Privacy Policy — 92fun Platform

This Privacy Policy ("Policy") is issued by 92fun ("Platform", "we", "us", "our") and governs the collection, processing, storage and disclosure of personal data relating to all individuals ("you", "your", "User") who visit, register on or otherwise interact with the website at https://92fun.cam and any associated services (collectively, the "Services").

92fun is committed to protecting your personal data and to operating in a manner consistent with applicable data protection principles. We collect only the data necessary to provide our Services, we keep it secure, and we do not sell it to third parties.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, you must discontinue use of the Services immediately. This Policy should be read alongside our Terms & Conditions, which also govern your use of the Platform.

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

We collect personal data from you directly (when you register, use our Services, or contact us) and automatically (through cookies, log files and analytics tools). The categories of personal data we may collect include:

We collect personal data through the following means:

• Direct Submission: Information you provide when completing the registration form, submitting KYC documents, contacting customer support, filling in preference settings, or communicating with us by email.
• Automated Technologies: Technical and behavioural data collected automatically as you interact with the Platform, including through cookies, web beacons, server log files and similar tracking technologies.
• Third-Party Verification Providers: Identity and address verification data returned to us by KYC and anti-fraud service providers when they process documents you submit to us.
• Payment Service References: Transaction metadata provided by payment processing intermediaries when you initiate deposits or withdrawals. Note that payment method names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced here as familiar Pakistani payment infrastructure context only and do not imply those providers share customer data with 92fun beyond what is necessary to process a specific transaction.
• Publicly Available Sources: In limited circumstances, we may verify information against publicly available records as part of compliance or anti-fraud checks.

We process your personal data for the following purposes:

1. Account Creation and Management: To register your account, verify your identity, maintain your account settings and manage your ongoing relationship with the Platform.
2. Service Delivery: To enable you to place bets, play casino games, access promotions, manage deposits and withdrawals, and use all features of the Platform.
3. Identity Verification (KYC): To comply with anti-money laundering (AML), counter-financing of terrorism (CFT) and know-your-customer obligations as required by the operator's applicable license jurisdiction.
4. Fraud Prevention and Security: To detect, investigate and prevent fraudulent transactions, account manipulation, money laundering, match fixing and other prohibited activities.
5. Responsible Gambling: To monitor betting patterns for indicators of problem gambling, to implement and enforce player-set limits and self-exclusion requests, and to provide responsible gambling information and interventions where appropriate.
6. Customer Support: To respond to your enquiries, resolve disputes, and maintain records of support interactions for quality assurance and training purposes.
7. Marketing Communications: To send you promotional materials, personalised offers and platform updates where you have consented to receive such communications. You may opt out at any time.
8. Platform Improvement: To analyse usage patterns, conduct A/B testing, identify technical issues and improve the functionality and user experience of the Platform.
9. Legal and Regulatory Compliance: To comply with applicable laws, regulations, court orders and lawful requests from competent authorities.

Where applicable data protection law requires a lawful basis for processing personal data, we rely on the following bases depending on the purpose of processing:

• Contractual Necessity: Processing necessary to perform the contract between you and 92fun — including account registration, service delivery, deposits and withdrawals.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including AML/KYC obligations and cooperation with competent authorities.
• Legitimate Interests: Processing for our legitimate business interests, such as fraud prevention, platform security, responsible gambling monitoring and platform analytics, where those interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where we have obtained your prior consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

92fun does not sell your personal data to third parties. We may share your data in the following limited circumstances:

• Service Providers (Data Processors): We engage trusted third-party service providers to assist in operating the Platform. These include KYC and identity verification providers, payment processing intermediaries, fraud detection services, IT hosting and infrastructure providers, and customer support platform vendors. All processors are bound by data processing agreements requiring them to handle your data securely and only for the purposes specified by 92fun.
• Regulatory and Law Enforcement Authorities: We may disclose personal data to competent authorities, regulators, law enforcement agencies or courts where required by applicable law, legal process, or to protect the rights, property or safety of 92fun, its users or the public.
• Responsible Gambling Schemes: Where required by license conditions, we may share limited data with recognised responsible gambling self-exclusion registries to enforce self-exclusion requests across participating operators.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of the 92fun business, personal data held by the Platform may be transferred to the acquiring entity, subject to equivalent data protection commitments.
• With Your Consent: We may share your data with other third parties where you have given explicit prior consent to such sharing.

We do not transfer your personal data to any third party for their own independent marketing purposes without your explicit consent.

The 92fun Platform uses cookies and similar tracking technologies to operate certain essential functions, to understand how you interact with the Platform, and to deliver a personalised experience. The types of cookies we use are as follows:

You can control non-essential cookies through your browser settings or the cookie preference centre on the Platform. Disabling certain cookies may affect the functionality of some features. For full details, please refer to the cookie settings available within your account.

We retain personal data only for as long as is necessary for the purposes set out in this Policy, or as required by applicable law and regulatory obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of your account's active status plus any mandatory post-closure retention period required by applicable AML, KYC or gambling regulations (typically five to seven years following account closure, depending on the applicable jurisdiction).
• Transaction Records: Financial transaction records, including deposits, withdrawals and betting history, are retained for a minimum of five years from the date of the transaction to satisfy applicable AML and financial record-keeping obligations.
• KYC Documentation: Identity and address verification documents are retained for the period required by the applicable regulatory framework, typically five years after the end of the customer relationship.
• Support Communications: Customer support records are retained for up to three years following the resolution of the relevant enquiry, for quality assurance and dispute resolution purposes.
• Marketing Data: Data held solely for marketing purposes is retained until you withdraw your consent or opt out of marketing communications, after which it is deleted within a reasonable administrative timeframe.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to any identifiable individual.

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

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform
• Encryption of sensitive data fields — including passwords (stored as hashed values) and financial account details — at rest
• Role-based access controls limiting Platform staff access to personal data on a strict need-to-know basis
• Regular security assessments, vulnerability scanning and penetration testing of Platform infrastructure
• Incident response procedures to detect, respond to and notify affected parties in the event of a data breach
• Contractual security requirements imposed on all third-party data processors who handle personal data on our behalf

Subject to applicable data protection law and any overriding legal obligations (such as mandatory retention requirements under AML regulations), you may have the following rights in respect of your personal data:

To exercise any of these rights, please contact our Data Protection contact at [email protected] with a description of your request. We will respond within a reasonable timeframe in accordance with applicable law. We may need to verify your identity before processing your request.

In order to provide the Services, 92fun may transfer your personal data to countries outside Pakistan and, depending on the operator's jurisdiction, outside the European Economic Area (EEA). Where such transfers occur, we take appropriate steps to ensure that your personal data receives an adequate level of protection.

These steps may include:

• Transferring data to countries recognised as providing an adequate level of data protection by the applicable supervisory authority
• Implementing contractual safeguards (such as standard contractual clauses) with third-party recipients of personal data
• Ensuring that data processors located in third countries are bound by contractual obligations requiring them to maintain appropriate security standards

If you require further information about the safeguards we apply to international data transfers, please contact us at [email protected].

92fun's Services are strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's applicable license jurisdiction. We do not knowingly collect personal data from persons below the applicable minimum age.

We implement age-verification procedures during the registration and KYC process to prevent underage access. If we discover that personal data has been collected from a minor, we will immediately close the relevant account and delete all associated personal data in accordance with applicable law.

If you are a parent or guardian and believe that your minor child has created an account on 92fun, please contact us immediately at [email protected] so that we can take appropriate action without delay.

The 92fun Platform may reference third-party services or contain contextual references to payment infrastructure familiar to Pakistani users. These references — including mentions of Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are provided for contextual familiarity only and do not constitute affiliation, endorsement or data-sharing arrangements with those providers beyond what is strictly necessary to process a specific transaction instruction.

If you interact with third-party websites, apps or services that are not operated by 92fun, this Policy does not apply to those interactions. We have no control over the data practices of third-party services and encourage you to review their own privacy policies before providing any personal information.

92fun reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the structure of the Platform. When we make material changes, we will notify registered users by email (to the address on file) or by displaying a prominent notice on the Platform.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. Your continued use of the Services following any update constitutes your acknowledgment of the revised Policy. If you do not agree with the revised Policy, you must stop using the Services and request account closure.

We recommend reviewing this page periodically to stay informed about how we protect your personal data.

If you have any questions, concerns or complaints regarding this Privacy Policy or the way in which 92fun handles your personal data, please contact us using the details below. We aim to respond to all privacy-related enquiries within a reasonable timeframe.

If you are not satisfied with our response to your privacy enquiry, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. Users in Pakistan are advised to monitor applicable regulatory guidance from the relevant Pakistani authority as the local data protection framework continues to develop.