Privacy Policy — 92co

1 Introduction

This Privacy Policy ("Policy") sets out how 92co ("Platform", "we", "us", "our"), the operator of the website located at https://92co.cam, collects, uses, processes, stores, shares and protects personal data submitted by users ("User", "you", "your") in connection with your use of the Platform.

92co is committed to protecting your privacy and processing your personal data in a manner that is lawful, fair and transparent. This Policy is intended to inform you clearly about your rights and our obligations regarding the personal data we hold.

By registering an Account or otherwise using the 92co Platform, you confirm that you have read and understood this Policy. If you do not agree with any part of this Policy, you should not use the Platform or submit personal data through it.

This Policy should be read alongside our Terms & Conditions, which govern the broader relationship between 92co and its users. In the event of any conflict between this Policy and the Terms & Conditions with respect to the handling of personal data, this Policy shall prevail.

2 Definitions

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

3 Data Controller

The Data Controller responsible for the personal data processed in connection with the 92co Platform is the operating entity behind 92co, operating under its applicable operator licence. The contact details for data-related queries are set out in Section 15 of this Policy.

Where third-party service providers process personal data on our behalf — such as payment processing companies, identity verification providers and game-content suppliers — those providers act as Data Processors and are contractually bound to process personal data only in accordance with our documented instructions and in compliance with applicable data protection obligations.

4 Data We Collect

92co collects personal data through the following categories of interaction with the Platform:

4.1 Registration & Account Data

When you create an Account, we collect:

• Full legal name;
• Date of birth (for age verification purposes);
• Email address and/or mobile number;
• Residential address (city, region, country — including Pakistani users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and elsewhere);
• Username and encrypted password credentials.

4.2 Identity Verification (KYC) Data

To comply with anti-money laundering requirements and to verify your identity before withdrawals are processed, we may collect:

• Copy of a government-issued identity document (e.g., CNIC, passport);
• Proof of residential address (e.g., utility bill, bank statement);
• Source-of-funds documentation where applicable;
• Biometric data where required by the verification service provider, subject to separate consent.

4.3 Financial & Transaction Data

When you make deposits or withdrawals, we collect information about the transaction, including:

• Payment method type and reference details (e.g., mobile wallet identifier or bank account reference — 92co does not store full card or bank account numbers);
• Transaction amounts in PKR;
• Transaction timestamps and processing status.

References to payment methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are provided as contextual references only. The collection of transaction reference data is governed by the respective payment provider's terms and privacy policy, which operate independently of this Policy.

4.4 Usage & Behavioural Data

We collect information about how you interact with the Platform, including:

• Pages visited, features accessed and time spent on the Platform;
• Betting and gaming activity (markets viewed, bets placed, games played);
• Responsible gambling tool usage (deposit limits set, session durations);
• Device type, operating system, browser type and screen resolution.

4.5 Communications Data

If you contact our support team by email or live chat, we retain a record of your communications, including any personal data you include in the content of your messages.

4.6 Technical & Log Data

Our servers automatically collect certain technical information when you access the Platform, including:

This technical data is used for security monitoring, fraud prevention and aggregate platform analytics. It is not used for personalised profiling without appropriate legal basis.

5 How We Use Your Data

92co uses personal data collected from users for the following purposes:

6 Legal Basis for Processing

Where data protection law requires a legal basis for the processing of personal data, 92co relies on the following legal bases as applicable:

• Contractual necessity: Processing required to perform the contract between 92co and the user, including Account registration, payment processing and service delivery;
• Legal obligation: Processing required to comply with anti-money laundering obligations, identity verification requirements and other mandatory regulatory obligations;
• Legitimate interests: Processing for fraud prevention, security monitoring, responsible gambling monitoring and aggregate platform analytics, where such interests are not overridden by your fundamental rights;
• Consent: Processing for marketing communications and, where applicable, the use of non-essential cookies — consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Data Sharing

92co does not sell your personal data to third parties. We may share personal data with the following categories of recipients, solely to the extent necessary for the stated purpose:

7.1 Payment Service Providers

Transaction reference data is shared with payment processors to facilitate deposits and withdrawals. Payment providers process transaction data under their own privacy policies and are independently responsible for their data practices. The reference to providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah is contextual; actual sharing depends on the payment method used and the provider's applicable data terms.

7.2 Identity Verification Providers

KYC documentation may be transmitted to third-party identity verification service providers to conduct verification checks. These providers act as Data Processors under our instructions and are contractually bound to maintain appropriate data security measures.

7.3 Game Content Suppliers

Where game content is supplied by third-party providers, limited session and transaction data may be shared with those suppliers to facilitate game delivery, maintain game integrity and resolve disputes.

7.4 Regulatory and Law Enforcement Authorities

We may be required to disclose personal data to regulatory bodies, law enforcement agencies or courts pursuant to a lawful order, legal obligation or regulatory requirement. We will disclose only the minimum data necessary to comply with such requirements.

7.5 Corporate Transfers

In the event of a merger, acquisition or sale of all or part of the Platform's assets, personal data may be transferred to the successor entity as part of that transaction, subject to equivalent data protection obligations.

8 International Transfers

The 92co Platform is operated from outside Pakistan. By using the Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions other than Pakistan, including jurisdictions that may not provide the same level of data protection as those applicable in your country of residence.

Where personal data is transferred internationally, 92co takes appropriate steps to ensure that adequate safeguards are in place, including contractual data protection obligations with the receiving entity, to protect your personal data in accordance with the standards set out in this Policy.

9 Data Retention

92co retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal and regulatory obligations. The following general principles apply:

• Active Account data: Retained for the duration of the Account relationship and for a defined period thereafter as required by anti-money laundering and gaming regulatory obligations;
• KYC and identity documents: Retained for the period required under applicable anti-money laundering legislation in the operator's licence jurisdiction, typically a minimum of five years from the end of the customer relationship;
• Transaction records: Retained for the minimum period required by applicable financial record-keeping obligations;
• Support communications: Retained for a reasonable period sufficient to manage ongoing queries, dispute resolution and complaint handling;
• Marketing consent records: Retained until consent is withdrawn or the Account is closed, whichever is earlier.

Upon the expiry of the applicable retention period, personal data is deleted or anonymised in a manner that prevents re-identification.

10 Cookies & Tracking Technologies

92co uses cookies and similar tracking technologies on the Platform for the following purposes:

You can manage cookie preferences through your browser settings. Blocking essential cookies will affect Platform functionality and may prevent you from logging in or completing transactions. For further information on managing cookies, consult your browser's help documentation.

11 Your Rights

Subject to applicable data protection law, you have the following rights with respect to your personal data held by 92co. To exercise any of these rights, please contact us using the details in Section 15:

Requests will be responded to within a reasonable timeframe in accordance with applicable data protection law. We may request verification of your identity before processing any data subject request to prevent unauthorised access to another person's data.

12 Children's Privacy

The 92co Platform is strictly for adults aged 18 years or older, or such higher minimum age as required by the operator's licence jurisdiction or applicable local law. 92co does not knowingly collect personal data from individuals under the applicable minimum age.

If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated Account. If you have reason to believe that a minor has registered an Account or submitted personal data to the Platform, please contact us immediately using the details in Section 15.

13 Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive personal data at rest within Platform databases;
• Role-based access controls restricting access to personal data to authorised personnel only;
• Regular security assessments and monitoring of Platform infrastructure;
• Incident response procedures for detecting and responding to data security events.

While we take all reasonable precautions, no data transmission over the internet or storage system can be guaranteed to be 100% secure. Users are also responsible for maintaining the security of their own Account credentials. You should use a strong, unique password and enable two-factor authentication where available.

In the event of a data security incident that poses a material risk to your rights and interests, 92co will notify affected users in accordance with the applicable notification obligations under relevant data protection law.

14 Changes to This Policy

92co reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, Platform functionality, applicable law or regulatory guidance. Where changes are material, we will provide reasonable advance notice through the Platform, by email to your registered address, or through an on-screen notification upon next login.

The "Last reviewed" date at the top of this Policy indicates the date of the most recent revision. Your continued use of the Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you must stop using the Platform and may request closure of your Account in accordance with the Terms & Conditions.

We recommend reviewing this Policy periodically to stay informed of how your personal data is handled.

15 Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or have a concern about how 92co handles your personal data, please contact us using the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line. Expected response: within 24–48 hours on business days.
• Live Chat: Available 24/7 through the chat widget on the Platform. For data subject requests, please ask to be connected with the relevant support team.

When submitting a data subject request, please provide sufficient information to allow us to verify your identity and locate your Account. We will not process requests without reasonable verification to protect against unauthorised access to personal data.