92r5 Privacy
Policy

1. Introduction

92r5 is an internationally licensed online gaming and sports betting platform serving players across Pakistan, including Karachi, Lahore, Islamabad, Faisalabad, and beyond. The platform operates at 92r5.pro and provides casino games, live dealer tables, slot games, and cricket and PSL sports betting, all denominated in Pakistani Rupees (PKR).

We are committed to protecting the privacy and personal data of every player. This Policy has been drafted to provide you with a clear, honest, and complete account of our data practices. If at any point you have questions about this Policy or about how your personal data is being handled, please contact us via live chat or at [email protected].

2. Data Controller Identity

For the purposes of applicable data protection legislation , 92r5 is the data controller responsible for your personal data collected through the Platform. The Company processes personal data in accordance with the requirements of its international gaming license, applicable data protection law, and the anti-money laundering (AML) and Know Your Customer (KYC) obligations imposed by its licensing authority.

All data protection queries, subject access requests, and formal complaints relating to the processing of your personal data should be directed to the 92r5 Data Protection contact via email at [email protected], clearly marked "Data Protection Query" in the subject line.

3. Personal Data We Collect

The following table summarises the categories of personal data that 92r5 collects from players and the context in which each category is collected:

92r5 does not collect or process special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data for identification purposes) except where a document submitted for identity verification incidentally contains such information, in which case only the data necessary for identity verification is processed and the document is stored securely.

4. How We Collect Your Personal Data

92r5 collects personal data through the following channels:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or submitting responsible gaming requests;
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, server logs, and session tracking technologies;
• Third-party providers: Identity verification and AML screening data received from our KYC service providers; transaction data from JazzCash, EasyPaisa, and banking partners; fraud and risk signals from security service providers;
• Publicly available sources: Publicly available sanctions lists, politically exposed persons (PEP) databases, and adverse media screening tools used as part of our AML compliance programme.

5. Purpose and Legal Basis for Processing

92r5 processes your personal data for the following purposes and on the following legal bases:

• Account registration and management — necessary for the performance of our contract with you as a registered player;
• Identity verification (KYC) — necessary for compliance with our legal obligations under our international gaming license and AML regulations;
• Payment processing — necessary for the performance of our contract with you; and for compliance with financial reporting obligations;
• Fraud prevention and security — necessary for our legitimate interests in protecting the Platform and our players from fraud, money laundering, and unauthorised access;
• Responsible gaming monitoring — necessary for compliance with our licensing obligations and for our legitimate interests in protecting vulnerable players;
• Customer support — necessary for the performance of our contract with you and our legitimate interests in maintaining quality service;
• Platform analytics and improvement — based on our legitimate interests in understanding how Pakistani players use the Platform so we can improve the user experience;
• Marketing communications — based on your consent, where you have opted in to receive promotional emails or SMS messages from 92r5. You may withdraw consent at any time by contacting support;
• Legal and regulatory compliance — necessary for compliance with our legal obligations, including responding to lawful requests from regulatory authorities and law enforcement agencies.

6. Data Sharing and Third-Party Disclosure

92r5 does not sell your personal data to any third party. We share personal data only where necessary, on a strictly need-to-know basis, with the following categories of recipients:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK — solely for the purpose of processing your deposits and withdrawals in PKR;
• Identity verification providers: Third-party KYC and AML screening service providers who assist with verifying your identity and screening against sanctions and PEP lists;
• Gaming software providers: Game studios and live casino operators whose titles are hosted on the 92r5 Platform, where game session data is shared for the purpose of delivering the gaming service;
• Licensing authority: Our international gaming regulator, to whom we are obliged to report player activity data and AML-related information as required by our license conditions;
• Law enforcement and regulators: Where 92r5 is under a legal obligation or court order to disclose personal data to a government authority, law enforcement agency, or regulatory body;
• IT infrastructure and security providers: Cloud hosting, cybersecurity, and fraud detection service providers who process data strictly on 92r5's behalf under binding data processing agreements;
• Professional advisers: Lawyers, auditors, and accountants, where disclosure is necessary for legitimate professional advisory purposes and is subject to professional confidentiality obligations.

All third-party service providers who process personal data on 92r5's behalf are required to maintain appropriate technical and organisational security measures and are prohibited from using your personal data for any purpose other than those specified by 92r5.

7. Data Retention

92r5 retains personal data only for as long as is necessary to fulfil the purpose 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 your active account relationship with 92r5, plus a minimum of five (5) years following account closure, to comply with AML record-keeping obligations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AML and financial reporting requirements;
• KYC and verification documents: Retained for the duration of your account relationship plus five (5) years following account closure;
• Customer support communications: Retained for three (3) years from the date of the last interaction;
• Technical and usage data: Retained in identifiable form for up to twelve (12) months, after which it may be retained in anonymised and aggregated form indefinitely for analytics purposes;
• Responsible gaming records: Self-exclusion and problem gambling records are retained for the duration of the exclusion period and for a minimum of five (5) years thereafter, to prevent re-registration by self-excluded players.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 92r5's data destruction procedures.

8. Data Security

92r5 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 92r5's servers;
• AES-256 encryption for personal data and financial records stored at rest in 92r5's databases;
• Multi-factor authentication (MFA) requirements for all 92r5 internal staff accessing systems that hold player data;
• Role-based access controls limiting employee access to personal data strictly to those whose job functions require it;
• Regular penetration testing and vulnerability assessments of the Platform's infrastructure;
• Continuous fraud detection and anomaly monitoring systems that flag unusual account or transaction behaviour in real time;
• Secure, geographically redundant data centre infrastructure with physical access controls.

Despite these measures, no system is entirely immune to security risks. In the event of a data breach that poses a risk to your rights and freedoms, 92r5 will notify affected players and the relevant regulatory authority in accordance with the timelines required by applicable law. You can help protect your own account by using a strong, unique password and enabling any two-factor authentication options offered on the Platform.

9. Your Data Subject Rights

As a data subject, you have the following rights with respect to the personal data that 92r5 holds about you:

• Right of Access: You may request a copy of the personal data 92r5 holds about you, together with information about how it is being processed;
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected or updated. For basic account details, you may be able to update certain information directly within your account settings;
• Right to Erasure: You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected. Note that this right is subject to overriding legal retention obligations, particularly AML record-keeping requirements;
• Right to Restriction of Processing: You may request that 92r5 restrict the processing of your personal data in certain circumstances, such as 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 your consent or on contractual necessity and is carried out by automated means, you may request that your personal data be provided to you in a structured, commonly used, machine-readable format;
• Right to Object: You may object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though 92r5 may be able to demonstrate compelling legitimate grounds that override your objection;
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please contact 92r5 via live chat or send a written request to [email protected] with "Data Subject Request" in the subject line. 92r5 will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing a request to protect your data from unauthorised access.

10. Cookies and Tracking Technologies

92r5 uses cookies and similar technologies (such as local storage and session tokens) on the Platform. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery (CSRF). These cannot be disabled without impairing Platform functionality;
• Functional Cookies: Used to remember your preferences, such as your preferred language, currency display (PKR), and notification settings, to provide a more personalised experience;
• Analytics Cookies: Used to collect anonymised data about how visitors use the Platform — such as which pages are visited most frequently and where users encounter errors — to help 92r5 improve the Platform. All analytics data is aggregated and de-identified before analysis;
• Session Security Cookies: Short-lived cookies used to detect and prevent fraud, account takeover attempts, and suspicious login activity.

92r5 does not use advertising or retargeting cookies, and does not allow third-party advertisers to place cookies on the Platform. You can control cookie settings through your browser preferences. Disabling strictly necessary cookies may affect your ability to log in and use certain features of the Platform.

11. Minors and Age Verification

If 92r5 becomes aware that personal data has been collected from a person under the age of 21, the account will be suspended immediately and all personal data associated with the underage account will be securely deleted in accordance with our data destruction procedures, subject to any mandatory retention obligations that may apply under AML regulations.

Parents and guardians who believe that a minor may have registered on the 92r5 Platform should contact us immediately at [email protected] so that the account can be investigated and closed without delay.

12. International Data Transfers

As an internationally licensed platform, 92r5 may transfer your personal data to countries outside Pakistan for processing by our service providers, including our hosting infrastructure and KYC verification partners. Where such transfers occur, 92r5 ensures that appropriate safeguards are in place to protect your personal data, including contractual data transfer agreements with receiving parties that impose data protection obligations equivalent to those required by applicable law.

92r5 does not transfer personal data to countries or organisations that cannot demonstrate an adequate level of data protection without first putting in place the contractual safeguards described above.

13. Changes to This Privacy Policy

92r5 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, Platform features, or applicable law. When material changes are made, we will notify registered players by email to the address on file and by posting a prominent notice on the Platform. The effective date at the top of this Policy will be updated to reflect the date the revised Policy takes effect.

We encourage you to review this Policy periodically. Your continued use of the Platform following the notification of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the revised Policy, you must cease using the Platform and may request account closure through 92r5 support.

14. Contact and Privacy Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or about 92r5's handling of your personal data, please contact us through any of the following channels:

• Email: [email protected] — please include "Privacy Policy Query" or "Data Protection Complaint" in the subject line;
• Live Chat: Available 24/7 via the chat widget on 92r5.pro;
• Response Time: 92r5 aims to acknowledge all privacy-related queries within 48 hours and to provide a substantive response within 30 days.

If you are not satisfied with 92r5's response to your privacy complaint, you have the right to escalate the matter to the relevant data protection authority or to our licensing authority's dispute resolution mechanism. Details of the applicable regulatory escalation channels are available in the 92r5 Help Centre via live chat.