Privacy Policy — po99 Platform

po99 ("we", "us", "our") operates the online gaming platform accessible at https://po99.cam ("the Platform"). This Privacy Policy ("Policy") sets out how po99 collects, uses, discloses, stores and protects personal data belonging to individuals who access, register on or use the Platform ("you", "the User", "the Player").

po99 is an English-language online gaming platform designed primarily for Pakistani users. We are committed to handling personal data with care, transparency and in accordance with the applicable data protection framework governing the operator's jurisdiction. This Policy is intended to give you a clear and honest account of our data practices.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, which together form the full set of agreements governing your use of the Platform.

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

po99 collects personal data across several categories, depending on the nature of your interaction with the Platform:

We do not intentionally collect sensitive personal data (such as racial origin, political opinions, religious beliefs or biometric data) except where identity verification requirements make it unavoidable (e.g., a government-issued ID that includes a photograph). Such data is used solely for the stated KYC purpose and not processed further.

Personal data is collected through the following mechanisms:

• Direct submission: Data you enter into registration forms, KYC upload portals, support chat or email correspondence.
• Automated technical collection: Server logs, cookies and similar tracking technologies that record device and session information each time you visit the Platform.
• Transaction processing: Data received from payment processors when you make a deposit or request a withdrawal — for example, wallet IDs associated with Easypaisa or JazzCash transactions. These payment providers are referenced here as context only; they do not endorse, affiliate with or support po99's gambling operations.
• Third-party verification services: Identity and age verification providers who confirm the authenticity of documents you submit during KYC.
• Analytics tools: Aggregated, anonymised usage data from analytics platforms used to improve Platform performance and content relevance.

Where applicable data protection frameworks require a lawful basis for processing personal data, po99 relies on the following bases:

• Contractual necessity: Processing required to perform our contract with you — operating your account, processing deposits and withdrawals, providing access to games and customer support.
• Legal obligation: Processing required to comply with applicable law — including KYC, anti-money-laundering checks, fraud prevention and regulatory reporting obligations.
• Legitimate interests: Processing for our legitimate business interests, including fraud detection, Platform security, improving services and managing responsible gambling obligations — where these interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained and can be withdrawn at any time.

po99 uses personal data collected from users for the following purposes:

• Account management: Creating, maintaining and securing your po99 account; authenticating logins and processing account requests.
• Transaction processing: Facilitating deposits and withdrawals; verifying payment method ownership; maintaining transaction records in PKR.
• Identity verification (KYC): Confirming that users are who they claim to be; verifying age to enforce the 18+ restriction; fulfilling anti-money-laundering obligations.
• Customer support: Responding to queries, complaints and responsible gambling requests submitted via live chat or email ([email protected]).
• Fraud prevention and security: Detecting suspicious behaviour, preventing account takeover, investigating and responding to potential fraud or financial crime.
• Responsible gambling: Monitoring usage patterns relevant to player protection; applying limits or restrictions requested by the player; facilitating self-exclusion.
• Platform improvement: Analysing aggregated usage data to improve game offerings, interface performance and content relevance for Pakistani users — including those in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.
• Marketing (with consent): Sending promotional communications about po99 offers, new game releases and cricket or PSL-related promotions where you have opted in. You may withdraw consent at any time.
• Legal compliance: Meeting obligations imposed by applicable law, court orders or regulatory requirements.

po99 does not sell, rent or trade personal data to third parties for their own marketing purposes. We may share personal data in the following limited circumstances:

• Payment processors: Transaction data shared with payment service providers to process deposits and withdrawals. Payment provider names referenced on this platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah and crypto processors — are mentioned for contextual purposes only. Their involvement as processors does not imply endorsement of gambling activities or affiliation with po99.
• Identity verification providers: KYC documents and personal data shared with regulated third-party identity verification services solely to fulfil verification obligations.
• Fraud prevention services: Data shared with fraud detection and anti-money-laundering screening providers as required by applicable law and industry standards.
• Legal and regulatory authorities: Personal data disclosed to law enforcement agencies, courts, regulators or government bodies where required by law, court order, or to protect the rights and safety of po99 or third parties.
• IT and infrastructure providers: Hosting, data storage and analytics providers who process data on our behalf under data processing agreements that require them to keep data secure and use it only for specified purposes.
• Business transfers: In the event of a merger, acquisition or sale of the business, personal data may be transferred to the successor entity, subject to equivalent privacy protections.

po99 may transfer personal data to servers or service providers located outside your country of residence, including outside Pakistan. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place to protect your personal data, including contractual clauses or data transfer agreements with receiving parties.

By using the Platform and providing your personal data, you acknowledge that your data may be transferred to and processed in countries outside Pakistan whose data protection laws may differ from those in your jurisdiction.

po99 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulatory obligation.

Where retention beyond these periods is required by applicable law or regulatory obligation — for example, anti-money-laundering legislation — data will be retained for the duration of that legal requirement.

po99 uses cookies and similar tracking technologies on the Platform. Cookies are small files placed on your device that help us operate the Platform, remember your preferences and analyse usage patterns.

• Essential cookies: Required for the Platform to function — including session authentication, security tokens and load balancing. These cannot be disabled without breaking core functionality.
• Functional cookies: Remember your preferences, such as language settings and interface choices, to personalise your experience.
• Analytical cookies: Collect aggregated, anonymised data about how users navigate the Platform — page views, session durations, device types. Used to improve Platform performance and content.
• Marketing cookies: Track user interactions to deliver relevant promotional content. These require your explicit consent and may be withdrawn at any time.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing core Platform features, but may limit some personalisation or analytics functionality.

Subject to applicable data protection law and any overriding legal obligations, you have the following rights regarding your personal data held by po99:

To exercise any of these rights, contact our support team at [email protected] (plain text — not a clickable link). We will respond within a reasonable timeframe. We may require identity verification before acting on a data rights request.

Please note that certain rights are limited by legal and regulatory retention requirements. For example, KYC documents and transaction records must be retained for specified periods under applicable financial regulation regardless of an erasure request.

po99 may send promotional communications — including welcome offer updates, PSL cricket betting promotions and new game announcements — by email or other channels, but only where you have given explicit consent to receive them.

• You may opt out of marketing communications at any time by updating your preferences in your account settings or by contacting our support team.
• Withdrawing consent for marketing does not affect the lawfulness of processing carried out before withdrawal.
• Transactional communications — such as account verification emails, withdrawal confirmations and security alerts — are not marketing and will continue to be sent as necessary for account operation.

The po99 Platform is strictly intended for adults aged 18 years or over — or the higher minimum age required by the applicable operator/licence jurisdiction. We do not knowingly collect personal data from persons under the age of 18.

If we become aware that personal data has been collected from a person under the applicable minimum age, that account will be suspended immediately and the data will be deleted as soon as practicable, subject to any legal retention obligations. If you believe that a minor has registered on the Platform, please notify us immediately at [email protected].

Being 18 years of age does not make gambling lawful in all parts of Pakistan. Users are responsible for understanding and complying with the laws applicable in their own jurisdiction.

The po99 Platform may contain references or links to third-party websites or services. This Privacy Policy applies solely to data collected by po99 through the Platform. po99 has no control over the privacy practices of third-party websites and accepts no responsibility for them. We encourage you to review the privacy policies of any third-party service you access.

po99 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration or disclosure:

• Encryption in transit: All data transmitted between your device and the Platform is encrypted using SSL/TLS protocols.
• Encryption at rest: Sensitive data, including passwords (stored as cryptographic hashes) and financial identifiers, is encrypted in storage.
• Access controls: Access to personal data is restricted to authorised personnel who require it to perform their role, on a least-privilege basis.
• Two-factor authentication: Available to all registered users as an additional layer of account security.
• Security monitoring: We employ logging and monitoring systems to detect and respond to unusual activity or potential security incidents.
• Staff training: Personnel with access to personal data are trained in data protection obligations and security best practices.

No security system is impenetrable. In the event of a data breach that poses a risk to your rights, we will notify affected users and relevant authorities in accordance with applicable legal requirements.

po99 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered users by email or by a prominent notice on the Platform prior to the change taking effect. The date of the most recent revision is shown at the top of this document.

Continued use of the Platform after the effective date of any amendment constitutes acceptance of the revised Policy. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure by contacting our support team.

For any questions, concerns or requests relating to this Privacy Policy or your personal data, please contact the po99 support team using the details below. All contact information is provided as plain text only and is not a clickable link:

We aim to acknowledge all data-related enquiries within 5 business days and to resolve them within 30 calendar days where possible. Complex requests — such as large-scale data access requests or contested erasure matters — may require additional time, and we will keep you informed of progress.

If you are dissatisfied with our response to a privacy concern, you may have the right to lodge a complaint with the relevant data protection supervisory authority in the jurisdiction governing this Platform's operations.