99abai Privacy Policy

99abai ("the Company," "we," "us," "our") operates the online casino and sportsbook platform available at https://99abai.app ("the Platform"). 99abai is the data controller responsible for the personal data of all registered players and visitors to the Platform.

This Privacy Policy applies to all personal data collected, processed, and stored by 99abai in connection with the operation of the Platform and the provision of gaming, betting, payment, and customer support services to players based in Pakistan and other jurisdictions where access to the Platform is permitted.

This Policy should be read alongside the 99abai Terms and Conditions and the Responsible Gaming Policy, both of which form part of the overall agreement between 99abai and its registered players.

99abai collects the following categories of personal data from players and Platform visitors. The specific data collected depends on the nature of your interaction with the Platform.

99abai collects personal data through the following channels:

• Direct interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or submit any form on the Platform, you provide data directly to us.
• Automated technical collection: When you visit the Platform, our servers automatically log technical data including your IP address, device identifiers, browser type, and session timing data. This collection is necessary for Platform security and fraud detection.
• Cookies and similar technologies: The Platform uses cookies and local storage to maintain your session, remember your preferences, and collect anonymised usage analytics. See Section 7 for full details of our cookie practices.
• Payment processors: When you make a deposit or withdrawal via JazzCash, EasyPaisa, bank transfer, or card payment, our payment processors share transaction confirmation data with us for reconciliation and fraud prevention purposes.
• Identity verification providers: During the KYC process, 99abai may use third-party identity verification services to validate the authenticity of documents submitted. These providers process your document data on our behalf under strict data processing agreements.

99abai uses personal data for the following purposes only:

• Account management: Creating, maintaining, and securing your 99abai account, including processing login requests, managing session security, and enabling account settings changes.
• Identity verification (KYC): Verifying your identity, age, and payment method ownership as required by our international gaming license obligations and anti-money laundering compliance requirements.
• Transaction processing: Processing deposits from JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and card providers; processing approved withdrawal requests; maintaining accurate transaction records.
• Fraud prevention and security: Detecting and preventing account takeovers, multi-accounting, bonus abuse, money laundering, and other forms of fraud. Technical and usage data is analysed by automated systems for anomaly detection.
• Customer support: Responding to your support enquiries via live chat and email; investigating complaints; processing responsible gaming requests including self-exclusion and deposit limit adjustments.
• Regulatory compliance: Maintaining records required by our international gaming license authority; complying with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations; responding to lawful requests from regulatory and law enforcement authorities.
• Responsible gaming: Monitoring betting and deposit patterns to identify indicators of problem gambling; proactively reaching out to players displaying concerning patterns; processing self-exclusion and cooling-off requests.
• Platform improvement: Analysing anonymised and aggregated usage data to improve Platform performance, game selection, and user experience. This analysis does not involve processing individually identifiable data.
• Promotional communications: Where you have opted in to marketing communications at registration or via account settings, sending you information about promotions, new games, and offers relevant to your playing preferences. You may opt out at any time.

99abai processes personal data on the following legal bases depending on the purpose of processing:

• Contractual necessity: The majority of data processing described in Section 4 is necessary for the performance of the contract between you and 99abai — namely, the provision of gaming, betting, and payment services under the Terms and Conditions. Without this processing, we cannot provide the Platform services.
• Legal obligation: Identity verification (KYC), transaction record keeping, and AML/CTF monitoring are required by 99abai's international gaming license obligations. This data must be processed regardless of your individual preferences.
• Legitimate interests: Fraud detection, platform security monitoring, and anonymised analytics are processed on the basis of 99abai's legitimate interests in protecting the integrity of the Platform and its players. We have assessed that these interests are not overridden by player privacy rights given the protective nature of the processing.
• Consent: Marketing communications are sent only where you have provided explicit consent. You may withdraw this consent at any time by updating your communication preferences in account settings or by contacting support.

99abai does not sell your personal data to any third party under any circumstances. We share personal data only in the following limited circumstances and only to the extent strictly necessary:

• Payment processors: JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, Visa, and Mastercard processor partners receive the financial data necessary to process your deposits and withdrawals. These entities process data under their own privacy policies and applicable financial services regulations.
• Identity verification providers: Third-party KYC service providers receive document data during the verification process. All such providers are contractually bound to process data solely for verification purposes and to maintain equivalent security standards.
• Fraud detection and analytics partners: Anonymised technical and usage data may be shared with fraud detection service providers. These partners do not receive personally identifiable information — only tokenised or anonymised datasets.
• Regulatory and legal authorities: 99abai will disclose personal data to regulatory bodies, law enforcement agencies, or courts where required to do so by a valid legal obligation, court order, or licensing requirement. Where legally permitted, 99abai will notify you of such a disclosure.
• Business transfers: In the event that 99abai undergoes a merger, acquisition, or sale of all or part of its business assets, personal data held by the Platform may be transferred to the acquiring entity. Players will be notified of any such transfer and of any resulting changes to data processing arrangements.

99abai uses cookies and similar technologies on the Platform. Cookies are small text files stored on your device by your browser. They are used to maintain Platform functionality, remember your preferences, and collect usage data. The following cookie categories are used:

• Strictly necessary cookies: These cookies are required for the Platform to function. They maintain your authenticated session, remember your language preferences, and protect against cross-site request forgery. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: These cookies remember your game preferences, display settings, and other personalisation choices. Disabling them will not prevent you from using the Platform but will mean your preferences are not remembered between sessions.
• Analytics cookies: These cookies collect anonymised data about how players navigate and interact with the Platform. This data is used to improve Platform design and performance. Analytics cookies do not collect personally identifiable information.
• Security cookies: These cookies support our fraud detection systems by enabling detection of unusual session behaviour, concurrent session anomalies, and device fingerprinting inconsistencies.

You can manage cookie preferences through your browser settings. Please be aware that disabling certain categories of cookies may affect the functionality of the Platform. 99abai does not use third-party advertising cookies or cross-site tracking technologies.

99abai retains personal data for the periods set out below. Retention periods are determined by the purpose of processing and applicable legal and regulatory obligations:

• Active account data: Retained for the full duration of your account's active status on the Platform.
• Closed account data: Following account closure, identity and transaction data is retained for a minimum of 5 years to satisfy anti-money laundering record-keeping requirements under our international gaming license. This period may be extended where an investigation is pending.
• KYC verification documents: Retained for 5 years from the date of verification or from the date of account closure, whichever is later.
• Customer support communications: Retained for 3 years following the closure of the relevant support case.
• Technical and session logs: Retained for 12 months for security and fraud analysis purposes, after which they are deleted or fully anonymised.
• Marketing consent records: Retained until you withdraw your consent, plus 12 months thereafter to enable verification of historical consent status.

On expiry of the applicable retention period, personal data is securely and permanently deleted from all 99abai systems, or fully anonymised such that it can no longer be attributed to any individual. Anonymised data may be retained indefinitely for statistical and analytical purposes.

Subject to applicable legal exceptions, you hold the following rights over the personal data that 99abai processes about you:

• Right of access: You may request a copy of all personal data that 99abai holds about you. We will provide this in a structured, commonly used format within 30 days of receiving your verified request.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct it. Minor corrections (contact details, username preferences) can be made directly in your account settings; corrections to identity data require submission via support.
• Right to erasure ("right to be forgotten"): You may request deletion of your personal data where: (a) it is no longer necessary for the purpose for which it was collected; (b) you withdraw consent and there is no other legal basis for processing; or (c) the data has been processed unlawfully. This right is subject to legal retention obligations — data required for AML compliance cannot be deleted before its mandatory retention period expires.
• Right to restriction of processing: You may request that we restrict processing of your data while a dispute about its accuracy or the lawfulness of its processing is under review.
• Right to data portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request that your data be provided in a machine-readable format suitable for transfer to another provider.
• Right to object: You may object to processing carried out on the basis of legitimate interests. 99abai will cease processing unless we can demonstrate compelling legitimate grounds that override your interests. You may also object to marketing communications at any time, and this objection will be honoured unconditionally.

To exercise any of the above rights, submit your request to our support team at [email protected] or via live chat. We will respond within 30 days. Complex requests may require an extension of up to a further 60 days, in which case you will be notified within the initial 30-day period.

99abai maintains a comprehensive information security programme designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• Encryption in transit: All data transmitted between your device and the 99abai Platform is encrypted using TLS 1.3. Connections over unencrypted HTTP are automatically redirected to HTTPS.
• Encryption at rest: Personal data stored in 99abai databases is encrypted using AES-256 encryption. Encryption keys are managed separately from the data they protect.
• Access controls: Access to personal data within 99abai's internal systems is restricted on a strict need-to-know basis. Staff access is logged, monitored, and reviewed regularly. Former employees' access is revoked immediately upon departure.
• Two-factor authentication: 99abai offers two-factor authentication (2FA) for all player accounts. We strongly recommend all players enable 2FA via account settings. Internal staff systems require mandatory 2FA.
• Penetration testing: The Platform undergoes regular security assessments including vulnerability scanning and penetration testing. Critical vulnerabilities identified during testing are remediated on a priority basis before public disclosure.
• Incident response: 99abai maintains a documented data breach response procedure. In the event of a breach that affects your personal data, you will be notified without undue delay in accordance with applicable notification requirements.

Whilst 99abai takes all reasonable technical and organisational measures to protect your data, no system connected to the internet can be guaranteed to be entirely secure. You are responsible for maintaining the confidentiality of your account credentials. Do not share your 99abai password with any third party.

The 99abai Platform is strictly intended for adults aged 21 years and above. 99abai does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step of the registration and KYC process, and accounts where age verification cannot be completed are suspended pending verification.

If you believe that a person under the age of 21 has registered an account on the Platform, or that 99abai has inadvertently collected personal data relating to a minor, please contact us immediately at [email protected]. Upon receiving such a notification, 99abai will investigate promptly and, if confirmed, will permanently close the account and securely delete all associated personal data without delay.

99abai reserves the right to update or amend this Privacy Policy at any time. Changes may be required to reflect updates to Platform features, changes in applicable law or regulatory requirements, or improvements to our data handling practices.

Where changes are material — meaning they significantly affect the way we process your personal data or the rights you hold — 99abai will notify registered players via email and via a prominent notice on the Platform at least 14 days before the changes take effect. Continued use of the Platform after the effective date of updated Policy constitutes acceptance of the revised terms.

Where changes are non-material — for example, minor clarifications, corrected typographical errors, or formatting updates — the Policy will be updated without advance notice, and the "Last Reviewed" date at the top of this document will be updated accordingly.

We recommend that you review this Privacy Policy periodically to stay informed about how 99abai protects your personal data. The current version of this Policy is always available at https://99abai.app/privacy-policy.