Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by 92ab ("the Company," "we," "us," or "our") and applies to all personal data collected through the 92ab online gaming platform accessible at 92ab.net, including associated mobile web interfaces, customer support channels, email communications, and any other service we provide (collectively, the "Platform").

92ab is committed to protecting the privacy and personal data of all users, particularly given the sensitivity of financial and identity information processed through our platform. We operate in accordance with applicable data protection legislation and the requirements imposed by our international gaming licence.

By registering an account on 92ab and using our services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the Platform.

2 Data Controller

For the purposes of applicable data protection law, 92ab acts as the data controller in respect of personal data collected from users of the Platform. As data controller, 92ab determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

If you have any questions, concerns, or requests relating to how 92ab processes your personal data, you may contact our support team at any time using the contact details provided in Section 15 of this Policy.

3 Personal Data We Collect

92ab collects only such personal data as is necessary to provide you with a safe, compliant, and functional gaming experience. The categories of data we collect are outlined in the table below.

We do not collect special category data (such as racial or ethnic origin, political opinions, religious beliefs, genetic or biometric data) except where strictly required for identity verification purposes and only with your explicit consent.

4 How We Collect Your Data

4.1 Directly from You

The majority of personal data we hold is provided directly by you during the registration process, KYC verification, deposit and withdrawal requests, interactions with customer support, and when completing surveys or entering promotions. You are responsible for ensuring that all data you provide to 92ab is accurate and up to date.

4.2 Automatically

When you access the 92ab Platform, certain technical data is collected automatically through server logs, cookies, and similar tracking technologies. This includes your IP address, device identifiers, browser information, and clickstream data. This automatic collection is necessary for the secure operation of the Platform and for fraud prevention.

4.3 From Third Parties

In certain circumstances, 92ab may receive personal data about you from third parties. This includes identity verification data from KYC service providers, fraud-risk data from payment processing partners, and aggregated analytics data from advertising partners where you have interacted with 92ab promotional content off-platform. In all such cases, we ensure that the third party has a lawful basis for sharing your data with us.

5 Legal Basis for Processing

92ab processes your personal data only where a lawful basis exists under applicable data protection law. The primary legal bases on which we rely are:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions agreement with you, including operating your account, processing payments, and delivering gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and record-keeping requirements under our gaming licence.
• Legitimate Interests: Processing carried out in pursuit of our legitimate business interests, including fraud detection and prevention, platform security, responsible gaming monitoring, and internal analytics, provided such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily applicable to marketing communications and non-essential cookies. You may withdraw consent at any time.

6 How We Use Your Personal Data

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

6.1 Account Management

To create, manage, and maintain your 92ab account, verify your identity and age, process your login credentials securely, and communicate account-related information including transaction confirmations, security alerts, and service updates.

6.2 Payment Processing

To process deposits and withdrawal requests across all supported payment channels, including USDT (TRC-20), Bitcoin, JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank. Financial data is used solely for the purpose of processing your transactions and is not retained beyond the period required by applicable regulations.

6.3 Regulatory Compliance

To fulfil our obligations under applicable anti-money laundering legislation, KYC requirements, and the terms of our international gaming licence. This may include screening your information against sanctions lists and submitting mandatory reports to regulatory bodies where required by law.

6.4 Fraud Prevention & Security

To detect, investigate, and prevent fraudulent activity, unauthorised account access, bonus abuse, and other prohibited conduct. Technical data including IP addresses and device fingerprints are used as part of our automated and manual fraud monitoring systems.

6.5 Responsible Gaming

To monitor gameplay patterns that may indicate problem gambling behaviour, enforce responsible gaming tools such as deposit limits and self-exclusion requests, and comply with our duty of care obligations towards players. Your betting history and session data may be reviewed by our responsible gaming team.

6.6 Marketing & Personalisation

Where you have provided consent, to send you promotional communications about 92ab offers, bonuses, new game launches, and relevant content. You can withdraw marketing consent at any time by contacting our support team or using the unsubscribe mechanism in any marketing email. Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to withdrawal.

7 Sharing Your Personal Data

92ab does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. We share your data only in the following limited and controlled circumstances:

• Payment Processors: Necessary financial data is shared with our payment processing partners (including JazzCash, EasyPaisa, and banking partners) to facilitate your transactions. These partners are contractually bound to process data only for the purpose of executing your payment.
• Identity Verification Providers: Identity documents submitted for KYC are processed by our contracted identity verification service providers, who are subject to strict confidentiality obligations.
• Fraud & Security Providers: Technical data may be shared with fraud detection and cybersecurity service providers who assist us in protecting the Platform and our players.
• Regulatory Authorities: We may be required by law to disclose personal data to regulatory bodies, law enforcement agencies, or courts where mandated by a valid legal obligation or court order.
• Group Companies: Data may be shared within the 92ab corporate group for internal administrative purposes, subject to the same data protection standards applied across all group entities.
• Business Transfers: In the event of a merger, acquisition, or sale of business assets, your data may be transferred to the relevant successor entity, subject to appropriate confidentiality protections and notification to you in advance where practicable.

In all cases where personal data is shared with third-party processors, 92ab enters into data processing agreements that bind those parties to process your data only in accordance with our instructions and applicable law.

8 Cookies & Tracking Technologies

92ab uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file stored on your device by your browser when you visit a website. Cookies enable core Platform functionality, enhance performance, and — where you have consented — support analytics and personalised content.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled without impairing core functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations to personalise your experience.
• Analytics Cookies: Used to understand how players interact with the Platform — which pages are visited most frequently, where users encounter difficulties, and how navigation flows can be improved. Analytics data is aggregated and anonymised where possible.
• Marketing Cookies: Used, where consent has been given, to deliver relevant promotional content. These cookies track your activity across sessions to avoid showing duplicate promotional messages.

You can manage your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may affect your ability to use some features of the Platform.

9 Data Retention

92ab retains personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with applicable legal obligations, resolve disputes, and enforce our agreements. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and gaming regulatory requirements.
• Transaction and Financial Records: Retained for a minimum of seven (7) years following the date of the transaction, as required by applicable financial regulations.
• Technical and Usage Data: Retained for up to twenty-four (24) months from the date of collection, after which it is anonymised or deleted.
• Marketing Preferences: Retained until you withdraw consent or request deletion, at which point we will cease marketing processing within a reasonable timeframe.
• Support Correspondence: Retained for up to three (3) years following the resolution of your enquiry.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised using industry-standard methods that prevent recovery or reconstruction.

10 Data Security

92ab implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• End-to-end SSL/TLS encryption for all data transmitted between your device and our servers;
• AES-256 encryption for sensitive data stored at rest, including identity documents and financial records;
• Multi-factor authentication for all internal staff accessing production systems;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments of Platform infrastructure;
• Automated anomaly detection and 24/7 security monitoring of platform systems;
• Formal incident response procedures for managing security breaches.

While 92ab takes all reasonable precautions to protect your data, no system is entirely infallible. You are responsible for keeping your own login credentials secure and for notifying us immediately if you suspect any unauthorised access to your account.

11 Your Rights Over Your Personal Data

Subject to applicable data protection law and any overriding legal obligations (such as AML record-keeping requirements), you have the following rights with respect to your personal data held by 92ab:

• Right of Access: You may request a copy of the personal data we hold about you (commonly known as a Subject Access Request). We will respond within 30 days of a valid request.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data. Basic profile data can be corrected directly within your account settings; other data may require you to contact support.
• 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, where consent has been withdrawn (and no other legal basis applies), or where processing is found to be unlawful. This right is subject to our obligations to retain certain data under applicable law.
• Right to Restriction of Processing: You may request that we restrict processing of your personal data in certain circumstances, for example while the accuracy of data is being contested.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing of your personal data carried out on the basis of our legitimate interests, and to processing for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, 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 our support team. We may ask you to verify your identity before processing your request. There is no fee for making a rights request in ordinary circumstances.

12 Children's Privacy

The 92ab Platform is strictly not intended for use by persons under the age of 21 years. We do not knowingly collect personal data from anyone under 21. If you are a parent or guardian and believe that a minor in your care has registered on the 92ab Platform or provided us with personal data, please contact our support team immediately.

Upon receiving a credible notification of underage registration, 92ab will promptly suspend the relevant account, delete the associated personal data (except to the extent retention is required by law), and return any deposited funds to the payment source. Any winnings generated from underage play may be forfeited in accordance with our Terms & Conditions.

13 International Data Transfers

Given the global nature of cloud infrastructure and third-party service providers, your personal data may be transferred to and processed in countries outside of Pakistan. In all such cases, 92ab ensures that appropriate safeguards are in place to protect your data in accordance with applicable data protection standards. These safeguards may include:

• Data processing agreements incorporating appropriate data transfer clauses;
• Transfers only to jurisdictions recognised as providing an adequate level of data protection;
• Binding corporate rules where data is transferred within the 92ab corporate group.

By using the 92ab Platform, you acknowledge and consent to such international transfers of your personal data where necessary for the operation of the services you have requested.

14 Changes to This Privacy Policy

92ab reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or Platform functionality. The date of the most recent revision is always displayed at the top of this page.

For material changes that significantly affect your rights or the way we process your data, we will provide at least 14 days' advance notice by email to your registered address or by prominent notice on the Platform, before the changes take effect. For minor clarifications or corrections, changes may take effect upon publication.

Your continued use of the 92ab Platform following publication of a revised Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised terms, you must cease using the Platform and may request account closure in accordance with our Terms & Conditions.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or how 92ab processes your personal data, please reach out using the following channels. We are committed to responding to all privacy-related enquiries promptly and thoroughly.

Data Enquiries / Support Email: support at 92ab.net

Live Chat: Available 24 hours a day, 7 days a week through the on-platform chat interface.

Target Response Time: Under 5 minutes via live chat; within 24 hours via email for standard enquiries; within 30 days for formal Subject Access Requests.