Privacy Policy – How 92pr Collects, Uses & Protects Your Personal Data

This Privacy Policy ("Policy") is issued by 92pr ("we," "us," or "our"), the operator of the online gaming platform accessible at 92pr.bid (the "Platform"). This Policy describes how 92pr collects, processes, stores, shares, and protects the personal data of individuals who visit, register with, or use the 92pr Platform ("you" or "the Player").

92pr serves players across Pakistan — from Karachi and Lahore to Faisalabad and Islamabad — and handles significant volumes of personal and financial data as part of its everyday operations. We take this responsibility seriously. Privacy at 92pr is not treated as a secondary concern; it is integrated into how we design our systems, train our staff, and make decisions about data.

By registering a 92pr account or continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read, understood, and agreed to the processing of your personal data as described herein. If you disagree with any part of this Policy, you should discontinue use of the Platform immediately.

For the purposes of applicable data protection legislation, 92pr is the Data Controller responsible for the personal data collected through the 92pr.bid Platform. As Data Controller, 92pr determines the purposes for which personal data is processed and the means by which that processing is carried out.

92pr operates the Platform under an international gaming licence that includes data protection obligations consistent with internationally recognised privacy standards. Our data protection practices are designed to meet or exceed the requirements applicable to online gaming operators serving Pakistani players.

All enquiries, complaints, and data rights requests related to this Policy should be directed to the 92pr Data Protection contact at: [email protected]

92pr collects personal data through several channels: directly from you during registration and account use, automatically through the Platform's technical systems, and in some cases from third-party verification services. The categories of data collected are set out below:

92pr does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, or biometric data (other than where a selfie photograph is required for identity verification purposes).

92pr uses collected personal data for the following specific purposes:

• Account Creation and Management: To create, maintain, and manage your 92pr player account, including storing your login credentials, account preferences, and responsible gaming settings.
• Identity and Age Verification (KYC): To verify that you are who you claim to be and that you are at least 21 years of age, in compliance with regulatory requirements applicable to online gaming operators.
• Payment Processing: To process deposits via JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and to execute withdrawal requests to your verified payment methods in PKR.
• Fraud and Money Laundering Prevention: To detect, investigate, and prevent fraudulent activity, account abuse, collusion, and money laundering. This includes monitoring account activity for patterns inconsistent with legitimate recreational play.
• Game Provision and Platform Operation: To deliver the games, sports betting markets, and all other features of the 92pr Platform to you during your sessions.
• Customer Support: To respond to your enquiries, process complaints, and resolve disputes relating to your 92pr account.
• Legal and Regulatory Compliance: To fulfil obligations under applicable anti-money laundering laws, gaming licensing conditions, and any court orders or regulatory directives that require disclosure of account information.
• Responsible Gaming Monitoring: To monitor gameplay for indicators of problem gambling and to support the implementation and enforcement of responsible gaming tools including self-exclusion.
• Service Improvement: To analyse aggregated, anonymised data about how players use the Platform in order to improve game selection, platform performance, and user experience.
• Marketing Communications (with consent): To send you promotional materials, bonus offers, and updates about 92pr where you have provided explicit consent to receive such communications. See Section 12 for details.

92pr processes your personal data on the following legal grounds, consistent with international data protection principles:

• Contractual Necessity: Processing necessary to perform the contract between you and 92pr — i.e., to operate your player account, process deposits and withdrawals, and deliver gaming services. Without this processing, 92pr cannot provide you with the Platform services.
• Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, gaming licensing conditions, and tax reporting obligations. KYC verification and transaction monitoring fall into this category.
• Legitimate Interests: Processing necessary for 92pr's legitimate interests, provided those interests are not overridden by your fundamental rights. This includes fraud prevention, platform security, and service improvement based on anonymised analytics.
• Consent: Where 92pr relies on your consent to process data — primarily for marketing communications — you may withdraw that consent at any time by contacting [email protected] or adjusting your account communication preferences. Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.

92pr does not sell your personal data. We do not share your personal information with third parties for their own marketing or commercial purposes. However, 92pr may share your data with the following categories of third party where necessary for the purposes described in this Policy:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers need to receive your financial and identity data to process your PKR deposits and withdrawals. These processors operate under their own privacy policies and applicable financial regulations.
• Identity Verification Providers: Third-party KYC service providers who assist 92pr in verifying your identity and age using your CNIC and other documentation. These providers are contractually bound to process your data only for verification purposes.
• Game Providers: Software providers who supply the games available on 92pr may receive limited technical and gameplay data required to operate their games. Game providers do not receive your financial or identity data.
• Regulatory and Law Enforcement Authorities: 92pr may disclose your personal data to gaming regulators, financial intelligence authorities, law enforcement agencies, or courts where required to do so by applicable law, court order, or regulatory direction. 92pr will provide only the minimum information required and will notify you where legally permitted to do so.
• Professional Advisers: Legal counsel, accountants, and auditors who require access to account data on a confidential basis in the course of providing professional services to 92pr.

92pr uses cookies and similar tracking technologies on the 92pr.bid Platform to provide essential functionality, remember your preferences, and analyse how the Platform is used. The categories of cookies employed are as follows:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable you to log in to your 92pr account, maintain your session, and use core features such as the game lobby and account dashboard. These cookies cannot be disabled without preventing core Platform functionality.
• Functional Cookies: These cookies remember your preferences — such as language settings, display preferences, and your most recently played games — so that the Platform behaves in the way you expect between sessions.
• Performance and Analytics Cookies: These cookies collect anonymised data about how players interact with the Platform — which pages are visited most frequently, how long sessions last, and which features are most used. This data helps 92pr improve the Platform experience. No individually identifiable data is included in these analytics reports.
• Security Cookies: These cookies assist 92pr's fraud prevention and account security systems by detecting unusual login patterns and verifying device consistency between sessions.

You can manage cookie preferences through your browser settings. Blocking strictly necessary cookies will impair your ability to use the 92pr Platform. Blocking functional or analytics cookies will not prevent you from using the Platform but may reduce the quality of your experience.

92pr implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• Encryption in Transit: All data transmitted between your device and 92pr's servers is encrypted using TLS 1.3 with 256-bit AES cipher suites. The 92pr.bid domain enforces HTTPS exclusively — unencrypted HTTP connections are not accepted.
• Encryption at Rest: Sensitive personal data — including CNIC information, financial account numbers, and identity verification documents — is encrypted at rest using AES-256 encryption in 92pr's database infrastructure.
• Access Controls: Access to personal data within 92pr's systems is restricted on a strict need-to-know basis using role-based access controls. Employee access is logged and audited. Only personnel who require access to specific data categories to perform their job functions are granted that access.
• Two-Factor Authentication: 92pr's internal systems require multi-factor authentication for all staff access. Players are also encouraged — and may be required — to enable two-factor authentication on their 92pr accounts for additional protection.
• Penetration Testing and Security Audits: 92pr's systems undergo regular penetration testing and independent security audits to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: 92pr maintains a documented data breach response plan. In the event of a confirmed personal data breach, the incident response team is activated immediately to contain the breach, assess its scope, and notify affected players and relevant authorities as required.

While 92pr employs industry-standard security measures, no internet-based platform can guarantee absolute security. Players are encouraged to use strong, unique passwords for their 92pr accounts, enable two-factor authentication, and notify 92pr immediately if they suspect any unauthorised access to their account.

92pr retains personal data for no longer than is necessary for the purposes for which it was collected, taking into account our legal and regulatory obligations. Specific retention periods applicable to different categories of data are set out below:

At the expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytics purposes.

As a player whose personal data is processed by 92pr, you hold the following rights in relation to your personal information. These rights may be exercised at any time by contacting 92pr's support team at [email protected]:

All data rights requests are acknowledged within 3 business days and resolved within 30 calendar days of receipt. Where a request is particularly complex, 92pr may extend this period by a further 60 days with notification provided to the requesting player. Identity verification may be required before a rights request is fulfilled.

The 92pr Platform is strictly for individuals who are 21 years of age or above. 92pr does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register for or use the 92pr Platform, and you must not provide any personal information to 92pr through any channel.

92pr employs CNIC-based age verification as part of its KYC process specifically to prevent minors from accessing real-money gaming services. Where 92pr becomes aware that personal data has been collected from an individual who is under 21, we will take immediate steps to delete that data and close the associated account. All funds held in such accounts will be handled in accordance with applicable regulatory guidance.

If you are a parent or guardian and believe that a minor in your care has registered a 92pr account or provided personal data to 92pr, please contact us immediately at [email protected] and we will investigate and act promptly.

92pr may send you promotional communications about bonuses, new games, special events, and platform updates where you have explicitly opted in to receive such communications during the registration process or via your account settings.

Opting Out: You may withdraw consent to receive marketing communications at any time by:

• Clicking the "unsubscribe" link included in every marketing email sent by 92pr;
• Updating your communication preferences in your 92pr account settings; or
• Contacting 92pr support at [email protected] with a request to opt out.

Opting out of marketing communications will not affect the delivery of transactional communications — such as deposit confirmations, withdrawal notifications, account security alerts, and KYC verification requests — which are essential components of account management and cannot be disabled.

92pr operates internationally and some of the third-party service providers (including game software providers and KYC verification services) with whom we share limited data may be located in jurisdictions outside Pakistan. Where personal data is transferred internationally, 92pr ensures that appropriate safeguards are in place to protect your data to the same standard described in this Policy.

Appropriate safeguards for international transfers employed by 92pr include:

• Contractual clauses in data processing agreements with third-party recipients that impose equivalent data protection obligations;
• Transfers only to recipients located in jurisdictions that provide an adequate level of data protection as assessed by applicable regulatory guidance;
• Technical security measures ensuring that transferred data remains encrypted and access-controlled at the recipient's systems.

You may request further information about the specific safeguards applied to any particular international transfer of your personal data by contacting [email protected].

92pr reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, applicable laws, or regulatory requirements. When material changes are made, 92pr will notify active players by email to their registered address and/or by prominent notice displayed on the 92pr.bid Platform prior to the changes taking effect.

The "Effective Date" and "Last Reviewed" dates shown at the top of this Policy indicate when the current version was adopted. Your continued use of the 92pr Platform after the effective date of any update constitutes acceptance of the revised Policy.

If you do not agree with any update to this Policy, you should discontinue use of the Platform and contact 92pr support to close your account and request processing of any outstanding withdrawal prior to closure.

For all privacy-related enquiries, data rights requests, or complaints relating to how 92pr handles your personal data, please contact our Data Protection team through the following channels:

• Email: [email protected] — please include "Privacy Request" or "Data Rights" in the subject line to ensure prompt routing to the appropriate team.
• Live Chat: Available 24/7 within the 92pr Platform dashboard after logging in to your account.
• Response Commitment: All privacy enquiries are acknowledged within 3 business days. Full responses to data rights requests are provided within 30 calendar days.

If you are not satisfied with 92pr's response to a privacy complaint, you have the right to escalate the matter to the relevant data protection supervisory authority or gaming regulatory authority, details of which are available from 92pr support on request.