92goo Privacy Policy

01 Introduction

This Privacy Policy ("Policy") is issued by 92goo ("92goo", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at 92goo.cam (the "Platform"). It applies to all individuals who register an account, access, browse or otherwise interact with the Platform ("User", "you", "your").

92goo is an English-language platform designed for users including those in Pakistan. We take the privacy and security of your personal data seriously. This Policy describes what personal data we collect, why we collect it, how we use and share it, how long we retain it, and what rights you have in relation to your data.

By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the data-processing activities described herein to the extent that consent is the applicable legal basis. Where other legal bases apply (such as contractual necessity or legitimate interests), your continued use constitutes acknowledgement of those processing activities.

02 Definitions

For the purposes of this Privacy Policy, the following terms have 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, postal address, financial details and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, deletion or destruction.
• "Data Controller" means 92goo, as the entity that determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means any third party that processes Personal Data on behalf of 92goo under a data-processing agreement.
• "KYC Data" means identity-verification documents and associated data collected as part of the Know Your Customer process, including government-issued identification and proof of address.
• "Cookies" means small text files placed on a User's device by the Platform for session management, analytics and preference storage purposes.
• "Account" means a registered user account on the 92goo Platform.
• "PKR" means Pakistani Rupees, the primary currency display denomination used on the Platform for Pakistani users.

03 Data We Collect

92goo collects Personal Data in several ways: directly from you when you register or use the Platform; automatically through technical systems when you access the Platform; and from third-party verification or payment-processing partners where applicable. The categories of Personal Data we collect are as follows.

3.1 Registration & Account Data

• Full legal name and date of birth.
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar).
• Email address and, where provided, mobile telephone number.
• Username, encrypted password and security question responses.
• Account preferences, language settings and responsible gambling limit configurations.

3.2 KYC & Verification Data

• Copies of government-issued photo identification (National Identity Card, Passport or Driver's Licence).
• Proof of address documents (utility bills, bank statements or similar documents dated within three months).
• Proof of payment method ownership where required by anti-money-laundering procedures.
• Selfie or liveness-check images where required by the Platform's KYC provider.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts in PKR and payment method references.
• Payment method type (e.g., bank transfer, mobile wallet reference type). Full payment account numbers are not stored on the Platform; they are processed by third-party payment providers.
• Betting and wagering history, including markets placed on cricket, PSL, ICC tournaments, football, UFC and casino games.
• Bonus redemption and wagering-requirement fulfilment records.

3.4 Technical & Usage Data

• IP address and general geographic location derived from IP data.
• Device type, operating system, browser type and version.
• Session logs including login timestamps, pages visited and actions taken.
• Cookie identifiers and analytics data (see Section 8).
• Customer support interaction records, including live chat transcripts and email correspondence.

3.5 Data We Do Not Collect

92goo does not intentionally collect sensitive categories of Personal Data such as racial or ethnic origin, political opinions, religious beliefs, health data or biometric data, except where biometric-style liveness checks are required as part of a KYC verification process conducted by a third-party provider under their own data-processing terms.

04 Data Processing

92goo processes your Personal Data for the following purposes. The table below sets out each purpose and the corresponding data categories involved.

05 Legal Basis for Processing

92goo processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to provide the Platform services you have signed up for, including account management, transaction processing, bet settlement and customer support.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money-laundering (AML) requirements, Know Your Customer (KYC) regulations, and licensing-authority obligations under the applicable international gambling licence framework.
• Legitimate Interests: Processing carried out in the pursuit of 92goo's legitimate business interests — including fraud prevention, Platform security, responsible gambling monitoring and improving the user experience — where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing carried out before withdrawal. Consent-based processing primarily covers direct marketing communications and non-essential cookies.

06 Data Sharing

92goo does not sell your Personal Data to third parties. We share your data only in the circumstances described below, and only to the extent necessary for the stated purpose.

6.1 Service Providers & Data Processors

We engage third-party service providers who process data on our behalf under contractual data-processing agreements. These include:

• KYC and identity verification technology providers.
• Payment processing and transaction services. References to Pakistani payment methods — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are contextual only. These institutions are not data processors for 92goo; any data shared with them relates solely to the transaction processing they conduct in their own capacity.
• Platform hosting and cloud infrastructure providers.
• Analytics and fraud-detection technology providers.
• Customer support platform providers.
• Game content and sports-data feed providers (receiving only non-personally-identifiable session data necessary for game/odds delivery).

6.2 Regulatory & Legal Disclosure

We may disclose Personal Data to regulators, licensing authorities, law enforcement agencies or courts where required by applicable law, a court order, regulatory requirement or to protect the rights, property or safety of 92goo, its users or third parties.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of 92goo's business, Personal Data may be transferred as part of that transaction. Affected Users will be notified in accordance with the notification procedures in Section 13 of this Policy.

07 Data Retention

92goo retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying applicable legal, regulatory, accounting and licensing retention obligations.

• Account & KYC Data: Retained for the duration of your active Account and for a minimum period after Account closure as required by the applicable licensing authority's AML and record-keeping obligations. This period is typically five (5) years from Account closure, though the specific period is governed by the applicable licensing framework.
• Transaction & Betting Records: Retained in accordance with applicable financial record-keeping obligations, generally for a minimum of five (5) years.
• Support Records: Retained for a reasonable period following resolution of the relevant support interaction, sufficient to address any follow-up queries or regulatory requirements.
• Marketing Preferences: Retained until you withdraw consent or opt out of marketing communications. Opt-out records are retained indefinitely to ensure compliance.
• Technical & Log Data: Retained for a shorter period sufficient for security monitoring and fraud detection purposes, typically not exceeding twelve (12) months in identifiable form.

When Personal Data is no longer required for the purposes for which it was collected and no legal basis for further retention exists, it will be securely deleted or anonymised.

08 Cookies & Tracking Technologies

92goo uses cookies and similar tracking technologies on the Platform to maintain session security, deliver a personalised experience and analyse Platform performance. The following categories of cookies are in use.

You can manage non-essential cookie preferences through your browser settings. Note that disabling certain functional cookies may affect the Platform's ability to remember your preferences. Disabling essential cookies will impair or prevent Platform functionality entirely.

92goo does not use third-party advertising cookies or cross-site tracking cookies for advertising purposes on behalf of third-party advertisers.

09 User Rights

Subject to applicable data-protection law and the legal basis for processing, you have the following rights in relation to your Personal Data. These rights are not absolute and may be subject to limitations where, for example, they conflict with 92goo's legal obligations.

To exercise any of the above rights, please contact 92goo via the details in Section 14. We will respond to verified requests within thirty (30) days. We may need to verify your identity before processing a rights request.

10 Data Security

92goo implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. Security measures in place include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform.
• Encrypted storage of sensitive data at rest, including passwords (stored as one-way hashes) and financial records.
• Access controls limiting Personal Data access to authorised personnel on a need-to-know basis.
• Two-factor authentication availability for all user Accounts.
• Regular security assessments and monitoring of the Platform infrastructure.
• Data-processor due-diligence and contractual security requirements imposed on third-party service providers.

No data transmission over the internet or electronic storage system can be guaranteed as completely secure. In the event of a Personal Data breach that poses a risk to your rights and freedoms, 92goo will notify affected Users in accordance with the notification obligations under the applicable regulatory framework.

11 Minors

If 92goo becomes aware that Personal Data has been collected from an individual under the age of 18 without appropriate verification, the relevant Account will be suspended immediately, all associated data will be reviewed and any data collected without valid basis will be deleted in accordance with applicable requirements.

If you have reason to believe that a minor is accessing the Platform or that their data has been collected, please contact us immediately using the details in Section 14.

12 International Data Transfers

92goo operates as an international platform and may process or store your Personal Data in jurisdictions outside Pakistan. Where such transfers occur, 92goo takes steps to ensure that adequate levels of data protection are applied, including through contractual safeguards with Data Processors and service providers.

Pakistani users should be aware that data-protection laws outside Pakistan may differ from any applicable Pakistani data-protection standards. By using the Platform, you acknowledge that your data may be transferred to and processed in such jurisdictions as part of Platform operations.

13 Policy Amendments

92goo may update this Privacy Policy from time to time to reflect changes in data-processing practices, applicable law, Platform features or organisational structure. Where material changes are made, we will notify registered Users via email or a prominent Platform notification prior to the revised Policy taking effect.

The "Last updated" date at the top of this Policy indicates when it was most recently revised. Continued use of the Platform after the effective date of a revised Policy constitutes acceptance of the updated terms. We encourage you to review this Policy periodically.

14 Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data-subject rights, wish to withdraw consent for marketing communications, or need to report a privacy concern, please contact the 92goo privacy team through the following channel:

Please include "Privacy Request" or "Data Subject Rights" in the subject line of your email to ensure your message is routed to the appropriate team. We will verify your identity before processing any request relating to Personal Data.