99ae Privacy Policy

§01 Who We Are

99ae is an online casino and sports betting platform accessible at 99ae.app. The platform is operated by a duly licensed operator entity (hereinafter referred to as "99ae", "we", "us", or "our"). 99ae acts as the data controller in respect of personal data collected from users ("you", "your") who register and use the platform.

This Privacy Policy applies to all personal data collected through the 99ae website, mobile-optimised interface, and any related communications, including account registration, payment processing, customer support interactions, and promotional communications.

§02 Data We Collect

99ae collects the following categories of personal data from its users, depending on the nature and extent of your interaction with the platform:

2.1 Identity & Registration Data

• Full legal name as it appears on your CNIC (Computerised National Identity Card)
• Date of birth (for mandatory 21+ age verification)
• CNIC number and copies of identity documentation where required for KYC
• Username and hashed account credentials
• Nationality and country of residence

2.2 Contact Information

• Email address (primary communication channel)
• Pakistani mobile phone number (for JazzCash/EasyPaisa verification and 2FA)
• Residential address where required for enhanced identity verification

2.3 Financial & Transaction Data

• JazzCash and EasyPaisa mobile wallet identifiers
• Bank account details (HBL, UBL, Meezan Bank, or other linked bank) where used for deposits/withdrawals
• Transaction history including deposit amounts, withdrawal requests, and timestamps
• Bonus and promotional credit records

2.4 Gaming Activity Data

• Bets placed, games played, stakes, and outcomes
• Session duration and frequency of play
• Responsible gaming tool settings (deposit limits, self-exclusion periods)
• Promotional participation and bonus wagering records

2.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Session logs and platform access timestamps
• Cookie identifiers (see Section 10)

2.6 Communications Data

• Content of support chat or email correspondence
• Feedback, complaints, and dispute records
• Records of marketing communication preferences

§03 How We Collect Your Data

99ae collects your personal data through the following means:

• Directly from you: When you register an account, complete identity verification, make a deposit, contact support, or participate in a promotion.
• Automatically: Through cookies, session tracking, and server logs when you access and interact with the 99ae platform.
• From third parties: Identity verification providers, payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank), and fraud prevention services may provide supplementary data to confirm identity and prevent financial crime.

§04 Purposes of Processing

99ae processes your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, credential data
Identity and age verification (21+ compliance)	CNIC, date of birth, identity documents
Processing deposits and withdrawals	Financial data, payment method identifiers
Anti-money-laundering (AML) and fraud prevention	Transaction data, identity data, IP/device data
Delivering casino and sports betting services	Gaming activity, session data
Responsible gaming monitoring	Gaming activity, self-exclusion preferences
Customer support	Communications data, account data
Platform security and fraud detection	IP, device, session data
Marketing communications (where consented)	Contact information, gaming preferences
Legal and regulatory compliance	All applicable categories

§05 Legal Bases for Processing

99ae processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the agreement between you and 99ae — including account creation, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws, including anti-money-laundering regulations, identity verification requirements, and licensing conditions.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving the 99ae product, where such interests are not overridden by your fundamental rights.
• Consent: For marketing communications and non-essential cookies, where consent has been explicitly obtained and can be withdrawn at any time.

§06 Data Sharing with Third Parties

99ae does not sell, rent, or trade your personal data. We share your data with third parties only in the following limited circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers receive the minimum data necessary to process your transactions.
• Identity verification services: Third-party KYC and AML providers receive identity and documentary data to complete mandatory verification procedures.
• Game software providers: Game studios such as Evolution, Pragmatic Play, and PG Soft receive session data required to run their games. These providers operate under their own certified security frameworks.
• Regulatory authorities: Where required by applicable licensing or law enforcement authorities, 99ae may be legally obligated to disclose certain data without advance notice to the user.
• IT and infrastructure providers: Cloud hosting and security vendors who process data on behalf of 99ae under strict data processing agreements.

All third-party service providers engaged by 99ae are required to implement appropriate technical and organisational safeguards to protect your data and are prohibited from using it for any purpose other than the specific service they provide to 99ae.

§07 International Data Transfers

As an internationally licensed platform serving Pakistani users, 99ae may transfer your personal data to, and store it in, countries outside Pakistan. Where such transfers occur, 99ae ensures appropriate safeguards are in place — including contractual data protection clauses with receiving entities — to maintain a level of protection equivalent to that applied within the platform's operating jurisdiction.

§08 Data Retention

99ae retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal, regulatory, and licensing obligations. Specific retention periods include:

• Account and transaction data: Retained for a minimum of 5 years following account closure, in compliance with standard AML record-keeping requirements.
• Identity verification documents: Retained for the duration of your account plus a minimum of 5 years post-closure.
• Communications and support records: Retained for a minimum of 2 years from the date of the communication.
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier.
• Session and device logs: Retained for up to 12 months for fraud detection and security purposes.

Following the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any individual user.

§09 Security Measures

99ae implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction:

• Transport Layer Security (TLS 1.3) encryption for all data in transit between your device and 99ae servers.
• AES-256 encryption for sensitive data at rest, including payment details and identity documents.
• Optional two-factor authentication (2FA) for all user accounts.
• Strict role-based access controls ensuring that only authorised 99ae personnel can access personal data, limited to what is necessary for their role.
• Regular security audits, penetration testing, and vulnerability assessments of the 99ae platform.
• Automated fraud detection systems monitoring for unusual account activity and suspicious transactions in real time.

§10 Cookies & Tracking Technologies

99ae uses cookies and similar tracking technologies on the platform for the following purposes:

• Essential cookies: Required for the platform to function correctly, including maintaining your login session, storing cart or bet slip data, and remembering security tokens. These cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and game lobby filters.
• Security cookies: Used to detect and prevent fraudulent account activity, bot traffic, and suspicious login patterns.
• Analytics cookies: Aggregate, anonymised data used by 99ae to understand how users interact with the platform and identify areas for improvement. No individual user is identifiable from this data.

99ae does not deploy third-party advertising or tracking cookies. You can manage cookie preferences through your browser settings; however, disabling essential cookies may impair your ability to log in or use certain features of the platform.

§11 Children's Privacy

The 99ae platform is strictly for persons aged 21 years and over. 99ae does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not attempt to register or use the platform.

If 99ae becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, all data will be deleted in accordance with applicable data protection obligations, and the circumstances will be reviewed in line with our responsible gaming policies.

§12 Your Data Rights

Subject to applicable law and our legal obligations, you have the following rights in respect of your personal data held by 99ae:

• Right of access: You may request a copy of the personal data 99ae holds about you.
• Right of rectification: You may request correction of any inaccurate or incomplete personal data.
• Right of erasure: You may request deletion of your personal data where 99ae no longer has a legal basis to retain it. Note that AML retention obligations may prevent full deletion of certain records.
• Right to restrict processing: You may request that 99ae pauses its processing of your data in specific circumstances.
• Right to data portability: You may request your data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing of your data for direct marketing purposes at any time with immediate effect.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact 99ae's data team via the support email listed in Section 15. We will acknowledge your request within 5 business days and aim to respond fully within 30 calendar days.

§13 Marketing Communications

Where you have provided your consent during registration or subsequently opted in, 99ae may send you marketing communications about bonuses, promotions, new games, and platform updates via email and SMS. These communications will be relevant to your use of the 99ae platform and will not be shared with third-party advertisers.

You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email from 99ae.
• Updating your communication preferences in your 99ae account settings.
• Contacting 99ae support directly with an opt-out request.

Please note that opting out of marketing does not affect transactional or account-related communications (such as deposit confirmations, withdrawal notifications, and account security alerts), which are necessary for platform operation.

§14 Changes to This Privacy Policy

99ae may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or platform features. When material changes are made, 99ae will notify you by:

• Sending a notification to your registered email address; and/or
• Displaying a prominent notice on the 99ae platform at your next login.

The "Effective Date" at the top of this policy will be updated to reflect the date of the latest revision. Your continued use of the 99ae platform following the effective date of any changes constitutes your acknowledgement of the revised Privacy Policy.

§15 Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the 99ae data protection team:

Our support team handles queries in English and Urdu and is available during Pakistan Standard Time business hours. For general platform questions, you may also visit our FAQ page.