999cb Privacy Policy

This Privacy Policy ("Policy") describes the manner in which 999cb ("the Platform", "we", "us", "our") collects, processes, stores, discloses and protects personal data belonging to individuals ("User", "you", "your") who access or use the services available at https://999cb.cam (the "Site") and all associated applications, tools and features (collectively, the "Services").

999cb is an English-language online betting and casino information platform targeting Pakistani users. We recognise that privacy is a fundamental right. This Policy has been written to ensure you understand exactly what data we hold about you, why we hold it and what choices you have in relation to it.

This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform. Where this Policy refers to legal obligations, those references are provided for context only and do not constitute legal advice.

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" — any information that identifies or could reasonably be used to identify a natural person, directly or indirectly, including name, email address, IP address, account identifiers and financial information.
• "Processing" — any operation performed on personal data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, 999cb acts as the Data Controller in respect of user data collected via the Site.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller, pursuant to a written data-processing agreement.
• "Consent" — a freely given, specific, informed and unambiguous indication of the User's agreement to the processing of their personal data for a stated purpose.
• "Cookies" — small text files placed on a User's device by the Site for the purposes of session management, analytics, personalisation and security.
• "KYC" — Know Your Customer procedures, encompassing identity verification, address verification and source-of-funds documentation required by applicable regulatory obligations.
• "Sensitive Data" — a subset of personal data that warrants additional protection, including financial account details, government-issued identification numbers and data revealing religious or political beliefs.

We collect personal data in the categories set out below. We collect only what is necessary for the stated purposes and do not process personal data beyond those purposes without your prior consent or a separate legal basis.

Personal data is collected through the following channels:

4.1 Direct Collection

Information you provide directly when you register an account, complete a KYC request, make a deposit or withdrawal, submit a support query, participate in a promotion, or communicate with our team via Live Chat or email.

4.2 Automated Collection

Technical and usage data collected automatically as you interact with the Platform, including through server logs, cookies, web beacons and similar tracking technologies. This data is collected to ensure platform security, detect fraudulent behaviour and improve the user experience.

4.3 Third-Party Sources

We may receive personal data from third-party service providers engaged in identity verification, payment processing, fraud screening and analytics. All third-party data providers are vetted and operate under data-processing agreements consistent with this Policy.

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

• Contractual Necessity: Processing is required to perform the contract between you and 999cb — for example, to manage your account, process deposits and withdrawals, and deliver the Services you have requested.
• Legal Obligation: Processing is required for the Platform to comply with applicable legal and regulatory obligations, including anti-money laundering (AML), counter-financing of terrorism (CFT), and Know Your Customer (KYC) requirements.
• Legitimate Interests: Processing is necessary for the Platform's legitimate business interests, including fraud prevention, security monitoring, platform improvement and responsible-gambling programme management — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: For processing activities not covered by the above bases — such as sending optional marketing communications or placing non-essential cookies — we rely on your freely given, informed consent, which you may withdraw at any time.

Your personal data is used for the following specific purposes:

• Creating and managing your registered account, including identity and age verification;
• Processing deposits, withdrawals and all financial transactions associated with your account;
• Complying with KYC, AML and CFT obligations required under applicable licensing and regulatory frameworks;
• Detecting, investigating and preventing fraud, money laundering, collusion and any other form of prohibited activity on the Platform;
• Monitoring gambling activity to support responsible-gambling obligations, including identifying patterns that may indicate problem gambling behaviour;
• Providing customer support, resolving disputes and maintaining records of communications for quality-assurance purposes;
• Personalising your user experience and surfacing content, promotions and markets most relevant to your stated preferences;
• Sending transactional communications related to your account (e.g., deposit confirmations, withdrawal updates, security alerts);
• Sending optional marketing communications where you have provided consent to receive them;
• Analysing aggregated, anonymised usage data to improve platform performance, fix technical issues and develop new features;
• Fulfilling any legal obligations imposed by applicable law, court order or regulatory directive.

999cb does not sell, rent or trade your personal data to third parties for their independent marketing purposes. We share personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

7.1 Service Providers

We engage trusted third-party companies to perform services on our behalf, including payment processing, identity verification, fraud detection, customer support tooling, cloud hosting and data analytics. All such providers operate under written data-processing agreements that prohibit them from using your data for any purpose other than providing services to 999cb.

7.2 Regulatory and Law Enforcement Authorities

We may disclose personal data to competent regulatory bodies, law enforcement agencies or courts where required to do so by applicable law, valid legal process or enforceable governmental request. We will notify you of any such disclosure where we are legally permitted to do so.

7.3 Corporate Transactions

In the event of a merger, acquisition, restructuring or sale of all or part of the Platform's assets, personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to data-handling practices that result from it.

7.4 With Your Consent

We may share your data with third parties for purposes not described above where you have given us explicit, prior consent to do so. You may withdraw that consent at any time by contacting our support team.

As an internationally operating platform, 999cb may transfer personal data to service providers or infrastructure providers located outside Pakistan. Where such transfers occur, we take appropriate steps to ensure an adequate level of data protection is maintained, including:

• Entering into standard contractual clauses or equivalent contractual safeguards with the receiving entity;
• Transferring data only to jurisdictions that maintain adequate data-protection frameworks recognised by the applicable regulatory standard;
• Applying technical security measures (encryption, pseudonymisation) to data in transit and at rest.

By using the Services, you acknowledge that your personal data may be processed in jurisdictions outside Pakistan that may have different data-protection laws. Where legally permissible, we ensure that equivalent protections apply regardless of where data is processed.

We retain personal data for no longer than is necessary to fulfil the purposes for which it was collected or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained for the full duration of your account's active status and for a minimum period after account closure as required by applicable regulatory or legal obligations (typically five to seven years for financial records).
• KYC Documentation: Retained for the period required by the applicable AML/CFT regulatory framework, which is typically a minimum of five years following the end of the business relationship.
• Transaction Records: Retained for a minimum of five years in accordance with standard financial record-keeping requirements.
• Support Communications: Retained for three years following the closure of the relevant support case, for dispute resolution and quality-assurance purposes.
• Technical & Usage Data: Typically retained in identifiable form for up to 24 months, after which it is aggregated or anonymised for analytical purposes.
• Marketing Consent Records: Retained for the duration of consent plus a minimum of three years to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymised or archived in a manner that prevents further identification, unless a lawful basis for extended retention exists.

999cb implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest, including financial records and identity documents;
• Role-based access controls limiting internal access to personal data to authorised personnel on a need-to-know basis;
• Regular penetration testing and vulnerability assessments conducted by qualified security professionals;
• Multi-factor authentication requirements for internal administrative access;
• Automated intrusion detection and real-time security monitoring systems;
• Staff training on data protection, secure data handling and incident response procedures.

Notwithstanding these measures, no system connected to the internet is entirely immune to security risks. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and take all reasonable steps to contain and remediate the incident.

999cb uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that maintain your logged-in state, security tokens and load-balancing cookies. These cannot be disabled without impairing core functionality.
• Functional Cookies: Remember your preferences such as language selection, display settings and responsible-gambling limit configurations to improve your experience across sessions.
• Analytical Cookies: Collect aggregated data about how users interact with the Platform — pages visited, time on page, error events — to help us identify areas for improvement. We use privacy-respecting analytics tools that do not share your data with third-party advertising networks.
• Marketing Cookies: Used only where you have given explicit consent to receive personalised promotional communications. You may withdraw this consent at any time via your account preferences or browser settings.

You can control cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. Your cookie preferences are saved per device and browser; you may need to reset preferences if you clear your browser data.

The Services provided by 999cb are strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect, process or store personal data belonging to individuals under the applicable minimum age.

Age verification is conducted as part of the account registration and KYC process. Where we have reason to believe that a registered user is under the minimum age, the account will be suspended immediately, all balances will be withheld pending investigation and all personal data associated with that account will be deleted upon confirmation of the user's age.

Subject to applicable law and any overriding legal obligations (such as AML/KYC record-keeping requirements), you have the following rights in relation to your personal data held by 999cb:

To exercise any of the above rights, please contact our support team using the contact details in Section 16. We will respond to verified requests within thirty (30) days. We may need to verify your identity before processing a data rights request to prevent unauthorised disclosure.

999cb serves a primarily Pakistani user base across cities including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We recognise that Pakistan has its own evolving legal landscape in relation to data protection, digital services and online activities, and we are committed to operating with transparency and respect toward our Pakistani users.

14.1 No Government Endorsement

This Privacy Policy does not claim endorsement, authorisation or approval by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, any provincial authority or any Pakistani financial institution. Users are responsible for ensuring that their use of this Platform complies with applicable Pakistani law.

14.2 Payment Provider References

References to familiar payment methods used in Pakistan — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — appear in this Policy and on the Platform solely as contextual references to payment methods that may be available in the cashier. Such references do not constitute endorsement of gambling activities by those institutions, nor do they imply that those providers have approved the processing of gambling-related transactions.

14.3 Data Protection Framework

Pakistan's Personal Data Protection Bill and associated regulatory developments are evolving. 999cb monitors these developments and will update its data-handling practices as required to maintain alignment with applicable Pakistani data-protection standards as they come into force.

999cb reserves the right to update or revise this Privacy Policy at any time. When material changes are made, the "Last Updated" date at the top of this page will be revised accordingly. Where technically feasible and where changes materially affect how your data is processed, we will notify registered users via email or an in-platform notification prior to the changes taking effect.

Your continued use of the Services following notification of changes constitutes acceptance of the revised Policy. If you do not agree with any material change, you may request account closure in accordance with the Terms & Conditions prior to the effective date of the change.

We recommend reviewing this Policy periodically. The most current version will always be accessible at https://999cb.cam/privacy-policy.

If you have any questions, concerns or requests relating to this Privacy Policy or to the processing of your personal data by 999cb, please contact us using the details below. We aim to respond to all privacy-related enquiries within five (5) business days.

For information about your rights in relation to gambling activity, responsible-gambling tools or account-level controls, please visit our Responsible Gambling page. For all platform usage terms, refer to our Terms & Conditions.