Privacy Policy of 99av

01 Introduction

99av ("we", "us", "our", "the Company", "the Platform") is committed to protecting the privacy and personal data of all individuals who use the 99av website at https://99av.bio and all related services, features, and functionality offered through the platform. This Privacy Policy ("Policy") has been prepared in accordance with internationally recognised data protection principles and sets out in clear, transparent terms how we handle your personal information.

This Policy applies to all current and former registered players, visitors who browse the 99av website without registering, and any individual whose personal data is processed by 99av in connection with the operation of its platform and services. By accessing or using the 99av platform, you confirm that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of the binding agreement between you and 99av.

02 Data Controller

For the purposes of applicable data protection legislation, 99av acts as the data controller in respect of the personal data it collects and processes about you. As data controller, 99av determines the purposes for which, and the manner in which, your personal data is processed.

If you have any questions about this Policy, wish to exercise any of your data protection rights, or wish to make a complaint regarding our handling of your personal data, please contact our dedicated Data Protection team:

03 Data We Collect

99av collects and processes the following categories of personal data about you, depending on the nature of your interaction with the platform:

04 How We Collect Data

99av collects personal data through the following means:

• Direct collection: Information you provide when creating an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the 99av platform, including via cookies, web beacons, and server log files.
• Third-party sources: Identity verification data from KYC service providers; fraud intelligence from payment processing partners; publicly available information used for AML screening purposes.
• Payment providers: Transaction confirmation and status data from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other integrated payment processors.

We only collect personal data that is necessary for a specified, explicit, and legitimate purpose. We do not collect personal data beyond what is reasonably required to operate the 99av platform safely and in compliance with our legal obligations.

05 How We Use Your Data

99av processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your 99av player account, including password resets, login verification, and profile updates.
• Identity and age verification: Confirming that you are who you claim to be and that you meet the minimum age requirement of 21 years. This is a legal obligation and a condition of access to the 99av platform.
• Payment processing: Executing deposits and withdrawals in PKR through your chosen payment method, and maintaining accurate transaction records.
• Platform operation and personalisation: Delivering the games, betting markets, and features you use, and tailoring your experience based on your preferences and activity history.
• Responsible gaming: Monitoring your gaming behaviour to identify signs of problem gambling, applying limits you have set, processing self-exclusion requests, and complying with responsible gaming obligations.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, money laundering, multi-accounting, bonus abuse, and other prohibited conduct.
• Legal and regulatory compliance: Meeting our obligations under applicable anti-money laundering (AML) legislation, international gaming regulations, and the requirements of our licensing authority.
• Marketing communications: Sending you promotional offers, bonus notifications, and product updates — but only where you have opted in to receive such communications. You may withdraw your marketing consent at any time by contacting [email protected].
• Customer support: Responding to your enquiries, resolving disputes, and improving the quality of our support services.
• Analytics and improvement: Analysing aggregated usage data to understand how players interact with the platform and to improve our games, features, and user experience.

06 Legal Basis for Processing

99av processes your personal data on the following legal bases under applicable data protection law:

• Contractual necessity: Processing required to perform our contract with you — including account creation, payment processing, game delivery, and dispute resolution.
• Legal obligation: Processing required to comply with AML laws, KYC regulations, age verification requirements, and the directives of our licensing authority.
• Legitimate interests: Processing necessary for our legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — provided these interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent (such as for marketing communications or the use of non-essential cookies), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Sharing Your Data

99av does not sell your personal data to any third party. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate confidentiality and data protection obligations:

• KYC and identity verification providers: Third-party service providers who verify your identity documents and confirm your eligibility to use the platform.
• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other integrated payment service providers, solely to process your financial transactions.
• Fraud prevention and AML screening services: Specialist providers who help us identify and prevent fraudulent transactions and money laundering activity.
• IT and platform service providers: Cloud hosting, cybersecurity, and technical support vendors who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Where we are required by law or a court order to disclose your personal data, or where disclosure is necessary to prevent or investigate a serious crime.
• Gaming licensing authority: Our international licensing authority may require access to certain player records as part of its regulatory oversight function.

08 Cookies & Tracking Technologies

99av uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files placed on your device when you access the 99av website. We use the following categories of cookies:

• Strictly necessary cookies: Essential to the operation of the platform, including session management, login authentication, and security functions. These cannot be disabled without impairing your ability to use the site.
• Functional cookies: Remember your preferences and settings (such as language preference and display settings) to personalise your experience.
• Analytics cookies: Collect anonymised or aggregated data about how players use the platform, helping us understand usage patterns and improve performance.
• Marketing cookies: Used (with your consent) to deliver relevant promotional content based on your interests and activity on the 99av platform.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 99av platform. A detailed Cookie Policy is available on request from [email protected].

09 Data Retention

99av retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. Our standard retention periods are as follows:

• Active account data: Retained for the duration of your account's active status plus five (5) years following account closure, in accordance with AML and gaming regulatory requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by international AML standards.
• KYC and identity documents: Retained for five (5) years following the end of the business relationship, or longer if required by applicable law.
• Support and communications records: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained for as long as you remain opted in, plus one (1) year following opt-out for compliance audit purposes.

Once the applicable retention period has expired, your personal data is securely deleted or anonymised so that it can no longer be associated with you as an individual.

10 Your Rights

Subject to applicable data protection law, you have the following rights in relation to your personal data held by 99av. You may exercise any of these rights at any time by contacting us at [email protected]:

We will respond to all valid data rights requests within 30 days of receipt. Where a request is complex or we receive a high volume of requests, we may extend this period by a further two months, in which case we will notify you of the extension and the reason for it.

11 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 99av platform.
• Encryption at rest for all sensitive personal and financial data stored on our servers.
• Role-based access controls ensuring that only authorised 99av personnel with a legitimate operational need can access your personal data.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• Multi-factor authentication for administrative access to systems containing personal data.
• Incident response procedures ensuring prompt detection, containment, and notification in the event of a personal data breach.

Notwithstanding the above measures, no data transmission over the internet or electronic storage system can be guaranteed as 100% secure. We therefore encourage all players to take responsibility for their own account security by using a strong, unique password and logging out after each session.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, 99av will notify you without undue delay and provide guidance on the steps you should take to protect yourself.

12 International Data Transfers

As an internationally licensed gaming platform, 99av may transfer your personal data to, and process it in, countries outside of your home jurisdiction. Some of these countries may not provide a level of data protection equivalent to that in your own country.

Where 99av transfers personal data internationally, we ensure that appropriate safeguards are in place to protect your data, including:

• Transfers to countries recognised as providing an adequate level of data protection.
• Use of Standard Contractual Clauses (SCCs) or equivalent contractual protections with data recipients.
• Binding Corporate Rules or equivalent intra-group data transfer mechanisms where applicable.

You may request further information about the specific safeguards applied to international transfers of your personal data by contacting us at [email protected].

13 Children & Minors

The 99av platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from any person under the age of 21. If you are under 21 years of age, you are prohibited from registering an account, accessing the platform, or providing any personal information to 99av.

If 99av becomes aware that personal data has been collected from an individual under the age of 21 without parental or guardian consent, we will take immediate steps to delete that data and close the associated account. Parents and guardians who believe their child may have accessed the 99av platform are encouraged to contact us immediately at [email protected].

14 Third-Party Links

The 99av platform may contain references or links to third-party websites or services that are not operated by us. This Privacy Policy applies solely to data collected and processed by 99av. We have no control over and assume no responsibility for the privacy practices or content of any third-party websites.

We strongly recommend that you review the privacy policy of any third-party website you visit. The inclusion of any reference to a third-party service on the 99av platform does not constitute an endorsement of that third party's privacy practices.

15 Changes to This Policy

99av reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the structure of our business. The "Last Updated" date at the top of this document will always indicate when the most recent revision was made.

Where changes to this Policy are material — meaning they significantly affect the way in which we process your personal data or the rights available to you — we will notify you by email to your registered address or by a prominent notice on the 99av platform prior to the changes taking effect.

16 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which 99av handles your personal data, please do not hesitate to get in touch with our Data Protection team. All enquiries are handled in English and responded to within the applicable statutory timeframe.

Email: [email protected] (plain text — not a clickable link)

For data rights requests, please include the subject line "DATA PROTECTION REQUEST" along with your registered account email address and a description of your request. For urgent matters relating to suspected data breaches or unauthorised account access, please mark your email "URGENT – DATA SECURITY".

99av is committed to resolving all privacy-related concerns fairly and transparently. If you remain dissatisfied with our response, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.