Privacy Policy — How 92star Protects Your Data

Introduction

This Privacy Policy ("Policy") sets out how 92star ("the Platform", "we", "us", "our"), operating through the website https://92star.cam, collects, uses, stores, shares and protects the personal data of individuals ("User", "you", "your") who access or use our online gaming and sports betting services.

92star is an English-language platform targeting Pakistani users. We recognise the trust you place in us when you share your personal information, and we take our obligations as a data handler seriously. This Policy is written in plain professional English to ensure it is understandable without specialist legal training. If any part of this Policy is unclear, please contact our support team before proceeding.

By registering an Account or continuing to use the 92star Platform, you acknowledge that you have read this Privacy Policy and understand how your personal data will be handled. If you do not agree with this Policy, you must not use the Platform.

Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, email address, postal address, identification documents and financial information.
• "Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this case, 92star.
• "Data Processor" means any third party that processes personal data on behalf of 92star under a contractual arrangement.
• "KYC Data" means identity and verification documents submitted as part of the Know Your Customer process, including CNIC, passport, proof of address and liveness checks.
• "Cookies" means small text files stored on your device by the Platform for the purposes of session management, analytics or personalisation.
• "Account" means your registered user profile on the 92star Platform.

Data We Collect

92star collects personal data in the following categories, depending on the services you use and the stage of your account lifecycle:

3.1 Registration Data

When you create an Account, we collect your full name, date of birth, email address, username, password (stored in encrypted form) and country of residence. This is the minimum data required to establish your identity and create a functional account.

3.2 Identity Verification (KYC) Data

To comply with anti-money laundering (AML) and identity verification requirements, we may collect copies of identity documents such as a valid CNIC (Computerised National Identity Card) or passport, proof of address (such as a utility bill or bank statement), and a photograph or liveness-check image. This data is processed through secure HTTPS channels only. You must never submit KYC documents through unsecured messaging applications.

3.3 Financial Data

We collect records of deposits, withdrawals and transaction history associated with your Account. We may also collect partial payment method identifiers (such as a masked bank account number or wallet reference) to facilitate withdrawals. Full payment credentials are handled by third-party payment processors and are not stored directly by 92star.

3.4 Usage and Behavioural Data

We collect data about how you interact with the Platform, including pages visited, games accessed, betting activity, session duration, device type, operating system, browser type and IP address. This data is used for analytics, fraud prevention and platform improvement.

3.5 Communications Data

If you contact our support team, we retain records of those communications — including chat logs and emails — for the purpose of resolving your enquiry and improving service quality.

3.6 Responsible Gambling Data

Where you apply for a deposit limit, loss limit, cool-off period or self-exclusion, we process and retain the relevant data to enforce your requested restrictions effectively and consistently.

How Data Is Collected

Personal data is collected through the following mechanisms:

• Directly from you — at registration, during KYC verification, when you contact support, when you complete transactions or when you update your Account settings.
• Automatically — through cookies, log files and similar tracking technologies as you browse and interact with the Platform.
• From third parties — from identity verification service providers engaged to assist with KYC compliance, and from payment processors to confirm transaction status.

Legal Basis for Processing

To the extent that applicable data protection law requires a legal basis for the processing of personal data, 92star relies on the following lawful bases:

How We Use Your Data

92star uses the personal data it collects for the following purposes:

• To create, verify and maintain your Account in accordance with our Terms & Conditions.
• To verify your identity and age as required by our KYC and AML obligations.
• To process deposits, bets, winnings and withdrawal requests.
• To detect, investigate and prevent fraud, account abuse, money laundering and other prohibited activities.
• To enforce responsible gambling restrictions you have requested, including deposit limits, loss limits, cool-off periods and self-exclusion.
• To analyse Platform usage and improve the user experience for all users, including those in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.
• To respond to support enquiries and resolve complaints.
• To send you service notifications relevant to your Account status, security or activity.
• To send marketing communications where you have provided explicit consent to receive them, and to withdraw that consent at any time.

Data Sharing & Disclosure

92star does not sell, rent or trade your personal data. We may share your data in the following limited circumstances:

7.1 Service Providers and Data Processors

We engage third-party service providers to assist in operating the Platform, including identity verification providers, payment processors, analytics platforms and customer support infrastructure. These providers process data on our behalf under contractual data processing agreements and are not permitted to use your data for their own purposes.

7.2 Legal and Regulatory Disclosure

We may be required to disclose personal data to competent authorities, regulators or courts where we are legally obliged to do so, including in connection with AML investigations, fraud proceedings or law enforcement requests. 92star does not claim to be under the jurisdiction of Pakistani regulatory authorities; however, legal obligations in the jurisdiction of our operating licence may require disclosure.

7.3 Business Transfers

In the event of a merger, acquisition or sale of all or part of our business, personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer through the Platform prior to the change taking effect.

7.4 Payment Method References

Where you use a payment method to deposit or withdraw funds, necessary transaction data is shared with the relevant payment processor. Payment methods familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are referenced as familiar local context. 92star does not represent that any named provider endorses gambling or has confirmed availability on this Platform. Each provider operates its own privacy practices independent of this Policy.

Cookies & Tracking Technologies

The 92star Platform uses cookies and similar tracking technologies to deliver a functional, secure and personalised user experience. Cookies are small text files stored on your device when you visit the Platform.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Platform to function — including session management, security tokens and login persistence. These cannot be disabled without impairing Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the Platform. This data helps us identify areas for improvement.
• Preference Cookies: Used to remember your settings and preferences, such as language and display options, across sessions.
• Marketing Cookies: Only deployed where you have provided explicit consent. Used to personalise promotional content you may see on the Platform.

8.2 Managing Cookies

You can control and delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will impair your ability to use the Platform. Instructions for managing cookies vary by browser — please consult your browser's help documentation for specific guidance.

Data Retention

92star retains personal data for as long as necessary to fulfil the purposes set out in this Policy or as required by applicable legal and regulatory obligations. The following general retention principles apply:

• Account data is retained for the duration of your active Account and for a period thereafter as required by the operator's regulatory obligations — typically a minimum of five years following account closure.
• KYC documents are retained in accordance with AML regulatory requirements applicable in the operator's licensing jurisdiction. This period is typically a minimum of five years from the end of the business relationship.
• Transaction records are retained as required by financial and regulatory record-keeping obligations.
• Support communications are retained for a reasonable period — typically up to three years — to facilitate ongoing support quality and dispute resolution.
• Analytics data may be retained in aggregated, anonymised form indefinitely as it does not constitute personal data after anonymisation.

Where data is no longer required and retention is not mandated, we apply appropriate deletion or anonymisation procedures.

Data Security

92star implements technical and organisational measures designed to protect your personal data against unauthorised access, loss, destruction or alteration. These measures include:

• HTTPS encryption for all data in transit between your device and the Platform.
• Encryption or hashing of sensitive stored data, including passwords and selected personal data fields.
• Access controls limiting Platform system access to authorised personnel on a need-to-know basis.
• Regular review of security procedures and infrastructure.
• KYC document uploads processed exclusively through designated secure HTTPS verification flows.

Your Data Rights

Subject to applicable law, you may have the following rights in respect of your personal data held by 92star:

11.1 Right of Access

You may request confirmation of whether 92star holds personal data about you and, if so, a copy of that data together with information about how it is processed.

11.2 Right to Rectification

You may request correction of inaccurate or incomplete personal data held about you. Please note that certain data — particularly KYC-verified identity information — cannot be unilaterally changed without supporting documentary evidence.

11.3 Right to Erasure

You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other lawful basis applies. This right is subject to overriding legal and regulatory retention obligations.

11.4 Right to Restrict Processing

In certain circumstances, you may request that we restrict the processing of your personal data — for example, while an accuracy dispute is being investigated.

11.5 Right to Data Portability

Where processing is based on consent or contract and carried out by automated means, you may request a structured, machine-readable copy of the personal data you have provided to us.

11.6 Right to Object

You may object to processing based on legitimate interests, including profiling for marketing purposes. Where you object to direct marketing, we will cease processing for that purpose promptly.

11.7 Withdrawing Consent

Where processing is based on your consent — such as for marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Minors & Age Restriction

The 92star Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's licensing jurisdiction, whichever is greater. We do not knowingly collect personal data from minors.

Where we discover or have reasonable grounds to believe that personal data has been collected from a person under the minimum age, we will take immediate steps to close the associated Account, delete the relevant personal data and — where appropriate — retain only the data necessary to enforce the age-restriction breach in accordance with our Terms & Conditions.

If you believe that a minor has registered an Account on the Platform, please contact our support team immediately.

International Data Transfers

92star operates an international platform. Your personal data may be transferred to, and processed in, countries other than the country in which you are located. These countries may have different data protection laws from those in Pakistan or your country of residence.

Where personal data is transferred internationally, 92star takes steps to ensure that appropriate safeguards are in place in accordance with applicable data protection requirements, including contractual protections with third-party processors operating in other jurisdictions.

By using the 92star Platform, you acknowledge that your personal data may be transferred internationally as described in this Policy.

Changes to This Privacy Policy

92star reserves the right to amend, update or replace this Privacy Policy at any time. Where changes are material, we will provide advance notice through the Platform — including, where possible, via email to the address registered on your Account — prior to the changes taking effect. The "Last updated" date at the top of this Policy will reflect the most recent revision.

Your continued use of the Platform following notification of changes constitutes acceptance of the revised Privacy Policy. If you do not accept the revised Policy, you must cease using the Platform and may request account closure by contacting our support team.

Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the handling of your personal data, please contact our support team. We will respond to all data-related enquiries as promptly as practicable.

We will acknowledge receipt of all data rights requests and aim to provide a substantive response within 30 days. Complex requests may require additional time, in which case we will notify you of the expected response date.