p99o Privacy Policy

01 Introduction

p99o ("we", "us", "our", "the Company") is committed to protecting the privacy and personal data of every individual who interacts with our platform. This Privacy Policy ("Policy") describes what personal information we collect from you, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have in relation to it.

This Policy applies to all data subjects whose personal data is processed by p99o, including registered account holders, individuals who browse the Platform without registering, and individuals who communicate with p99o's customer support team. It covers data collected through the p99o website at https://p99o.net, our live chat system, email correspondence, and any other channel through which p99o interacts with users.

p99o is an internationally licensed online gaming operator. As part of our licensing obligations, we are required to collect, verify, and retain certain categories of personal data. This Policy explains how we fulfil those obligations while simultaneously respecting your privacy to the fullest extent permitted by applicable law.

Please read this Policy carefully alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your relationship with p99o.

02 Data Controller

For the purposes of applicable data protection law, p99o is the data controller in respect of all personal data collected through the Platform. This means that p99o determines the purposes and means by which your personal data is processed.

If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact our designated data protection point of contact using the details set out in Section 15 of this Policy.

03 Data We Collect

p99o collects the following categories of personal data, depending on how you interact with the Platform:

p99o does not knowingly collect sensitive personal data beyond what is strictly necessary for identity verification and regulatory compliance. Specifically, we do not collect biometric data, health data, religious beliefs, or political opinions unless you voluntarily provide such information in a support communication, in which case it is used solely for resolving your query and is not retained beyond the resolution of that query.

04 How We Collect Data

p99o collects personal data through the following channels and mechanisms:

• Direct submission: Information you provide when you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, or respond to a survey or promotion.
• Automated technologies: When you access the Platform, our servers automatically log technical data including your IP address, device fingerprint, browser type, and session activity. This is standard practice across all major web services and is necessary for Platform security and fraud prevention.
• Cookies and similar technologies: p99o uses first-party cookies and session storage to maintain your login state, remember preferences, and analyse usage patterns. See Section 9 for full details on cookie usage.
• Payment processors: When you make a deposit or withdrawal via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, or USDT TRC20, the relevant payment processor shares transaction confirmation data with p99o for reconciliation purposes.
• Third-party identity verification services: p99o may use licensed KYC service providers to assist with document verification. These providers process your identity documents on our behalf and return a verification result — they do not retain your documents beyond the verification process.
• Gaming platform providers: Our game suppliers provide p99o with aggregated game session data, including round outcomes and RTP data, for account management and dispute resolution purposes.

05 How We Use Your Data

p99o uses your personal data exclusively for the following purposes:

• Account management: Creating, maintaining, and securing your p99o account; verifying your identity and age; enabling you to deposit, wager, and withdraw funds in PKR.
• Contract performance: Processing your bets and casino game participation; settling winnings; applying bonuses; managing your responsible gaming tool settings.
• Regulatory compliance: Meeting our obligations under our international gaming licence, including anti-money laundering (AML) checks, responsible gaming monitoring, and mandatory record-keeping.
• Fraud and security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, multi-accounting, and other prohibited conduct as defined in our Terms and Conditions.
• Customer support: Responding to your queries, complaints, and dispute submissions; maintaining records of communications for quality assurance purposes.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have consented to receive such communications. You may withdraw consent at any time through your account notification settings.
• Platform improvement: Analysing aggregated usage data to improve our product offering, user interface, and performance for players across Karachi, Lahore, Islamabad, Faisalabad, and other cities in Pakistan.
• Legal obligations: Complying with applicable law, court orders, regulatory requests, and law enforcement directives where legally required to do so.

06 Legal Basis for Processing

p99o processes your personal data on the following legal grounds, depending on the nature of the processing activity:

• Contractual necessity: Processing that is required to provide you with the p99o service you have contracted for, including account creation, transaction processing, and game participation.
• Legal obligation: Processing required to comply with our gaming licence conditions, AML regulations, age verification requirements, and other applicable legal obligations.
• Legitimate interests: Processing for fraud prevention, platform security, internal analytics, and network integrity, where our legitimate interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for marketing communications, non-essential cookies, and personalisation features, where your freely given, specific, and informed consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Data Sharing & Disclosure

p99o does not sell your personal data to third parties. We share your data only in the following limited circumstances and only to the extent necessary for the stated purpose:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 network processors receive only the data necessary to execute your requested financial transaction.
• KYC and identity verification providers: Licensed third-party KYC vendors process your identity documents on p99o's behalf under strict data processing agreements.
• Game software providers: Our casino and sportsbook technology partners receive session data necessary to deliver and settle games and bets. These providers are contractually prohibited from using your data for any purpose beyond service delivery.
• Regulatory and licensing authorities: p99o may be required to disclose player data to its gaming regulator, relevant financial intelligence units, or law enforcement agencies pursuant to our licensing obligations or applicable law. Such disclosures are made without prior notice to you where legally required.
• Professional advisers: Our legal counsel, auditors, and insurance providers may access limited personal data where strictly necessary for the provision of their professional services, under binding confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of p99o's business, your personal data may be transferred to the successor entity, subject to equivalent data protection commitments.

08 Data Retention

p99o retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by our licensing and regulatory obligations:

• Account and identity data: Retained for a minimum of five years from the date of account closure, in accordance with AML record-keeping requirements.
• Transaction and betting records: Retained for a minimum of five years from the date of each transaction.
• KYC verification documents: Retained for a minimum of five years from the date of account closure or the completion of the relevant verification check, whichever is later.
• Customer support communications: Retained for three years from the date of the last communication in each support interaction.
• Marketing consent records: Retained for the duration of the consent period and for two years following withdrawal of consent, to demonstrate compliance with consent obligations.
• Technical and usage logs: Retained for up to 12 months in identifiable form, after which they are aggregated and anonymised for analytics purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification. Where data is required to be retained beyond the standard period due to an ongoing legal dispute, regulatory investigation, or court order, it will be retained until the resolution of that matter.

09 Cookies & Tracking Technologies

p99o uses cookies and similar tracking technologies on the Platform to ensure functionality, improve user experience, and support security operations. The following categories of cookies are in use:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management, login state persistence, and security token validation. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences such as language settings and last-visited page. These cookies improve your experience but are not essential.
• Analytics cookies: Collect anonymised data about how users navigate the Platform, which pages are most visited, and where users encounter errors. This data is used to improve Platform performance and is not linked to your individual identity.
• Security cookies: Used to detect and prevent fraudulent activity, including bot traffic, credential stuffing, and multi-account abuse. These are strictly necessary for Platform integrity.

p99o does not use third-party advertising or retargeting cookies. Your browsing activity on p99o is not shared with advertising networks or social media platforms for targeting purposes.

You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to log in and use the Platform. Analytics and functional cookies may be disabled without affecting core functionality.

10 Security Measures

p99o implements a layered security architecture to protect your personal and financial data. Our technical and organisational measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and p99o servers;
• Encrypted storage of all sensitive personal data at rest, using industry-standard encryption protocols;
• Role-based access controls ensuring that p99o staff can only access personal data that is necessary for their specific job function;
• Two-factor authentication available for all player accounts, and mandatory for staff accounts with access to player data;
• Continuous monitoring for suspicious access patterns, unauthorised login attempts, and data exfiltration indicators;
• Regular third-party security audits and penetration testing of our Platform infrastructure;
• Secure disposal of physical documents containing personal data.

In the event of a data security incident that affects your personal data, p99o will notify affected users in accordance with the notification requirements of applicable law and our licensing obligations. We will take immediate steps to contain any breach, assess its impact, and implement remedial measures.

11 Your Rights

Subject to applicable data protection law and our regulatory obligations, you have the following rights in relation to your personal data held by p99o:

• Right of access: You may request a copy of the personal data p99o holds about you. We will respond to verified access requests within 30 days.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that it be corrected. Minor details such as contact information can be updated directly within your account settings.
• Right to erasure: You may request the deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected. Please note that we are unable to delete data that we are legally required to retain under our licensing, AML, or tax obligations.
• Right to restrict processing: You may request that we limit the processing of your personal data in certain circumstances, such as while a dispute regarding accuracy is being resolved.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format where processing is based on your consent or a contract.
• Right to withdraw consent: Where processing is based on your consent (such as for marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to object: You may object to processing based on legitimate interests where you believe your individual rights and freedoms override those interests.

To exercise any of these rights, please contact p99o support via live chat or by email at [email protected]. We may require you to verify your identity before processing your request. We will respond to all verified requests within 30 days. In complex cases, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reasons for it.

12 Children's Privacy

The p99o Platform is strictly intended for adults aged 21 years and above. p99o does not knowingly collect personal data from individuals under the age of 21. Our registration process includes age declaration and CNIC-based age verification to enforce this requirement.

If p99o becomes aware that it has inadvertently collected personal data from an individual under the age of 21, we will immediately suspend the relevant account, delete the collected data to the extent permitted by our regulatory obligations, and — where applicable — refund any deposits made by the underage individual.

If you believe that a minor has registered on the p99o Platform, please notify us immediately at [email protected] so that we can investigate and take appropriate action without delay.

13 International Data Transfers

p99o is an internationally operated platform. Your personal data may be transferred to, stored in, and processed in countries outside Pakistan, including the jurisdiction in which p99o holds its gaming licence and the jurisdictions in which our technology and payment partners operate.

Where personal data is transferred internationally, p99o ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy. These safeguards may include:

• Standard contractual clauses approved by relevant data protection authorities;
• Binding corporate rules applicable to our group companies;
• Transfers to jurisdictions that have been assessed as providing an adequate level of data protection.

If you would like further information about the specific safeguards applicable to any international transfer of your personal data, please contact us using the details in Section 15.

14 Changes to This Policy

p99o reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this page;
• Display a notice on the Platform informing users of the change;
• Where the change materially affects how we process your personal data, send a notification to your registered email address or mobile number.

Your continued use of the p99o Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. If you do not accept the revised Policy, you should close your account and cease using the Platform. Your right to request deletion of your data under Section 11 remains unaffected.

This Privacy Policy was last reviewed and updated on 1 January 2026. The current version supersedes all previous versions of the p99o Privacy Policy.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by p99o, please reach out through the following channels:

When submitting a data rights request, please include your registered email address or mobile number and a brief description of your request so that we can verify your identity and respond efficiently. p99o will never charge a fee for handling a data rights request unless a request is manifestly unfounded or excessive, in which case we will notify you before applying any charge.