Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how 92pjr ("the Platform", "we", "us" or "our") collects, processes, stores and protects personal data submitted by users ("you", "your") of the 92pjr online gaming platform, accessible at https://92pjr.cam. The Platform is an English-language service designed for Pakistani players offering cricket betting, PSL and ICC tournament markets, live casino, slots, table games, instant games and esports.

We are committed to handling personal data responsibly, transparently and in line with internationally recognised data protection principles. This Policy sets out your rights and our obligations in plain, accessible English — because you deserve to understand exactly how your information is used, not just that it is collected.

This Policy should be read in conjunction with the Terms & Conditions and the Responsible Gambling policy, which together form the full agreement governing your use of 92pjr.

Definitions

For the purposes of this Policy:

• "Personal Data" — any information that identifies or could identify a natural person, directly or indirectly, including name, email address, date of birth, IP address and payment details.
• "Processing" — any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, erasure and destruction.
• "Data Controller" — 92pjr, as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" — a third party that processes Personal Data on behalf of 92pjr under a contractual arrangement, such as a KYC provider or payment processor.
• "Consent" — a freely given, specific, informed and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "Sensitive Data" — a subset of Personal Data that warrants additional protection, such as identification document details collected during KYC.
• "Cookie" — a small text file placed on your device by the Platform to enable certain functions and collect anonymous usage data.

Personal Data We Collect

92pjr collects only the Personal Data that is necessary for the purposes described in Section 05. The categories of data we may collect include:

We do not collect full payment card numbers. Payment card data is handled exclusively by PCI-DSS-compliant payment processors — 92pjr only receives masked card identifiers and transaction references.

How We Collect Personal Data

92pjr collects Personal Data through three principal channels:

• Directly from you: when you complete the registration form, submit KYC documents, make a deposit, contact support, respond to a survey, or interact with any other input feature on the Platform.
• Automatically: through cookies, web beacons, server logs and similar tracking technologies that record Technical Data and Usage Data as you interact with the Platform. See Section 09 (Cookies) for full details.
• From third parties: licensed KYC and identity-verification providers may supply verified identity data; fraud-prevention services may flag risk signals; payment processors may confirm transaction status. All third-party data providers are contractually bound to share data only as permitted by applicable law.

Purpose of Processing & Legal Basis

Every processing activity at 92pjr is carried out for a specific, documented purpose. The table below sets out those purposes and the legal basis under which we rely on them:

• Account creation and management — necessary to perform the contract between you and 92pjr.
• Identity verification (KYC) — legal obligation under anti-money-laundering and licence conditions.
• Processing deposits and withdrawals — necessary to perform the contract; legal obligation for AML record-keeping.
• Fraud detection and security monitoring — legitimate interest in protecting the Platform and its users from financial crime.
• Responsible gambling compliance — legal obligation; also legitimate interest in protecting vulnerable users.
• Customer support — necessary to perform the contract; legitimate interest in resolving disputes.
• Service personalisation and improvement — legitimate interest in delivering a relevant user experience.
• Marketing communications — your consent, where explicitly given. You may withdraw consent at any time.
• Regulatory reporting — legal obligation under applicable licence jurisdiction requirements.
• Legal claims — legitimate interest in establishing, exercising or defending legal claims.

We do not use your Personal Data for automated decision-making that produces legal or similarly significant effects without human oversight, except in fraud-prevention contexts where automated flags are always reviewed by a human analyst before account action is taken.

Data Sharing & Third Parties

92pjr does not sell, rent or trade your Personal Data. We share data only in the following circumstances and with the following categories of recipients:

• KYC and identity verification providers: to validate your identity and fulfil anti-money-laundering obligations. These providers process data under strict contractual and regulatory constraints.
• Payment processors: to facilitate deposits and withdrawals. Payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are mentioned for local familiarity only; actual payment processing is performed by the processors active in your cashier, which hold their own data-processing obligations.
• Game software providers: game studios providing casino, instant game and esports content may receive session-level identifiers to enable gameplay. They do not receive full identity data.
• Fraud prevention and security services: aggregated risk signals may be shared with specialist fraud-detection platforms to protect the Platform and its user community.
• Regulatory and licensing authorities: we may be required by law or licence condition to disclose user data to competent regulatory bodies.
• Law enforcement: we will comply with valid legal requests from law enforcement agencies in the jurisdiction of our licensing authority.
• Professional advisors: legal counsel, auditors and insurers may access relevant Personal Data under obligations of confidentiality.

Data Retention

92pjr retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and licence obligations. The following general retention periods apply:

• Active account data: retained for the lifetime of the account and for a minimum of five (5) years following account closure, in line with standard AML record-keeping requirements.
• KYC documents: retained for the period required by the licensing authority — typically five (5) years from the date of the last transaction or account closure, whichever is later.
• Financial transaction records: retained for a minimum of five (5) years from the date of each transaction.
• Support correspondence: retained for three (3) years from the date of resolution, unless related to an active dispute.
• Marketing consent records: retained for the duration of the consent period plus three (3) years to demonstrate compliance.
• Technical and usage logs: typically retained for thirteen (13) months in rolling format for fraud analysis and platform improvement.

After applicable retention periods expire, Personal Data is securely deleted or anonymised. Anonymised, aggregated data (from which no individual can be identified) may be retained indefinitely for statistical analysis.

Security Measures

92pjr implements technical and organisational security measures proportionate to the risk associated with processing your Personal Data. These include:

• Transport Layer Security (TLS): all data in transit is encrypted using current-generation TLS protocols.
• Encryption at rest: Personal Data stored on 92pjr servers is encrypted using AES-256 or equivalent standards.
• Access controls: internal access to Personal Data is restricted on a strict need-to-know basis. All staff with data access undergo background screening and data-protection training.
• Multi-factor authentication: sensitive internal systems are protected by MFA to prevent unauthorised staff access.
• Penetration testing: the Platform undergoes periodic security assessments by independent specialists.
• Incident response: 92pjr maintains a documented data-breach response procedure. In the event of a breach that poses a high risk to your rights and freedoms, we will notify affected users promptly.

While we take every reasonable precaution, no internet-connected service can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for logging out of shared devices.

Cookies & Tracking Technologies

92pjr uses cookies and similar technologies (web beacons, local storage) to enable core Platform functionality, remember your preferences and collect anonymised usage analytics. The categories of cookies in use are:

• Strictly Necessary Cookies: essential for the Platform to function — including session management, authentication tokens and security features. These cannot be disabled without impairing your ability to use the site.
• Functional Cookies: remember your preferences such as language, display settings and responsible gambling tool configurations.
• Analytics Cookies: collect anonymised data on how users interact with the Platform (pages visited, session length, click paths) to help us improve the service. No personally identifying data is included in analytics reports.
• Fraud Prevention Cookies: assist in identifying suspicious behaviour patterns, protecting your account and the Platform from fraudulent activity.

Most browsers allow you to manage or delete cookies through their settings. Disabling strictly necessary cookies will affect Platform functionality. For analytics cookies, continued use of the Platform following notice of their use constitutes implied consent; you may opt out by adjusting browser settings.

Your Data Rights

Subject to applicable law and the licence jurisdiction's data protection framework, you hold the following rights over your Personal Data held by 92pjr:

To exercise any of the above rights, contact the support team using the details in Section 15. We will respond within 30 days of receiving a valid request. In some cases, we may need to verify your identity before processing the request, to prevent unauthorised access to another person's data.

Note that certain rights may be limited where processing is required by law — for example, AML record-keeping obligations override erasure requests for transaction data within statutory retention periods.

Minors

Parents and guardians in Pakistan and other jurisdictions are encouraged to use parental control software and internet filtering tools to prevent minors from accessing online gambling platforms. Local laws may also impose additional obligations on operators and users regarding minor protection.

International Data Transfers

92pjr operates globally and may transfer Personal Data to servers or Data Processors located outside Pakistan. Where such transfers occur, we ensure appropriate safeguards are in place to protect your data to a standard equivalent to or higher than those described in this Policy.

• Transfers to KYC providers, payment processors and game studios may involve cross-border data flows to jurisdictions where those service providers are headquartered or where their servers are located.
• All international transfers are covered by contractual arrangements that require the recipient to maintain data protection standards consistent with this Policy.
• 92pjr does not transfer Personal Data to jurisdictions that lack adequate data protection frameworks without specific contractual safeguards in place.

Marketing Communications

Where you have provided explicit consent, 92pjr may send you promotional communications about bonuses, new games, sporting events (including Pakistan cricket fixtures, PSL matches, ICC tournaments and other sports) and Platform updates. These communications may be delivered by email or in-platform notification.

• Marketing consent is collected at registration and is entirely optional — declining marketing has no impact on your account or gameplay access.
• You may withdraw marketing consent at any time by updating your preferences in the account dashboard or by following the unsubscribe link included in every marketing email.
• Withdrawal of marketing consent does not affect the lawfulness of processing that occurred before withdrawal.
• Transactional communications — such as deposit confirmations, withdrawal notifications and security alerts — are not marketing and cannot be opted out of while your account is active.
• Accounts that have activated self-exclusion or a cooling-off period will have all marketing communications suppressed for the duration of the restriction.

Policy Amendments

92pjr reserves the right to update this Privacy Policy at any time. Material changes — such as new categories of data collected, new purposes, or new third-party recipients — will be communicated to registered users via a Platform notification or email before the changes take effect.

Minor clarifications and non-material edits may be made without specific notice, though the "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this Policy periodically to stay informed about how your Personal Data is handled.

Continued use of the Platform after a notified amendment constitutes acceptance of the revised Policy. If you do not accept the amended Policy, you must cease using the Platform and may request account closure per the Terms & Conditions.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how 92pjr has handled your Personal Data, please contact our support team. We aim to acknowledge all privacy-related queries within 48 hours and to resolve them fully within 30 days.

If you are not satisfied with our response to a privacy concern, you may have the right to lodge a complaint with the relevant data protection authority in the jurisdiction of our licensing authority. Details of the applicable authority will be provided upon request.