Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 92bat ("92bat", "we", "us", "our") collects, processes, stores and protects personal data relating to individuals ("User", "you", "your") who access or use the 92bat platform available at 92bat.cam and all associated services (collectively, the "Platform").

92bat is committed to handling personal data responsibly and in a manner consistent with applicable data protection principles. This Policy is designed to give you a clear, honest account of our data practices so you can make informed decisions about your use of the Platform.

By registering an account, making a deposit or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data processing activities described herein, to the extent that consent is the applicable legal basis for such processing.

2 Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, financial account details and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means the legal entity that determines the purposes and means of processing personal data — in this case, the Operator of the 92bat Platform.
• "Data Processor" means any third party that processes personal data on behalf of the Data Controller under a contractual arrangement.
• "KYC" means Know Your Customer — the identity verification process conducted in accordance with applicable anti-money laundering obligations.
• "Cookies" means small text files stored on your device by the Platform to facilitate session management, security and analytics.
• "Special Category Data" means sensitive personal data including health information, which may be relevant in the context of responsible gambling self-exclusion programmes.

3 Data We Collect

We collect the following categories of personal data in connection with your use of the Platform:

3.1 Identity and Contact Data

• Full legal name and any previous names
• Date of birth and nationality
• Residential address, including city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar) and postal code
• Email address and telephone number
• Government-issued identification numbers (national ID, passport number)

3.2 Financial Data

• Deposit and withdrawal transaction records
• Payment method details (masked card numbers, mobile wallet identifiers used as contextual references — e.g., account-holder names associated with Easypaisa, JazzCash or Raast)
• Account balance history and wagering records
• Source of funds documentation where required for AML compliance

3.3 Technical and Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system and browser version
• Session duration, page interaction logs and clickstream data
• Login timestamps and authentication event logs

3.4 Responsible Gambling Data

• Self-exclusion requests and status
• Deposit, loss and time limits set by the user
• Responsible gambling assessment responses where voluntarily provided

4 How We Collect Data

We collect personal data through the following channels:

5 Legal Basis for Processing

We process your personal data under one or more of the following legal bases:

• Contractual necessity: Processing required to open and maintain your account, process deposits and withdrawals, settle bets and provide platform services.
• Legal obligation: Processing required to fulfil AML, KYC and other regulatory obligations imposed on the Operator under applicable licensing conditions.
• Legitimate interests: Processing conducted to detect fraud, protect platform security, prevent money laundering and improve service quality, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and certain cookie categories, where you have given explicit consent that may be withdrawn at any time without detriment to your account standing.
• Vital interests: In limited circumstances, processing related to responsible gambling interventions where there is a credible risk to health or safety.

6 How We Use Your Data

92bat uses the personal data we collect for the following purposes:

• Creating, verifying and managing your account on the Platform
• Processing deposits, wagers, withdrawals and related financial transactions
• Conducting KYC and ongoing AML monitoring as required by the applicable licence
• Detecting, investigating and preventing fraud, account abuse and prohibited conduct
• Administering bonus and promotional offers in accordance with applicable terms
• Providing customer support and responding to queries and complaints
• Enforcing responsible gambling tools including self-exclusion and spending limits
• Sending transactional communications such as deposit confirmations and withdrawal notifications
• Sending marketing communications where you have given consent, including information about promotions relevant to cricket, PSL/T20 season events, football and other sports markets
• Analysing platform usage in aggregate to improve performance, navigation and product offerings
• Complying with applicable legal, regulatory and licensing obligations

7 Data Sharing & Disclosure

92bat does not sell your personal data. We may share your data with third parties only in the circumstances described below:

7.1 Service Providers and Data Processors

We engage third-party service providers who process data on our behalf under strict contractual data processing agreements. These include identity verification providers, payment processing intermediaries, fraud detection services, cloud hosting providers and customer support platform operators.

7.2 Regulatory and Legal Authorities

We may disclose personal data to licensing authorities, law enforcement bodies, financial intelligence units or courts where we are legally required or compelled to do so. Such disclosures are made to the minimum extent necessary to satisfy the applicable obligation.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of the 92bat business, personal data held by us may be transferred to the acquiring entity as part of that transaction. We will notify affected users of any such transfer where reasonably practicable.

7.4 With Your Consent

We may share your data with third parties in other circumstances where you have given explicit prior consent to that specific disclosure.

8 International Data Transfers

As a platform serving users across multiple jurisdictions, including Pakistan, personal data collected by 92bat may be transferred to and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from those of your jurisdiction.

Where such transfers occur, 92bat ensures that appropriate safeguards are in place — such as standard contractual clauses or equivalent data transfer mechanisms — to protect your data to a standard consistent with this Policy.

By using the Platform, you acknowledge and consent to the transfer of your data to jurisdictions outside Pakistan for the purposes described in this Policy.

9 Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory and licensing obligations. The following indicative retention periods apply:

Upon expiry of the applicable retention period, data is securely deleted or permanently anonymised so that it can no longer be attributed to you.

10 Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the Platform
• Encryption of sensitive data fields at rest using industry-standard algorithms
• Role-based access controls limiting internal access to personal data to authorised personnel only
• Multi-factor authentication requirements for administrative platform access
• Regular security assessments and penetration testing
• Incident response procedures including breach notification protocols

While we take all reasonable steps to protect your data, no method of internet transmission or electronic storage is entirely infallible. You are responsible for maintaining the security of your own account credentials and for notifying us promptly of any suspected unauthorised access.

11 Cookies & Tracking Technologies

92bat uses cookies and similar tracking technologies to support the operation, security and improvement of the Platform. The categories of cookies we deploy are as follows:

You may manage or withdraw consent for non-essential cookies at any time via your browser settings or the Platform's cookie preference centre. Disabling strictly necessary cookies may impair your ability to use the Platform.

12 Your Rights

Subject to applicable data protection law and our legal retention obligations, you have the following rights in relation to your personal data held by 92bat:

• Right of Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our overriding legal retention obligations.
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, for example while the accuracy of data is disputed.
• Right to Data Portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests. You may withdraw marketing consent at any time without affecting your account status.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact our support team using the details in Section 16. We will acknowledge your request within 10 business days and provide a substantive response within 30 calendar days, or notify you if an extension is required.

13 Minors & Age Verification

The 92bat Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator licence jurisdiction. We do not knowingly collect personal data from individuals under the applicable minimum age.

Age verification is conducted as part of the KYC process for all new account registrations. Where we become aware that personal data has been collected from a person below the minimum age, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor in your care has registered an account on the Platform, please contact us immediately at the details provided in Section 16.

14 Third-Party Services

The Platform may reference third-party services in an informational context — for example, familiar payment methods commonly used in Pakistan such as Easypaisa, JazzCash and Raast, or banking institutions such as HBL, UBL, Meezan Bank and Bank Alfalah. These references are provided for contextual familiarity only and do not constitute partnerships, endorsements or representations that these providers support gambling transactions.

Any third-party service providers engaged as data processors by 92bat are bound by contractual data processing agreements that require them to process personal data only on our documented instructions and to maintain appropriate security standards.

This Policy does not apply to the privacy practices of third-party websites or services that may be referenced in an informational context. Users should review the privacy policies of any third-party service independently.

15 Policy Amendments

92bat reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or Platform functionality. Where changes are material, we will provide reasonable advance notice via a prominent notice on the Platform or by email to your registered address.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Policy periodically.

16 Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how your personal data is being handled, please contact our support team. All data rights requests and formal privacy complaints must be submitted in writing.