Privacy Policy — 92par

1 Introduction

This Privacy Policy ("Policy") sets out how 92par ("we", "us", "our"), the operator of the platform accessible at https://92par.cam, collects, uses, stores, shares and protects personal data relating to users of our Service ("you", "your").

92par is an English-language online betting and casino information platform built for Pakistani users. We understand that our users trust us with sensitive personal information, and we take that responsibility seriously. This Policy is designed to be transparent, readable and practical — not a document designed to obscure how your data is handled.

By registering for an Account or continuing to use the 92par platform, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read in conjunction with our Terms & Conditions, which govern the overall use of the Service.

2 Definitions

In this Privacy Policy, the following terms carry the meanings defined below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, phone number, financial information, IP address or device identifiers.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, deletion or any combination thereof.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For this Platform, the Data Controller is 92par.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller under a contractual agreement.
• "Cookies" — small data files stored on your device by the Platform for purposes including session management, analytics and personalisation.
• "KYC" — Know Your Customer verification, the process by which we confirm your identity and age.
• "User" / "Account Holder" — a natural person who has registered an Account on the 92par platform.
• "Third Party" — any entity that is not 92par or the registered User, including payment processors, analytics providers and regulatory authorities.

3 Data We Collect

We collect personal data in the following categories, depending on how you interact with the 92par platform:

3.1 Registration & Account Data

• Full name, date of birth and gender.
• Email address, username and password (stored in hashed form).
• Mobile phone number and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi).
• Preferred language and currency (PKR where applicable).

3.2 Identity Verification (KYC) Data

• Government-issued photo ID (e.g., CNIC, passport, driver's licence).
• Proof of address documentation.
• Selfie or live verification image where required.
• Source of funds documentation as required by AML obligations.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records.
• Payment method references (e.g., mobile wallet identifiers associated with Easypaisa, JazzCash or Raast; bank account references for HBL, UBL, Meezan Bank, Bank Alfalah or other institutions). These references are used solely for payment processing verification — they do not imply endorsement by any payment provider.
• Transaction amounts, timestamps and processing outcomes.

3.4 Usage & Technical Data

• IP address and approximate geolocation derived from IP.
• Device type, operating system and browser information.
• Session logs, pages visited, features used and time spent.
• Betting and gaming activity, including stakes, wagers and game history.

3.5 Communications Data

• Support chat transcripts and email correspondence.
• Feedback, survey responses and promotional interactions.
• Responsible gambling self-assessment responses and tool activation records.

4 Legal Basis for Processing

Where data protection regulations applicable to the operator's jurisdiction require us to identify a legal basis for processing your personal data, we rely on the following:

5 Data Processing

We use personal data collected through the 92par platform for the following specific purposes:

5.1 Service Delivery. To operate your Account, process bets and transactions, provide customer support and deliver the core features of the 92par platform — including live sports betting on Pakistan cricket, PSL, ICC tournaments, esports and live casino products.

5.2 Identity & Compliance. To verify that you meet the eligibility criteria set out in our Terms and Conditions — including age verification (18+ or the higher minimum required by the applicable license jurisdiction) — and to comply with applicable KYC, AML and responsible gambling regulatory obligations.

5.3 Security & Fraud Prevention. To monitor Account activity for signs of fraudulent behaviour, unauthorised access, bonus abuse, multi-accounting or match-fixing involvement. Automated and manual monitoring processes are applied to protect both individual users and the integrity of the platform.

5.4 Responsible Gambling. To monitor betting patterns that may indicate problem gambling behaviour, to deliver responsible gambling tools (deposit limits, time limits, self-exclusion) and to contact users where our monitoring systems flag elevated risk indicators.

5.5 Platform Improvement. To analyse how users interact with the platform — including which sports markets are most popular, which pages are visited and where users encounter difficulties — enabling us to continuously improve the 92par experience for Pakistani users.

5.6 Marketing Communications. Where you have given explicit consent, to send you promotional communications about bonuses, new products, special offers and platform updates by email or push notification. You may withdraw consent at any time through your Account settings or by contacting support.

6 Data Sharing

92par does not sell your personal data to any third party. We share personal data only in the following controlled circumstances:

• Payment Processors: We share necessary transaction and identity data with payment processors to complete deposits and withdrawals. This may include references to local payment methods such as Easypaisa, JazzCash, Raast and banking institutions. These processors act as Data Processors under contract and may not use your data for their own purposes.
• KYC & Identity Verification Providers: We use specialist third-party identity verification services to carry out document checks. These providers process your KYC data solely for the purpose of verification under our instruction.
• Regulatory & Law Enforcement Authorities: We will disclose personal data to competent regulatory authorities, law enforcement agencies or courts where required by applicable law, court order or where we have a good-faith belief that disclosure is necessary to protect the rights, property or safety of 92par, our users or the public.
• Responsible Gambling Services: Where a User has requested self-exclusion, we may share necessary information with recognised third-party self-exclusion registries or responsible gambling support programmes where applicable and available.
• Technology & Infrastructure Providers: We engage cloud hosting, analytics and cybersecurity providers who process data on our behalf under strict data processing agreements. These providers are selected for their compliance credentials and contractually bound to process data only as instructed.

7 International Data Transfers

As an internationally operating platform, 92par may transfer personal data to countries outside your country of residence, including to countries that may not provide the same level of data protection as Pakistan or the European Union.

Where personal data is transferred internationally, we implement safeguards to protect it, which may include:

• Standard Contractual Clauses (SCCs) approved by relevant data protection authorities.
• Transfers to jurisdictions with adequate data protection frameworks, as determined by the applicable supervisory authority.
• Binding corporate rules and contractual data processing agreements requiring appropriate technical and organisational measures.

By using the 92par platform, you acknowledge that your personal data may be transferred, stored and processed in jurisdictions outside Pakistan for the purposes described in this Policy.

8 Data Retention

We retain personal data for as long as necessary to fulfil the purposes outlined in this Policy and to comply with applicable legal, regulatory and audit obligations. The following general retention periods apply:

When retention periods expire, personal data is securely deleted or anonymised so that it can no longer be attributed to an individual. Anonymised aggregate data may be retained indefinitely for statistical and research purposes.

9 Cookies & Tracking Technologies

92par uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small data file placed on your device when you visit our site. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that maintain your logged-in state, security tokens and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Performance & Analytics Cookies: Collect anonymised data on how users navigate the platform — including pages visited, time on page and error events. This data is used exclusively to improve platform performance and user experience.
• Functional Cookies: Remember your preferences such as language settings, currency display (PKR) and responsible gambling tool configurations between sessions.
• Marketing & Targeting Cookies: Used only where you have given explicit consent, to deliver personalised promotional communications and measure the effectiveness of marketing campaigns. You may withdraw consent at any time.

You can manage your cookie preferences at any time through your browser settings or through the cookie preferences panel available on the Platform. Disabling certain cookies may affect the functionality of the Service.

10 Security Measures

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• Two-factor authentication (2FA) available for all registered Accounts.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing and vulnerability assessments.
• Automated intrusion detection and real-time security monitoring.
• Secure data deletion procedures applied when retention periods expire.

While we apply rigorous security standards, no digital platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant supervisory authorities as required by applicable law.

11 Minors

The 92par platform is strictly for adults aged 18 years or older — or the higher minimum age required by the applicable license jurisdiction. We do not knowingly collect personal data from individuals under the age of 18.

If you are a parent or guardian and believe that a minor has accessed the platform or provided personal data, please contact us immediately at [email protected]. We will promptly investigate and, where confirmed, delete all associated personal data and close the Account.

We employ age verification as part of our KYC process and reserve the right to suspend any Account where we have reasonable grounds to suspect the Account holder does not meet the minimum age requirement.

12 User Rights

Subject to applicable data protection laws, you have the following rights in relation to your personal data held by 92par:

• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Some corrections can be made directly from your Account settings dashboard.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Note that we may be required to retain certain data to fulfil legal or regulatory obligations, even after an Account is closed.
• Right to Restriction of Processing: You may request that we restrict processing of your data in certain circumstances — for example, while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. Objection to marketing will result in immediate cessation of marketing communications.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact our support team. We will respond to all valid requests within 30 days. Where requests are complex or numerous, we may extend this period by a further two months, in which case we will notify you accordingly.

13 Complaints

If you believe that 92par has handled your personal data in a manner inconsistent with this Privacy Policy or applicable data protection law, we encourage you to raise the matter with us in the first instance. We take all privacy complaints seriously and will investigate and respond promptly.

You also have the right to lodge a complaint with the competent supervisory authority in the jurisdiction applicable to the operator's license. Where relevant data protection law applies in your territory, you may additionally raise concerns with your local data protection authority.

To submit a privacy complaint to 92par, contact our Data Protection team via the support contact details provided in Section 15 of this Policy, clearly referencing "Privacy Complaint" in your communication.

14 Policy Amendments

We reserve the right to update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or operational requirements. Where changes are material, we will notify registered Account holders by email or prominent on-platform notice at least 7 days before changes take effect, where reasonably practicable.

The date of the most recent update is displayed at the top of this page. We encourage you to review this Policy periodically. Your continued use of the 92par platform after an updated Policy takes effect constitutes your acceptance of the revised terms.

15 Contact Us

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the 92par Data Protection team using the details below. All communications should be in English.

Please note: contact details on this page are displayed as plain text only. We do not use clickable mailto links on any page of this platform.