Privacy Policy
pp98 Online Gaming Platform

1. Introduction

pp98 ("we", "us", "our", "the Platform") operates the online gaming information and platform service accessible at pp98.cam. This Privacy Policy sets out the basis on which we collect, use, disclose and protect personal data provided to us by users ("you", "your") of the Platform.

We take the privacy and security of your personal data seriously. All data collected through pp98 is processed in accordance with applicable data protection principles, including purposes of collection, data minimisation, accuracy, storage limitation, integrity and confidentiality.

By registering an account or using any part of the pp98 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform.

This Policy is intended to cover all users of pp98, including players based in Pakistan and other permitted jurisdictions. Where local data protection laws impose additional requirements, we will seek to comply with those requirements where practicable.

2. Definitions

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

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, date of birth, CNIC number, IP address and payment details.
• "Processing" — any operation performed on personal data, including collection, recording, storage, 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, this refers to pp98.
• "Data Processor" — any third party that processes personal data on behalf of pp98 under a contractual arrangement.
• "Cookies" — small text files stored on your device by a website to remember preferences and session information.
• "KYC" — Know Your Customer — the identity and age verification process applied to registered accounts.
• "AML" — Anti-Money Laundering — regulatory and compliance controls designed to detect and prevent financial crime.
• "Platform" / "Site" — the pp98 website at pp98.cam and any associated sub-domains or services.
• "User" / "Player" — any individual who accesses, registers on, or uses the Platform.

3. Data We Collect

pp98 collects only the personal data that is necessary for the purposes described in this Policy. The categories of data we may collect include:

3.1 Account Registration Data

• Full legal name;
• Date of birth;
• Email address;
• Residential address (including city and country — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar);
• Username and encrypted password;
• Mobile phone number (where provided).

3.2 Identity Verification (KYC) Data

• Government-issued identity document — CNIC (Computerised National Identity Card), passport or equivalent;
• Proof of address documentation (where required);
• Selfie or liveness verification image;
• Any additional documentation requested to fulfil AML or age verification obligations.

3.3 Financial Data

• Payment method details (as permitted by the relevant payment processor — e.g., bank transfer references, mobile wallet identifiers);
• Transaction history, deposit and withdrawal records;
• Account balance information.

3.4 Technical and Usage Data

• IP address and approximate geographic location;
• Device type, browser type and operating system;
• Pages visited, session duration and navigation paths;
• Login timestamps and session activity logs;
• Cookie identifiers and similar tracking data.

3.5 Communications Data

• Support chat transcripts and email correspondence;
• Feedback or complaints submitted to the support team;
• Marketing preferences where consent has been given.

4. How We Collect Your Data

pp98 collects personal data through the following means:

• Direct collection — data you provide when registering an account, completing KYC verification, contacting support, or otherwise interacting with the Platform;
• Automated collection — technical data collected automatically when you access the Platform, including via cookies, server logs and analytics tools;
• Third-party sources — identity verification providers, fraud prevention agencies and payment processors may share data with us in the context of account verification and transaction processing;
• KYC/AML providers — where we engage specialist identity verification or anti-money-laundering service providers, they may supply verification results and risk assessments relating to your account.

5. Data Processing

pp98 processes your personal data for the following purposes:

pp98 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where such processing is explicitly permitted by applicable law or required for fraud/AML purposes.

6. Legal Basis for Processing

pp98 relies on the following legal bases to process your personal data:

• Contractual necessity — processing required to register and manage your account, process payments and provide Platform services;
• Legal obligation — processing required to comply with applicable KYC, AML, age verification and regulatory requirements;
• Legitimate interests — processing for fraud prevention, Platform security, responsible gambling monitoring and analytics, where such interests do not override your rights;
• Consent — where you have provided explicit consent, such as for marketing communications. You may withdraw consent at any time by contacting support.

7. Data Sharing & Disclosure

7.1 Third-Party Service Providers

pp98 may share your personal data with carefully selected third-party service providers who process data on our behalf, including:

• Identity verification and KYC service providers;
• Payment processors and financial institutions (referenced contextually — e.g., HBL, UBL, Meezan Bank, Bank Alfalah, Easypaisa, JazzCash, Raast — subject to applicable data-sharing agreements);
• Fraud detection and AML compliance providers;
• Customer support platform providers;
• Web analytics and performance monitoring tools.

All third-party processors are required to handle your data in accordance with applicable data protection principles and are prohibited from using your data for any purpose other than the specific service they provide to pp98.

7.2 Legal Disclosures

pp98 may disclose personal data where required by applicable law, court order, regulatory authority, law enforcement agency or other competent governmental body. We will seek to notify affected users where legally permissible to do so.

7.3 No Sale of Personal Data

pp98 does not sell, rent or trade your personal data to any third party for their own commercial or marketing purposes. Your data is used only for the purposes described in this Privacy Policy.

8. Data Retention

pp98 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, AML or accounting obligations.

• Account data — retained for the duration of the account relationship and for a defined period following account closure, as required by regulatory obligations;
• KYC and identity documents — retained for a minimum period in line with applicable AML and regulatory requirements from the date of account closure;
• Transaction records — retained for the period required by applicable financial record-keeping obligations;
• Support communications — retained for the period necessary to resolve any outstanding disputes and for a reasonable period thereafter;
• Technical/usage data — typically retained for a shorter period consistent with its operational purpose, unless required for security or legal reasons.

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

9. Data Security

pp98 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• TLS/HTTPS encryption — all data transmitted between your browser and the Platform is encrypted in transit;
• Encrypted storage — sensitive data, including passwords, is stored using industry-standard hashing and encryption methods;
• Access controls — access to personal data is restricted to authorised personnel who require it for their specific role;
• KYC document security — identity documents are processed exclusively through secure, HTTPS-protected verification channels and are not accepted via unsecured communication methods;
• Ongoing security monitoring — the Platform is monitored for security incidents, anomalous activity and potential vulnerabilities.

While pp98 takes all reasonable precautions, no data transmission or storage system is guaranteed to be 100% secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will take appropriate steps in accordance with applicable notification obligations.

10. Cookies & Tracking Technologies

pp98 uses cookies and similar tracking technologies to operate and improve the Platform, personalise your experience, and analyse usage patterns. By using the Platform, you consent to the use of cookies as described below.

10.1 Types of Cookies Used

• Strictly Necessary Cookies — essential for the Platform to function correctly, including session management, authentication and security features. These cannot be disabled without affecting Platform functionality.
• Performance & Analytics Cookies — collect anonymous data about how users interact with the Platform (e.g., pages visited, session duration) to help us improve performance and user experience.
• Functionality Cookies — remember your preferences (e.g., language settings, account preferences) to provide a more personalised experience.
• Marketing Cookies — where applicable and with your consent, used to deliver relevant promotional content. These may be placed by third-party advertising networks.

10.2 Managing Cookies

You can control and delete cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform. For detailed guidance on managing cookies in your specific browser, please refer to your browser's help documentation.

11. User Rights

Subject to applicable data protection law, you have the following rights regarding your personal data held by pp98. To exercise any of these rights, please contact us using the details in Section 15.

pp98 will respond to all data rights requests within a reasonable timeframe. We may need to verify your identity before processing a request. Where a request cannot be fulfilled, we will explain the reason in writing.

12. Children's Privacy

The pp98 Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator or license jurisdiction. pp98 does not knowingly collect personal data from individuals under the minimum age threshold.

If we become aware that personal data has been collected from an underage individual, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately at the email address provided in Section 15.

13. International Data Transfers

pp98 operates on a platform that may involve the transfer of personal data to service providers or processing infrastructure located outside Pakistan. Where personal data is transferred internationally, pp98 takes steps to ensure that appropriate safeguards are in place to protect the data in accordance with applicable data protection principles.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in countries other than your country of residence. In all cases, such transfers are subject to contractual data protection obligations with the receiving party.

14. Changes to This Privacy Policy

pp98 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. All changes will be published to this page with an updated review date.

Where changes are material, we will endeavour to provide reasonable advance notice, which may include a notice on the Platform or an email to registered users. Your continued use of the Platform following publication of any revised Policy constitutes acceptance of the changes.

We recommend reviewing this Privacy Policy periodically to remain informed about how your data is being processed.

15. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the way in which pp98 processes your personal data, please contact our support team. We aim to respond to all data-related enquiries within 5 business days.