99ef Privacy Policy

99ef ("the Platform", "we", "us", "our") is an online casino and sports betting platform accessible at 99ef.pro. 99ef operates under an international gaming licence and offers services including live dealer casino games, video slots, crash games, and a sportsbook covering cricket, football, and other sporting events. The platform is made available in the English language and is designed for use by eligible players including those based in Pakistan.

For the purposes of this Privacy Policy, 99ef acts as the data controller in respect of the personal data of registered players and website visitors. This means 99ef determines the purposes for which your personal data is collected and the manner in which it is processed. As data controller, 99ef is responsible for ensuring that data processing activities comply with applicable data protection principles under our international gaming licence obligations.

99ef collects the following categories of personal data from players and website visitors. The specific data collected in each category depends on your level of interaction with the platform:

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, health data, or political opinions. The only exception is where such data is incidentally contained within a KYC document submitted by the player, in which case it is processed solely for identity verification and is not recorded separately or used for any other purpose.

99ef collects personal data through the following primary channels:

• Direct interactions: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or participating in a promotion.
• Automated technologies: Technical and usage data collected automatically when you access the 99ef website or platform, including cookies, server logs, pixel tags, and device fingerprinting tools used for fraud detection and responsible gaming monitoring.
• Third-party payment providers: Transaction confirmation data from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 processors, shared with 99ef to confirm deposit and withdrawal status.
• KYC and identity verification providers: Data returned by third-party identity verification services when processing document checks submitted by players during the KYC process.
• Responsible gaming monitoring tools: Behavioural data flagged by our responsible gaming system, which monitors for patterns consistent with problem gambling, as required under our international gaming licence duty-of-care obligations.

Personal data collected by 99ef is used strictly for the following purposes. We do not use your data for any purpose not listed below without first obtaining your consent or establishing a separate legal basis for processing:

• Account management: Creating, maintaining, and securing your 99ef player account, including password resets, account recovery, and session management.
• Identity verification and KYC compliance: Verifying your identity and age (21+) in line with our international gaming licence requirements and applicable anti-money-laundering regulations.
• Payment processing: Processing deposit and withdrawal requests via your chosen payment method, whether JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, or USDT TRC20.
• Fraud prevention and security: Detecting and preventing fraudulent activity, multi-accounting, bonus abuse, money laundering, and unauthorised access attempts on the platform.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviour and implementing responsible gaming interventions including deposit limits, self-exclusion, and cool-off periods.
• Customer support: Responding to your queries, resolving complaints, and maintaining records of support interactions for quality assurance and dispute resolution purposes.
• Legal and regulatory compliance: Meeting our obligations under our international gaming licence, including transaction reporting, record keeping, and cooperation with licensing authority requests.
• Platform improvement: Analysing aggregated and anonymised usage data to improve the 99ef platform, optimise game performance, and enhance the overall player experience.
• Marketing communications: Sending promotional offers, bonus notifications, and PSL cricket season promotions to players who have opted in to receive such communications. Players may opt out at any time.

99ef processes your personal data under one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to fulfil our obligations under the player account agreement, including account management, payment processing, and game service delivery.
• Legal obligation: Processing required to comply with applicable law and our international gaming licence requirements, including KYC verification, anti-money-laundering record keeping, and age verification.
• Legitimate interests: Processing carried out for 99ef's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where these interests are not overridden by your rights and interests.
• Consent: Processing of your data for marketing communications and certain optional cookie categories, where we have obtained your explicit consent. You may withdraw consent at any time by contacting [email protected].

99ef does not sell, rent, or trade your personal data. We share data only in the following limited and controlled circumstances:

• Payment service providers: Transaction data is shared with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 processors solely to facilitate deposit and withdrawal transactions. These providers operate under their own privacy policies and data protection obligations.
• Identity verification providers: Identity document data is shared with regulated third-party KYC verification services for the purpose of confirming player age and identity in line with our licence requirements.
• Game content providers: Certain gameplay data, including bet amounts and game session identifiers, may be shared with third-party game providers (such as live dealer game studios) to the extent necessary to deliver the relevant game service.
• Licensing and regulatory authorities: 99ef may be required to disclose player data to our international gaming licence authority, financial intelligence units, or law enforcement agencies in response to lawful requests or as part of mandatory regulatory reporting.
• Professional advisors: Legal counsel, auditors, and compliance consultants may access player data on a strictly confidential basis where necessary for the provision of their professional services to 99ef.
• Business transfers: In the event that 99ef or a substantial portion of its assets is acquired, player data may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer in advance.

99ef retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to mandatory minimum retention periods imposed by our international gaming licence and applicable anti-money-laundering regulations. The following general retention guidelines apply:

Upon expiry of the applicable retention period, personal data is either securely and permanently deleted from 99ef's systems or, where deletion is not technically feasible, anonymised such that it can no longer be associated with any individual player.

99ef implements a multi-layered security framework to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include the following technical and organisational controls:

• Encryption in transit: All data transmitted between your device and the 99ef platform is protected using TLS encryption. Connections over unencrypted HTTP are automatically redirected to HTTPS.
• Encryption at rest: Sensitive data including passwords, payment details, and identity documents is encrypted at rest using AES-256 or equivalent standards. Passwords are stored as salted hashes and are never stored or transmitted in plaintext.
• Access controls: Internal access to player data is restricted to staff who require it for their specific role. All internal data access is logged, and access rights are reviewed periodically. Privileged access requires multi-factor authentication.
• Fraud detection systems: 99ef operates automated fraud detection and anomaly monitoring systems that identify unusual account activity, login attempts from unrecognised devices or locations, and patterns consistent with account takeover attempts.
• Security assessments: The 99ef platform and its underlying infrastructure undergo periodic security reviews. Identified vulnerabilities are remediated according to a risk-based priority framework.
• Incident response: In the event of a data security incident affecting player data, 99ef maintains an incident response procedure that includes prompt investigation, containment, and notification to affected players and relevant authorities as required by our gaming licence obligations.

The 99ef platform uses cookies and similar tracking technologies to provide core platform functionality, remember your session state, detect fraud, and analyse usage patterns. By continuing to use the 99ef platform, you consent to the use of cookies in accordance with this section.

The following categories of cookies are used on the 99ef platform:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without preventing you from using the platform.
• Functional cookies: Remember your preferences such as language settings, display preferences, and previously visited game categories to personalise your experience on return visits.
• Analytics cookies: Collect anonymised data about how players navigate and interact with the platform. This data is used in aggregate form only to improve platform performance and user experience.
• Security and fraud prevention cookies: Used to identify device characteristics and detect suspicious behaviour, including automated access attempts, credential stuffing, and multi-accounting patterns. These are a regulatory requirement under our gaming licence.

You may manage your cookie preferences through your browser settings. Disabling strictly necessary or security cookies will impair or prevent your ability to use the 99ef platform. 99ef does not use third-party advertising cookies or retargeting pixel technologies.

As a 99ef player, you hold the following rights in relation to your personal data. These rights may be exercised at any time by submitting a written request to [email protected] with the subject line "Data Rights Request". 99ef will respond to all rights requests within 30 days of receipt.

• Right of Access: You may request a copy of all personal data 99ef holds about you, along with information about how it is being processed and the legal basis for processing.
• Right to Rectification: If any personal data 99ef holds about you is inaccurate or incomplete, you may request that it be corrected or updated. Where possible, corrections can be made directly within your account settings.
• Right to Erasure: In certain circumstances, you may request that 99ef delete your personal data. This right is subject to exceptions where retention is required by law or for our legitimate regulatory compliance purposes.
• Right to Restrict Processing: You may request that 99ef restrict the processing of your data in specific circumstances, for example where you contest the accuracy of the data or object to processing based on legitimate interests.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that 99ef provide your data in a structured, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling. You may also object at any time to the use of your data for direct marketing purposes, including promotional emails about 99ef bonuses and PSL cricket offers.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

The 99ef platform is strictly for adults aged 21 and above. We do not knowingly collect, store, or process personal data belonging to individuals under the age of 21. Registration on 99ef by any person under 21 is prohibited and constitutes a breach of our Terms & Conditions.

As part of our KYC compliance process, 99ef verifies the age of all players before processing any withdrawal. If 99ef discovers that a registered account belongs to a person under the age of 21, the following actions will be taken immediately:

• The account will be permanently suspended with no ability to reactivate.
• All personal data associated with the account will be deleted to the extent permitted by our regulatory retention obligations.
• Any deposits made will be assessed for return in line with our minor protection policy, and any winnings accumulated will be forfeited in full.
• The incident will be reported to our licensing authority as required under our international gaming licence conditions.

As an internationally licensed platform, 99ef operates infrastructure and works with service providers located in multiple jurisdictions. Personal data collected from players may be transferred to and processed in countries other than the country in which it was originally collected. This includes data transfers required for payment processing, KYC verification, and platform hosting.

Where personal data is transferred internationally, 99ef ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under our international gaming licence data protection obligations. These safeguards include:

• Contractual data processing agreements with all third-party service providers that impose data protection obligations equivalent to those applicable to 99ef.
• Ensuring that third-party processors engaged by 99ef operate in jurisdictions with adequate data protection frameworks or are bound by contractual clauses that provide equivalent protections.
• Restricting international transfers to the minimum data necessary for the specific processing purpose, in line with our data minimisation principle.

99ef reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our international gaming licence requirements. The version number and effective date shown at the top of this document will be updated whenever a revision is made.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — 99ef will notify registered players via email to their registered address at least 14 days before the changes take effect. Non-material changes (such as clarifications of existing practices or formatting updates) may be made without advance notice.

Your continued use of the 99ef platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any changes to this Privacy Policy, you should discontinue use of the platform and may close your account by contacting [email protected].

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 99ef, please contact our data protection team using the details below. We are committed to addressing all privacy-related enquiries promptly and transparently.

• Email: [email protected]
• Subject line for privacy requests: "Privacy Request" or "Data Rights Request"
• Response time: Within 48 hours for acknowledgement; full response within 30 days
• Support hours: Live chat available 24 hours / 7 days a week
• Business hours for email: Pakistan Standard Time (PKT), Monday to Saturday

If you are not satisfied with 99ef's response to your privacy concern, you may escalate the matter to our international gaming licence authority. Details of the relevant licensing authority are available on request by contacting our support team.