Privacy Policy — How 99ae Protects Your Data in Pakistan

1. Overview

This Privacy Policy applies to all users of the 99ae platform, accessible at 99ae.pro, including users who access the platform via the 99ae Android app or any other supported method. It governs the collection, storage, use and protection of personal data provided by or generated by players on the platform.

By registering an account and using the 99ae platform, you acknowledge that you have read and understood this Privacy Policy. This policy should be read alongside our Terms and Conditions and our Responsible Gaming policy, all of which together form the full agreement between you and 99ae.

We are committed to handling personal data responsibly. The principle is straightforward: we collect what we need, we use it only for the purposes stated, we protect it properly, and we do not pass it to third parties for commercial gain.

2. What We Collect

The personal data we collect falls into the following categories:

We do not collect sensitive personal data beyond what is necessary for identity verification. We do not collect biometric data, health information or political/religious affiliations.

3. How We Collect Your Data

3.1 Directly From You

When you register your account, you provide identity and contact data directly. When you make a deposit or withdrawal, you provide financial data. When you contact support, you generate communication data. All of this is provided voluntarily by you in the course of using the platform.

3.2 Automatically During Use

When you access the platform — whether via browser or the 99ae app — technical and activity data is collected automatically. This includes your IP address, device identifiers, session length, pages visited, games accessed and betting activity. This data is collected via standard server logging and, where applicable, cookies and local storage on your device.

3.3 From Payment Providers

When you transact via JazzCash, Easypaisa, Raast, bank transfer or card, the relevant payment provider may share transaction confirmation data with us. We use this to credit your account and maintain accurate transaction records. We do not receive your full financial credentials from payment providers — only the confirmation data necessary to process the transaction.

4. Why We Use Your Data

Every category of data we collect has a specific purpose. We do not collect data speculatively or "just in case." The table below maps data to purpose:

We will not use your data for any purpose not listed here without obtaining your explicit consent first. Marketing communications are opt-in — if you have not opted in, we will not send promotional messages.

5. Payment Data and Financial Records

Given that 99ae handles real PKR transactions — deposits and withdrawals via JazzCash, Easypaisa, Raast, bank transfer and cards — we take the handling of financial data particularly seriously.

All payment data is encrypted in transit using TLS and encrypted at rest in storage. We retain financial transaction records for the period necessary to satisfy our internal audit requirements and to resolve any payment disputes that may arise. After this retention period, financial records are securely deleted or anonymised.

5.1 What We Store

For each transaction, we store: the transaction reference number, the payment method used, the amount in PKR, the date and time, and whether the transaction was a deposit or withdrawal. We do not store full card numbers — only the last four digits where applicable for reference purposes. JazzCash and Easypaisa wallet numbers are stored in encrypted form.

5.2 What We Do Not Store

We do not store your mobile banking PINs, online banking passwords, full card numbers, CVV codes or any credential that could be used to initiate a transaction on your behalf. Payment authorisation goes through the provider's own secure interface — 99ae never handles your raw payment credentials directly.

6. Sharing Your Data

We do not sell, rent or trade your personal data to any third party for commercial or marketing purposes. Full stop. However, there are limited circumstances where your data may be shared with third parties in order to operate the platform:

6.1 Service Providers

We work with carefully selected third-party service providers who assist in operating the 99ae platform. These include payment processors (JazzCash, Easypaisa, Raast, banking partners), identity verification services, cloud hosting providers, and customer support tools. These providers are contractually bound to handle your data only for the specific purpose for which it was shared, and may not use it for their own purposes.

6.2 Game Software Providers

The games in the 99ae lobby — slots, fish games, live casino and sports betting markets — are provided by third-party software suppliers. When you play a game, a session token and game activity data may be passed to the relevant provider's system to run the game. The provider receives your session identifier, not your full personal profile. Their handling of session data is governed by their own privacy and data security standards.

6.3 Legal Requirements

In exceptional circumstances, we may be required to disclose personal data in response to a valid legal order or request from an authority with jurisdiction. In such cases, we will disclose only the minimum data required to satisfy the specific request and will, where legally permitted, notify the affected account holder.

6.4 Business Transfers

In the event that 99ae undergoes a merger, acquisition or transfer of ownership, personal data held by the platform may be transferred to the successor entity as part of that transaction. Players would be notified of any such change and the successor's privacy commitments would be made clear prior to the transfer taking effect.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required to meet our legitimate business and security obligations. The general retention timelines we apply are as follows:

• Active account data: Retained for the full duration your account is open, plus a reasonable period after closure to allow for dispute resolution.
• Transaction and financial records: Retained for a minimum of five years from the date of the transaction for audit and dispute purposes, then securely deleted or anonymised.
• Identity verification documents: Retained for the period your account is active and for a defined period post-closure. Copies of ID documents are deleted once the retention period expires.
• Support communication records: Retained for a rolling period of two years from the last interaction, then deleted.
• Technical and session logs: Retained for a shorter rolling period for security monitoring purposes, then deleted or anonymised.

When an account is closed — whether by the player or by the platform — active personal data enters a retention hold for the applicable period before being deleted. During the retention hold, the data is accessible only for the specific purposes that justify its retention (dispute resolution, legal requests, fraud investigation) and is not used for any other purpose.

8. Security Measures

Protecting the personal and financial data of 99ae players is a core operational responsibility. The platform implements a layered set of technical and organisational security measures designed to prevent unauthorised access, loss or disclosure of personal data.

8.1 Technical Measures

• All data transmitted between your device and the 99ae platform is encrypted using TLS (Transport Layer Security).
• Personal data and financial records stored in our systems are encrypted at rest.
• Access to production data systems is restricted to authorised personnel only, controlled via access management systems and monitored continuously.
• Regular security assessments are conducted to identify and address vulnerabilities.
• Suspicious login activity triggers automated alerts and, where warranted, account protection measures.

8.2 Your Role in Security

Security is a shared responsibility. We maintain platform-side security, but you play an important role too. Keep your password strong and unique to 99ae — do not reuse it across other platforms. Never share your account credentials with anyone. If you suspect your account has been compromised, contact support immediately so we can take protective action. Enable any two-step verification options available in your account settings.

9. Cookies and Local Storage

The 99ae platform uses cookies and browser local storage to maintain session state, remember user preferences and gather aggregate analytics about how the platform is used. We do not use cookies to track your activity across other websites.

9.1 Essential Cookies

These are required for the platform to function. They maintain your login session, remember your currency preference (PKR) and handle security tokens. You cannot opt out of essential cookies without preventing the platform from working correctly.

9.2 Analytics Cookies

These help us understand how players navigate the platform — which games are popular, where players encounter friction, and how platform updates affect usage patterns. Analytics data is aggregated and does not identify individual players. You may opt out of analytics cookies via the cookie settings accessible from your account.

9.3 Preference Cookies

These remember your display preferences, language settings and any platform customisations you have applied. Without these, you would need to reset your preferences each session. These can be cleared at any time via your browser settings.

Most browsers allow you to view, manage and delete cookies via their settings menus. Clearing cookies will log you out of the platform and reset any saved preferences. The 99ae app uses equivalent local storage mechanisms rather than browser cookies.

10. Your Rights Over Your Data

You have meaningful rights over the personal data 99ae holds about you. These rights can be exercised at any time by contacting support. We aim to respond to data rights requests within 30 days.

11. Children and Minors

The 99ae platform is strictly for adults aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. The registration process requires confirmation that the user is 18 or over, and we reserve the right to request age verification documentation at any time.

If we discover or are notified that an account is held by a person under the age of 18, the account will be closed immediately, any personal data collected will be deleted in accordance with our data deletion process, and any balance in the account will be handled according to our age verification policy in the Terms and Conditions. If you are a parent or guardian and believe a minor has registered on the platform, please contact support immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in how we operate the platform, changes in the services we offer, or for other operational or legal reasons. When we make changes, we update the "Last Updated" date at the top of this page.

For material changes — those that significantly affect how your data is collected or used — we will notify active account holders via their registered contact details or through a platform notification before the change takes effect. Minor updates, such as clarifications or corrections that do not affect the substance of the policy, will be posted without individual notification.

Continued use of the platform after a policy update constitutes acceptance of the updated policy. If you disagree with a change, you should contact support to discuss your options before the change takes effect.

13. Contact and Data Requests

For any questions about this Privacy Policy, to exercise your data rights, or to raise a concern about how your personal data is handled, contact the 99ae support team. We handle data-related enquiries promptly — typically within 24 to 48 hours for standard queries, and within 30 days for formal data rights requests.

For questions about our responsible gaming tools and self-exclusion options, visit the Responsible Gaming page. For general platform questions, the FAQ page covers the most common topics.