Privacy Policy — 99fe Platform

This Privacy Policy ("Policy") describes how 99fe ("the Platform", "We", "Us", "Our"), operated at https://99fe.cam, collects, processes, stores, shares and protects the personal data of individuals who access or use the Platform ("User", "You", "Your").

99fe is an English-language online entertainment platform designed for Pakistani users, covering live casino games, sports betting markets and real-time game-show content. Our Platform is built with a mobile-first approach and serves players across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and throughout Pakistan.

We are committed to handling your personal data with transparency, care and in accordance with applicable data protection principles. We collect only what is necessary, use it only for the purposes described in this Policy, and take appropriate measures to protect it from unauthorised access or disclosure.

The following terms are used throughout this Privacy Policy with the meanings set out below:

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, email address, identification documents, IP address and financial transaction records.
• "Processing" — Any operation performed on personal data, including collection, storage, use, transmission, alteration, restriction, archiving, erasure or destruction.
• "Data Controller" — The entity that determines the purposes and means of processing personal data. For this Platform, the Data Controller is the 99fe operator.
• "Data Processor" — A third party that processes personal data on behalf of the Data Controller, under contractual obligation and instruction.
• "KYC" — Know Your Customer — the identity and age verification process required to comply with anti-money-laundering and fraud prevention standards.
• "Cookie" — A small text file stored on your device by a website, used to maintain session state, gather analytics data or facilitate Platform functionality.
• "Consent" — A freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose.

The Data Controller for personal data processed through the 99fe Platform is the operator of the Platform. For all data-related enquiries, requests or complaints, please contact the Data Controller through the support channels described in Section 15 (Contact Us) of this Policy.

The Platform is not operated by, affiliated with or endorsed by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any Pakistani financial institution including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah. Payment provider names are referenced only as familiar Pakistani payment references and do not imply any partnership, affiliation or endorsement of gambling services.

4.1 Data You Provide Directly

• Registration Data: Full name, email address, date of birth, username and password, and any contact details provided during account creation.
• Identity Verification (KYC) Data: Government-issued identity documents — such as Pakistani CNIC or passport — selfie or liveness images, and proof-of-address documents where required.
• Payment Data: Information about the payment method used for deposits and withdrawals — such as account references associated with Easypaisa, JazzCash, bank accounts or cryptocurrency wallet addresses. Full card or account numbers are handled by payment processors and are not stored in raw form on our systems.
• Support Communications: Messages, chat transcripts or email correspondence submitted to our support team.
• Responsible Gambling Declarations: Information you provide when setting account limits, requesting cool-off periods or activating self-exclusion.

4.2 Data Collected Automatically

• Device and Session Data: IP address, browser type and version, operating system, device identifiers and session timestamps.
• Usage Data: Pages visited, games played, betting history, time spent on Platform features and navigation patterns.
• Location Data: General geographic location inferred from IP address. Precise device location is not collected.
• Cookie Data: Information collected through cookies and similar tracking technologies as described in Section 9.

We process your personal data for the following purposes:

• Account Management: Creating, maintaining and managing your registered account on the Platform.
• Identity Verification: Confirming your identity and age as part of KYC and anti-money-laundering compliance obligations.
• Transaction Processing: Facilitating deposits, withdrawals and the maintenance of accurate financial records.
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, account compromise, bonus abuse and other security threats.
• Responsible Gambling Compliance: Monitoring account activity to identify markers of harm and enforcing responsible gambling tools such as deposit limits and self-exclusion.
• Customer Support: Responding to queries, resolving complaints and providing assistance through Live Chat and email.
• Legal and Regulatory Compliance: Meeting obligations under applicable anti-money-laundering, counter-terrorism financing and data protection law.
• Platform Improvement: Using aggregated, anonymised analytics to understand how the Platform is used and to improve user experience.
• Communications: Sending service-related notifications — including account updates, transaction confirmations and policy change notices — where required or where you have provided consent for marketing communications.

We rely on the following legal bases when processing your personal data:

• Contractual Necessity: Processing required to perform the contract between you and the Platform — including account creation, transaction processing and support services.
• Legal Obligation: Processing required to comply with applicable laws — including KYC, AML and responsible gambling obligations under the licence jurisdiction.
• Legitimate Interests: Processing necessary for our legitimate business interests — including fraud detection, security monitoring and Platform analytics — where those interests are not overridden by your rights.
• Consent: Processing based on your explicit consent — such as for optional marketing communications. You may withdraw consent at any time by contacting our support team.

99fe does not sell, rent or trade your personal data. We may share your data only in the following circumstances:

• Service Providers and Data Processors: Third-party providers who process data on our behalf — such as payment processors, KYC verification services, cloud infrastructure providers and analytics platforms. These providers operate under strict data processing agreements and may only process data for the purposes we authorise.
• Regulatory and Legal Authorities: Where required by applicable law, court order or regulatory authority — including AML and counter-terrorism financing reporting obligations. We will disclose only the minimum data required to fulfil the obligation.
• Fraud Prevention: With fraud prevention databases or industry bodies where disclosure is necessary to detect, prevent or report fraudulent activity.
• Business Transfers: In the event of a merger, acquisition or sale of the Operator's business, user data may be transferred as part of the transaction. Users will be notified of any such transfer and the applicable privacy protections that will remain in place.

We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following general retention principles apply:

• Account Data: Retained for the duration of your active account and for a defined period following account closure, as required for legal, compliance and audit purposes.
• KYC and Identity Documents: Retained for the period required under applicable AML and identity-verification regulations, typically a minimum of five years from the end of the business relationship.
• Transaction Records: Retained for the period required under applicable financial record-keeping and AML obligations.
• Support Communications: Retained for a reasonable period to allow follow-up and dispute resolution, after which they are securely deleted.
• Session and Usage Data: Retained in aggregated or anonymised form for analytics purposes after the raw data is no longer needed for security or operational purposes.

Following the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be linked to an individual.

The 99fe Platform uses cookies and similar tracking technologies to maintain session integrity, improve Platform performance and understand how users interact with the site. The following categories of cookies may be used:

Most browsers allow you to manage cookie preferences through browser settings. Please note that disabling essential cookies may affect your ability to use the Platform. For more guidance on managing cookies in your browser, consult your browser's help documentation.

The security of your personal data is a priority for 99fe. We implement a range of technical and organisational security measures to protect your data from unauthorised access, disclosure, alteration or destruction, including:

• HTTPS/TLS Encryption: All data transmitted between your browser and the Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Access Controls: Access to personal data within our systems is restricted to authorised personnel who need that access to fulfil their operational responsibilities.
• Secure Storage: Personal data — including KYC documents — is stored on secured infrastructure with appropriate encryption for sensitive data categories.
• Incident Response: We maintain procedures to detect, investigate and respond to personal data breaches. In the event of a significant breach affecting your data, we will notify you and relevant authorities as required by applicable law.

Subject to applicable law and the Platform's operational and legal obligations, you have the following rights in relation to your personal data:

To exercise any of these rights, please contact our support team via Live Chat or at [email protected]. We will respond to requests within a reasonable timeframe and in accordance with applicable law. Certain rights may be subject to limitations where overriding legal obligations apply — for example, AML data retention requirements may prevent immediate erasure of certain records.

The 99fe Platform is strictly for adults aged 18 years or older — or the higher minimum age required by the operator or applicable licence jurisdiction. We do not knowingly collect, process or store personal data from individuals under 18 years of age.

If you are a parent or guardian and you believe that a minor has provided personal data to the Platform, please contact us immediately via Live Chat or at [email protected]. Upon confirmation, we will promptly delete any data relating to an underage individual and close the associated account.

In the course of operating the Platform and using third-party service providers — such as cloud infrastructure, KYC verification services or payment processors — your personal data may be transferred to and processed in countries outside of Pakistan. These countries may have different data protection laws from those applicable in Pakistan.

Where such international transfers occur, we take steps to ensure that appropriate safeguards are in place to protect your data — including contractual protections with third-party processors and, where applicable, reliance on recognised international transfer mechanisms.

For further information about international transfers applicable to your data, please contact our support team using the details in Section 15.

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, Platform features, legal requirements or business operations. Material changes to this Policy will be communicated to registered users via email notification or a prominent notice on the Platform prior to the changes taking effect.

The date at the top of this Policy ("Last Updated") indicates when it was most recently revised. Your continued use of the Platform following notification of any changes constitutes acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically. If you have concerns about any changes, please contact us using the details in Section 15 before continuing to use the Platform.

For any questions, concerns or requests relating to this Privacy Policy or to your personal data, please contact the 99fe Data Controller using the following channels:

• Live Chat: Available 24/7 via the Platform — the fastest way to reach our data support team for urgent queries.
• Email: [email protected] — for formal data rights requests, complaints or detailed privacy enquiries. Please include "Privacy Request" in the subject line. Email responses are handled during business hours.

We aim to acknowledge all data rights requests within a reasonable timeframe and to resolve them in accordance with applicable law. Where a request involves complex considerations — such as balancing your rights against legal retention obligations — we will communicate any limitations clearly and in writing.