99club Privacy Policy

99club is committed to protecting the privacy and personal data of all its users, with particular regard to the players who access our platform from Pakistan. We understand that your personal information is sensitive, and we treat it with the seriousness it deserves — not as a formality, but as a genuine obligation.

This Privacy Policy applies to all information collected through the 99club website, its mobile-optimised interface, customer support channels, marketing communications, and any other service operated under the 99club brand. It applies to registered account holders as well as visitors who browse the platform without registering.

99club processes personal data in accordance with the data protection obligations imposed by the jurisdiction in which it holds its international gaming licence, and in a manner consistent with good practice standards applicable to responsible online gaming operators. Where Pakistani laws or regulations impose additional obligations regarding personal data, 99club endeavours to comply with those requirements to the extent applicable.

99club collects personal data through several channels, including the account registration form, the KYC verification process, payment transactions, customer support interactions, and automated technical systems. The categories of data we collect are set out below.

2.1 Registration Data

When you create a 99club account, we collect the information you provide directly, which includes:

• Full legal name (as it appears on your CNIC or passport)
• Date of birth (used to verify the 21+ age requirement)
• Email address
• Mobile phone number (used for OTP verification and account security)
• Residential address in Pakistan (city, province, postal code)
• Username and password (password is stored in encrypted, hashed form — never in plain text)
• Preferred currency (PKR)

2.2 Identity Verification (KYC) Data

As part of our Know Your Customer obligations under our gaming licence, we may request:

• A copy of your valid Computerised National Identity Card (CNIC)
• A copy of your passport (where CNIC is unavailable)
• A recent utility bill or bank statement as proof of address
• A selfie or live photograph for facial verification purposes
• Source of funds documentation in cases where large transactions are involved

2.3 Financial Transaction Data

When you make deposits or request withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, or Mastercard, we collect:

• Payment method type and identifiers (e.g., last 4 digits of a card, mobile wallet number)
• Transaction amounts in PKR
• Transaction timestamps and reference numbers
• Bank name and account holder name (for bank transfer verification)

2.4 Gaming Activity Data

We maintain records of your gaming and betting activity on the platform, including:

• Games played, bets placed, and wagering amounts
• Session start and end times
• Bonus usage and wagering history
• Sports markets and cricket betting selections
• Win and loss history over time

This data is used for responsible gaming monitoring, fraud prevention, and dispute resolution. It is retained for the duration required by our licence.

2.5 Technical & Device Data

When you access 99club, our servers and analytics systems automatically collect:

2.6 Communications Data

If you contact our support team via live chat or email, we retain a record of those communications, including the content of messages, timestamps, and any attachments provided. This enables us to resolve disputes, maintain quality standards, and provide continuity of service.

99club processes personal data for the following purposes:

• Account creation and management: To register your account, verify your identity, manage your preferences, and provide ongoing access to platform services.
• Age and eligibility verification: To confirm that you meet the 21+ age requirement and are otherwise eligible to use the platform.
• Payment processing: To facilitate deposits and withdrawals via supported Pakistani payment methods and to maintain accurate financial records.
• KYC and anti-money laundering (AML) compliance: To fulfil our obligations under the terms of our international gaming licence, including transaction monitoring and suspicious activity reporting where required.
• Fraud detection and prevention: To identify and investigate suspicious account behaviour, multi-accounting, and other prohibited conduct.
• Responsible gaming: To monitor gaming patterns that may indicate problematic behaviour and to apply responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion where triggered.
• Customer support: To respond to your enquiries, process complaints, and manage account-related requests efficiently.
• Platform improvement: To analyse usage patterns and technical performance data in order to improve the platform experience for Pakistani players.
• Legal and regulatory compliance: To respond to lawful requests from regulatory authorities, law enforcement agencies, or courts of competent jurisdiction.
• Marketing communications: To send you promotional offers, bonus notifications, and relevant platform updates, but only where you have provided your consent to receive such communications.

99club processes personal data on the following legal bases, depending on the purpose of processing:

• Contractual necessity: Processing required to perform the contract between you and 99club — including account registration, payment processing, and the provision of gaming services.
• Legal obligation: Processing required to comply with applicable laws and regulatory requirements, including KYC, AML, and responsible gaming obligations under our gaming licence.
• Legitimate interests: Processing carried out for the legitimate business interests of 99club, including fraud prevention, platform security, and improvement of services, where those interests are not overridden by your rights and interests.
• Consent: Processing carried out on the basis of your explicit consent, including marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time.

99club does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the following limited circumstances:

5.1 Service Providers

We engage carefully selected third-party service providers to assist in operating the platform. These include payment processing companies (handling JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard transactions), identity verification partners, customer support technology providers, and cloud hosting services. All such providers are contractually bound to process data only for the specific purposes for which they are engaged and to maintain appropriate security standards.

5.2 Game Suppliers

Where you play games provided by third-party software suppliers (such as live casino game studios), those suppliers may receive limited gameplay data necessary to deliver the game experience. They are not permitted to use that data for any independent purpose.

5.3 Regulatory and Legal Disclosure

99club may disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required by law or by a binding legal order. We will notify you of such disclosures where we are legally permitted to do so.

5.4 Business Transfers

In the event that 99club undergoes a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and any material change to the privacy arrangements that results from it.

99club uses cookies and similar tracking technologies to operate the platform effectively and to improve the user experience. Cookies are small text files placed on your device when you visit the site. They do not contain personally identifying information on their own, but when combined with your account information, they help us recognise you and personalise your experience.

6.1 Types of Cookies Used

• Essential cookies: Required for the platform to function. These include session cookies that maintain your logged-in state and security cookies that protect against CSRF attacks. These cannot be disabled without impairing platform functionality.
• Functional cookies: Store your preferences such as language settings, display preferences, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymised or pseudonymous data about how players navigate and use the platform. This data is used internally to identify and fix performance issues and improve the overall experience.
• Marketing cookies: Used only where you have provided consent, to help us understand the effectiveness of our promotional campaigns. No third-party advertising networks are given access to 99club player data.

6.2 Managing Cookies

You may manage or disable non-essential cookies through your browser settings or via the cookie preference centre available on the platform. Please note that disabling certain cookies may affect the functionality of the platform.

99club retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by law or our gaming licence.

When the applicable retention period expires, 99club will securely delete or anonymise personal data so that it can no longer be associated with an identifiable individual.

99club implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption in transit: All data transmitted between your device and 99club servers is encrypted using TLS (Transport Layer Security) with a minimum of TLS 1.2.
• Encryption at rest: Sensitive data fields, including identity documents and financial information, are encrypted in our database using AES-256 or equivalent standards.
• Password hashing: Account passwords are stored using bcrypt or equivalent one-way hashing algorithms. 99club staff cannot read your password — only you know it.
• Access controls: Access to personal data within 99club is restricted on a strict need-to-know basis. Staff who handle personal data receive regular data protection training.
• Two-factor authentication (2FA): Available to all account holders via SMS OTP. We strongly encourage all Pakistani players to enable 2FA to protect their account.
• Regular security assessments: 99club conducts periodic vulnerability assessments and penetration testing to identify and remediate security weaknesses.

In the event of a personal data breach that poses a risk to your rights and freedoms, 99club will notify affected individuals and relevant authorities in accordance with applicable data breach notification obligations.

As a 99club player, you hold the following rights in respect of your personal data. These rights can be exercised by contacting our support team with a clear description of your request. We aim to respond to all data rights requests within 30 days.

• Right of access: You may request a copy of the personal data we hold about you, together with an explanation of how it is being used.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold. For registered players, many details can be updated directly through your account settings.
• Right to erasure: In certain circumstances, you may request deletion of your personal data. Note that this right is subject to legal retention obligations — we cannot delete data that we are required to retain under our gaming licence or applicable law.
• Right to restriction: You may request that we restrict processing of your data in specific circumstances, such as while a dispute is being resolved.
• Right to data portability: Where processing is based on your consent or on a contractual basis, you may request a copy of your personal data in a structured, machine-readable format.
• Right to object: You may object to processing based on legitimate interests, including direct marketing. Where you object to marketing, we will stop processing your data for that purpose immediately.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

99club operates a strict 21+ age policy. The platform is not directed at, and does not knowingly collect personal data from, individuals under the age of 21. Age is verified at the point of registration and again before any withdrawal is processed.

If 99club discovers that personal data has been collected from an individual who is under 21 years of age, that account will be closed immediately, all activity will be voided, and the data will be deleted to the extent permitted by our legal obligations. Any real-money deposits made by an underage individual will be returned to the payment source following investigation.

99club is operated under an international gaming licence and its infrastructure may involve servers located in multiple jurisdictions. As a result, your personal data may be transferred to and processed in countries outside Pakistan. Where such transfers occur, 99club ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses with service providers that require them to maintain equivalent data protection standards.
• Processing only in jurisdictions that provide an adequate level of data protection as assessed by our data governance team.
• Restricting cross-border data transfers to the minimum necessary for the specific service being provided.

By using the 99club platform, you acknowledge and consent to the transfer of your personal data internationally in accordance with the safeguards described in this policy.

99club reserves the right to update or revise this Privacy Policy from time to time to reflect changes in our data practices, applicable laws, or the services we offer. When material changes are made, we will notify registered players by email or via an in-account notification prior to the changes taking effect. The updated policy will always be published on this page with a revised effective date.

Your continued use of the 99club platform after any update to this policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should cease using the platform and request account closure.

If you have any questions, concerns, or complaints about how 99club handles your personal data, or if you wish to exercise any of your data rights, please contact us through the following channels:

• Email: support@99club.pro
• Live Chat: Available 24/7 inside your account dashboard after login.
• Subject Line: Use "Privacy Enquiry" or "Data Rights Request" to ensure prompt routing to our data team.

We aim to resolve all privacy-related enquiries within 30 days of receipt. If you are not satisfied with our response to a complaint, you may escalate the matter to the relevant data protection supervisory authority or regulatory body in your jurisdiction.