may object to processing based on legitimate interests, including profiling for marketing purposes.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without penalty to your account.

To exercise any of the above rights, please contact the 92pn data team at [email protected]. We will acknowledge your request within 5 working days and provide a full response within 30 calendar days. In complex cases, this period may be extended by a further 30 days, and you will be notified accordingly.

11 Children's Privacy

The 92pn platform is strictly for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been submitted by a person under 21 years of age, we will immediately close the relevant account, delete all associated personal data, and where appropriate, report the matter to our licensing authority.

Parents and guardians are strongly advised to make use of parental control software and internet filtering tools to prevent minors from accessing online gambling platforms. If you believe a minor has registered on the 92pn platform, please contact us immediately at [email protected].

12 Security Measures

92pn implements a layered approach to data security, combining technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption in transit: All data exchanged between your device and 92pn servers is encrypted using TLS (Transport Layer Security) protocols.
• Encryption at rest: Personal and financial data stored in 92pn's databases is encrypted using industry-standard encryption algorithms.
• Access controls: Access to personal data is restricted to authorised 92pn personnel on a strict need-to-know basis, with role-based access controls and audit logging in place.
• Two-factor authentication: Account holders are encouraged to enable two-factor authentication (2FA) to add an additional layer of security to their 92pn account.
• Incident response: 92pn maintains a data breach response procedure. In the event of a breach affecting your personal data, you will be notified without undue delay in accordance with our licensing obligations.

13 Third-Party Links

The 92pn platform may contain references to third-party services such as licensed game providers and payment processors. This Privacy Policy applies solely to data collected and processed by 92pn. Third-party services operate under their own privacy policies, and 92pn accepts no responsibility for the data practices of those parties.

You are encouraged to review the privacy policies of any third-party services you interact with in connection with your use of the 92pn platform.

14 Updates to This Policy

92pn reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or platform features. Where material changes are made, we will notify registered users via their registered email address at least seven days before the updated policy takes effect.

The effective date at the top of this page will always reflect the date of the most recent update. Continued use of the 92pn platform following an update to this Privacy Policy constitutes acceptance of the revised terms.

15 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or wish to raise a complaint about 92pn's data handling practices, please contact our team using the details below:

• Email: [email protected]
• Subject line: Please use "Privacy Request" or "Data Complaint" so your query is directed to the correct team member.
• Response time: Within 5 working days for acknowledgement; within 30 calendar days for a full response.
• Support hours: 24/7, Pakistan Standard Time.

If you are not satisfied with our response to a complaint, you have the right to escalate the matter to the relevant supervisory authority under our licensing jurisdiction.