Privacy Policy — 92pkt

Welcome to 92pkt. This Privacy Policy ("Policy") describes how 92pkt ("the Company", "we", "us", "our") collects, processes, stores, and protects the personal data of individuals ("you", "your", "the Player") who register for, access, or use the 92pkt platform available at https://92pkt.bet, including all associated games, betting services, payment channels, promotional offers, and support facilities.

By creating a 92pkt account or continuing to use the platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should cease using the platform and contact our support team to request account closure.

This Policy should be read alongside the Terms & Conditions and the Responsible Gaming Policy, both of which form part of your overall agreement with 92pkt. Where those documents reference data handling practices, this Policy provides the authoritative detail.

2.1 Identity. For the purposes of applicable data protection law, 92pkt is the data controller responsible for your personal data collected through the platform. As data controller, 92pkt determines the purposes for which, and the means by which, your personal data is processed.

2.2 Contact. If you have any questions or concerns about how 92pkt handles your personal data, or if you wish to exercise any of your data subject rights as described in Section 11 of this Policy, you may contact our Data Protection team via the support channels listed in Section 15.

2.3 Scope. This Policy applies to all personal data collected through the 92pkt website, mobile platform, customer support interactions, and any other channel through which you communicate with or use the services of 92pkt. It applies regardless of whether you are a registered player, a prospective player who has not yet completed registration, or a former player whose account has been closed.

3.1 Registration Data. When you create a 92pkt account, we collect the information you provide during the registration process, which may include:

• Full legal name;
• Date of birth (to verify you are 21 years of age or older);
• Email address;
• Country of residence;
• Preferred currency and language settings;
• Username and encrypted password.

3.2 KYC Verification Data. As part of our Know Your Customer (KYC) obligations under applicable anti-money laundering regulations, we may collect and process:

• Government-issued photo identification (CNIC, passport, or driving licence);
• Proof of address documents (utility bills, bank statements);
• Proof of payment method ownership (screenshots of JazzCash, EasyPaisa, or bank account details with personal information visible);
• Selfie or video verification where required.

3.3 Financial Data. When you make deposits or request withdrawals, we collect transaction-related data including deposit and withdrawal amounts, payment method identifiers (masked wallet addresses, partial IBAN numbers), and transaction timestamps. We do not store full cryptocurrency private keys or complete bank account numbers on our servers.

3.4 Usage and Technical Data. We automatically collect certain technical data when you access the 92pkt platform, including:

• IP address and approximate geographic location;
• Device type, operating system, and browser version;
• Session duration, pages visited, and features used;
• Game history, wagering activity, and betting patterns;
• Login timestamps and access logs.

3.5 Communications Data. When you contact 92pkt support via live chat or email, we retain a record of the conversation, including the content of your messages and any attachments you provide, for the purposes of resolving your query and improving our support service.

3.6 Data Collected in Tabular Summary:

92pkt processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your 92pkt account, including authentication and password recovery;
• Age and identity verification: To confirm that you are 21 years of age or older and that your identity matches the information provided during registration;
• Payment processing: To process deposits and withdrawals via USDT, Bitcoin, JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and to maintain accurate transaction records;
• Regulatory compliance: To fulfil anti-money laundering (AML), counter-terrorism financing (CTF), and gaming licence obligations, including transaction monitoring and suspicious activity reporting;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, and other activities that may harm 92pkt or its players;
• Platform personalisation: To tailor the games, offers, and content you see on the 92pkt platform based on your preferences and activity history;
• Marketing communications: Where you have opted in, to send you promotional emails, bonus notifications, and platform updates. You may opt out at any time;
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling and to enforce any self-exclusion, deposit limit, or cooling-off period you have set;
• Customer support: To respond to your queries, resolve disputes, and improve the quality of our support services;
• Platform improvement: To analyse aggregated usage data to identify technical issues, improve features, and optimise the overall player experience.

5.1 92pkt processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between you and 92pkt, including account creation, payment processing, and game delivery;
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, gaming licence conditions, and tax reporting requirements;
• Legitimate interests: Processing carried out in the legitimate interests of 92pkt — such as fraud prevention, platform security, and service improvement — where those interests are not overridden by your privacy rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, primarily for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6.1 92pkt does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• KYC and identity verification providers: Third-party services that assist 92pkt in verifying player identities and screening against sanctions and politically exposed persons (PEP) lists;
• Payment processors and financial institutions: Including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency payment gateway providers, solely to process your financial transactions;
• Game content providers: Licensed game studios and live dealer platform providers who supply games to the 92pkt platform. These providers may receive session data necessary to deliver and audit game outcomes;
• IT and infrastructure providers: Cloud hosting, database management, and cybersecurity providers who process data on our behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: Where required by law, court order, or the conditions of 92pkt's gaming licence, we may disclose your data to competent regulatory or law enforcement bodies;
• Professional advisers: Legal, accounting, and auditing firms who are bound by professional confidentiality obligations.

6.2 All third parties with whom 92pkt shares personal data are required to implement appropriate technical and organisational security measures, and are contractually prohibited from using your data for any purpose beyond what 92pkt has specified.

7.1 92pkt operates as a global platform and your personal data may be transferred to, and processed in, countries outside your country of residence, including countries that may not have the same level of data protection laws as your own jurisdiction.

7.2 Where 92pkt transfers personal data internationally, we ensure that appropriate safeguards are in place, such as standard contractual clauses approved by relevant data protection authorities, binding corporate rules, or transfers to countries that have been deemed to provide an adequate level of data protection.

7.3 By using the 92pkt platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Pakistan, including jurisdictions in which 92pkt's servers or service providers are located, for the purposes described in this Policy.

8.1 92pkt retains your personal data for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by applicable law.

8.2 The following general retention periods apply:

• Account and registration data: Retained for the duration of your active account, plus a minimum of five (5) years after account closure, as required by standard AML regulatory frameworks;
• KYC and identity documents: Retained for a minimum of five (5) years from the date of last transaction, as required by AML and gaming regulations;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction;
• Game session and betting history: Retained for a minimum of three (3) years from the date of each session;
• Support communications: Retained for a minimum of two (2) years from the date of the last interaction;
• Marketing consent records: Retained until consent is withdrawn and for a period thereafter sufficient to demonstrate that consent was properly managed.

8.3 When personal data is no longer required, 92pkt will securely delete or anonymise it in accordance with applicable data protection standards. Anonymised aggregate data that can no longer identify any individual may be retained indefinitely for statistical and analytical purposes.

9.1 92pkt uses cookies and similar tracking technologies (such as web beacons and pixel tags) on the platform. These technologies help us deliver a functional, secure, and personalised experience.

9.2 The following categories of cookies are used on the 92pkt platform:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery (CSRF). These cookies cannot be disabled without breaking core platform functionality;
• Performance and analytics cookies: Used to collect aggregated information about how players use the platform, including which pages are visited most frequently and where errors occur. This data helps us improve the platform;
• Functionality cookies: Used to remember your preferences, such as preferred language, display settings, and last-visited game categories;
• Marketing cookies: Used only where you have consented, to deliver relevant promotional content and to measure the effectiveness of marketing campaigns.

9.3 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 92pkt platform. Detailed instructions for managing cookies are available in the help documentation of all major browsers.

10.1 92pkt takes the security of your personal data seriously. We have implemented a range of technical and organisational measures designed to protect your data against unauthorised access, accidental loss, alteration, disclosure, or destruction.

10.2 Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 92pkt servers;
• Password hashing using industry-standard cryptographic algorithms — we never store plain-text passwords;
• Firewall protection, intrusion detection systems, and regular penetration testing;
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis;
• Regular security audits and vulnerability assessments;
• Secure, encrypted storage for all KYC documents with restricted access.

10.3 Despite these measures, no internet-based platform can guarantee absolute security. In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, 92pkt will notify affected players and relevant authorities in accordance with applicable data breach notification requirements.

11.1 Subject to applicable data protection law and certain legal exceptions, you have the following rights with respect to your personal data held by 92pkt:

• Right of access: You have the right to request a copy of the personal data 92pkt holds about you, along with information about how it is being processed;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain details directly in your account settings;
• Right to erasure: In certain circumstances, you have the right to request that 92pkt delete your personal data. This right is subject to exceptions, including where we are required to retain data by law or for the establishment or defence of legal claims;
• Right to restriction of processing: You have the right to request that 92pkt restricts the processing of your personal data in certain circumstances, such as where you contest its accuracy or object to its processing;
• Right to data portability: Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format;
• Right to object: You have the right to object to processing of your personal data where it is based on 92pkt's legitimate interests, including profiling for direct marketing purposes;
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

11.2 To exercise any of the above rights, please contact 92pkt via the support channels listed in Section 15. We will respond to all valid requests within thirty (30) days. We may ask you to verify your identity before processing your request.

12.1 The 92pkt platform is strictly intended for adults aged 21 years and above. 92pkt does not knowingly collect, process, or retain personal data from individuals under 21 years of age.

12.2 If 92pkt becomes aware that personal data has been collected from an individual under the minimum age threshold, the relevant account will be immediately closed, any remaining balance will be returned to the depositing payment method, and all personal data associated with that account will be securely deleted.

12.3 If you are a parent or guardian and you believe that a minor in your care has registered on the 92pkt platform, please contact us immediately via the support channels in Section 15 so that we can take prompt action.

13.1 The 92pkt platform may contain links to third-party websites or services (for example, game providers or payment gateways). 92pkt is not responsible for the privacy practices or content of any third-party website or service, and this Policy does not apply to them.

13.2 We encourage you to review the privacy policies of any third-party sites or services you access via the 92pkt platform. 92pkt does not endorse and is not responsible for the content, products, or privacy practices of any third party.

14.1 92pkt reserves the right to amend, update, or replace this Privacy Policy at any time. Any changes will be published on this page with an updated effective date. Where changes are material, we will endeavour to notify registered players via their registered email address before the updated Policy takes effect.

14.2 Your continued use of the 92pkt platform following the publication of a revised Privacy Policy constitutes your acceptance of those changes. If you do not agree to the revised Policy, you should stop using the platform and contact support to request account closure.

14.3 We recommend reviewing this Policy periodically so that you remain informed about how 92pkt protects your personal data and handles any changes in our practices.

If you have any questions, concerns, or requests relating to this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 11, please contact the 92pkt Data Protection team through any of the following channels:

• Live Chat: Available 24/7 directly on the 92pkt platform — average response time under 2 minutes
• Support Email: [email protected] (plain text — not a clickable link)

When submitting a data rights request, please include your registered account username, a clear description of your request, and a copy of a valid identity document so that we can verify your identity before processing the request. 92pkt will acknowledge all data rights requests within five (5) business days and provide a full response within thirty (30) days.