Privacy Policy — 92paj Platform

This Privacy Policy applies to all personal data processed by 92paj in connection with the operation of the 92paj online casino and sports betting platform, accessible at 92paj.net. It covers data collected through the website, the mobile-optimised interface, customer support communications, and any other channel through which members interact with 92paj.

This policy applies to all registered members of 92paj, including players from Karachi, Lahore, Islamabad, Faisalabad and all other cities across Pakistan. It also applies to any individual who visits the 92paj website without registering an account, to the extent that data is passively collected during that visit via cookies and analytics tools.

This Privacy Policy should be read alongside the 92paj Terms & Conditions and the Responsible Gaming Policy, both of which are incorporated by reference into the overall agreement governing your relationship with 92paj.

For the purposes of this Privacy Policy, 92paj acts as the data controller in respect of the personal data of all members and site visitors. As data controller, 92paj determines the purposes for which your personal data is processed and the means by which that processing takes place.

92paj operates under applicable international gaming licensing standards. Where 92paj engages third-party service providers to process data on its behalf — such as payment processors, identity verification providers, or analytics platforms — those providers act as data processors under the direction of 92paj and are contractually bound to process personal data only for the purposes instructed by 92paj and to maintain appropriate security standards.

If you have any questions, concerns or requests relating to the processing of your personal data, please contact the 92paj data team at [email protected]. All privacy-related enquiries will be acknowledged within 3 business days.

92paj collects only the personal data that is necessary for the purposes set out in this Privacy Policy. The categories of personal data we collect include the following:

Identity & Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (required to verify that you meet the 21+ age requirement);
• Residential address, including city and province;
• Email address;
• Mobile phone number (used for account verification and 2FA).

Identity Verification Data

• Copies of government-issued identification documents (CNIC, passport);
• Proof of address documentation where requested;
• Selfie or liveness check images where required by our verification provider;
• Source of funds documentation where required under anti-money laundering obligations.

Financial & Transaction Data

• Deposit and withdrawal transaction history;
• Payment method details (JazzCash account reference, EasyPaisa number, bank account details, USDT wallet address — as applicable);
• Account balance history and bonus credit records.

Gaming Activity Data

• Betting history across all products including slots, Mahjong Ways, Mahjong Ways 2, cricket betting and live casino;
• Session duration and frequency of play;
• Responsible gaming tool usage (deposit limits, self-exclusion elections);
• Game preferences and interaction patterns.

Technical & Device Data

• IP address and approximate geographic location derived therefrom;
• Device type, operating system, and browser type;
• Unique device identifiers;
• Login timestamps and session duration data.

Communications Data

• Records of live chat conversations with the 92paj support team;
• Email correspondence with 92paj customer support or compliance teams;
• Feedback and survey responses where submitted voluntarily.

92paj collects personal data through the following channels:

• Registration: When you create a 92paj account, you directly provide identity and contact information through the registration form;
• Account use: Transaction data and gaming activity data are generated automatically as you use the platform;
• Verification processes: Identity documents are collected when you submit them as part of KYC (Know Your Customer) verification;
• Payment processing: Financial data is collected when you make a deposit or withdrawal via the 92paj cashier;
• Customer support: Communications data is created when you contact the 92paj support team through any channel;
• Cookies and tracking technologies: Technical data is collected automatically when you visit 92paj.net, as described in the Cookies section below;
• Third-party verification providers: Where 92paj uses third-party identity verification services, those providers may supply verification outcomes and associated data to 92paj.

92paj processes your personal data for the following specific purposes:

92paj relies on the following legal bases when processing your personal data:

• Contractual necessity: Processing required to perform the contract between you and 92paj — including account management, payment processing and provision of gaming services;
• Legal obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money laundering checks, age verification, and record-keeping requirements;
• Legitimate interests: Processing necessary for 92paj's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring and product improvement — provided those interests are not overridden by your rights;
• Consent: Where 92paj seeks your consent before processing — for example, sending marketing communications or using non-essential cookies — we will obtain that consent explicitly. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

92paj does not sell your personal data to unaffiliated third parties for their own marketing purposes. We share personal data only in the following circumstances and with the following categories of recipients:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank and other payment service providers receive the financial data necessary to process your transactions;
• Identity verification providers: Third-party KYC and AML compliance service providers receive identity and document data to conduct verification checks on our behalf;
• Technology and hosting providers: Cloud hosting and infrastructure providers who store and process data on 92paj's behalf under contractual data processing agreements;
• Regulatory and law enforcement authorities: Where 92paj is required by applicable law, court order or regulatory directive to disclose personal data, we will do so. Where permitted, we will notify you of such disclosure;
• Fraud prevention organisations: Where data must be shared to prevent or detect financial crime or fraud affecting the platform or its members;
• Business transfers: In the event of a merger, acquisition or sale of all or part of the 92paj business, member data may be transferred to the successor entity, subject to the same data protection standards.

92paj retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of active membership and for a minimum of five (5) years following account closure, in accordance with AML record-keeping obligations;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming activity records: Retained for the duration of active membership and for three (3) years following account closure;
• Communications data: Support chat and email records retained for three (3) years;
• Technical and device data: Retained for up to twelve (12) months from collection, except where required for longer retention in connection with a specific fraud or security investigation.

When personal data is no longer required for any of the above purposes and no legal obligation requires its continued retention, 92paj will securely delete or anonymise it in accordance with our internal data lifecycle policy.

92paj implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 92paj platform;
• Encrypted storage of sensitive data, including payment method details and identity documents, at rest;
• Role-based access controls ensuring that only authorised 92paj personnel with a legitimate operational need can access member personal data;
• Two-factor authentication options for member accounts to reduce the risk of unauthorised login;
• Regular security audits and penetration testing of the 92paj platform infrastructure;
• Incident response procedures to detect, assess and notify in the event of a personal data breach.

92paj uses cookies and similar tracking technologies on the 92paj.net website to provide a functional, personalised and secure experience. A cookie is a small text file placed on your device when you visit a website. The following categories of cookies are used on the 92paj platform:

• Strictly necessary cookies: Essential for the platform to function. These include session management cookies that keep you logged in and security cookies. These cannot be disabled without breaking core functionality;
• Functional cookies: Remember your preferences such as language selection, lobby layout and recent game history to provide a more personalised experience;
• Analytics cookies: Allow 92paj to understand how members use the platform — which games are most popular, how users navigate the lobby, and where technical issues occur — so we can improve the service;
• Marketing cookies (with consent only): Used to serve relevant promotional content based on your interests and activity on the platform. These are only set where you have provided explicit consent.

You can manage your cookie preferences at any time through your browser settings or, where applicable, through the cookie preference centre available on the 92paj platform. Please note that disabling certain cookies may affect the functionality of the platform.

As a 92paj member, you have a range of rights in respect of your personal data. 92paj is committed to honoring these rights promptly and without undue friction. To exercise any of the rights listed below, please contact us at [email protected] with the subject line "Data Rights Request".

92paj will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further two months, in which case we will notify you within the initial 30-day period and explain the reason for the extension.

Age verification is conducted at registration and may be repeated at the withdrawal stage or at any other point during your membership. 92paj uses a combination of self-declaration, document verification and third-party identity verification services to enforce the 21+ age requirement across all accounts. Parents and guardians who believe a minor may have accessed the 92paj platform using false information are encouraged to contact us immediately at [email protected].

As 92paj operates an internationally licensed gaming platform, some personal data may be transferred to, stored, or processed in jurisdictions outside Pakistan. Where such transfers occur, 92paj ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that described in this Privacy Policy.

Safeguards for international transfers may include contractual clauses that bind recipient organisations to the same data protection standards applicable under 92paj's privacy framework, or transfers to jurisdictions that maintain recognised adequate levels of data protection. By using the 92paj platform, you acknowledge and consent to the transfer of your personal data on the basis described in this section.

92paj reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal obligations, or the services we offer. Where changes are material, 92paj will notify registered members by email or via a prominent notice on the platform at least seven (7) days before the updated policy takes effect.

For minor or administrative updates, the revised policy will be published on this page with an updated effective date. Your continued use of the 92paj platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed of how 92paj handles your personal data.

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by 92paj, please do not hesitate to get in touch. Our dedicated privacy and support team is available around the clock to assist you.