pn999 Privacy Policy

Introduction

This Privacy Policy ("Policy") is issued by pn999 ("we", "us", "our" or the "Operator"), the operator of the online gaming platform accessible at pn999.cam. This Policy sets out how we collect, use, disclose, store and protect personal data relating to individuals who visit, register with or use the Platform ("you", "User" or "Data Subject").

We take the privacy of our Users seriously. This Policy is intended to be read clearly, without unnecessary legal complexity, so that every user — including Pakistani players from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and elsewhere — can understand exactly what happens to their personal information when they interact with pn999.

This Policy applies to all personal data processed in connection with the Platform, whether collected through the website, the in-platform Live Chat, email correspondence, the KYC verification portal, or any other channel operated by pn999.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, which together form the full framework of agreements governing your use of the Platform.

Definitions

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

• "Personal Data" — any information relating to an identified or identifiable natural person. This includes names, email addresses, device identifiers, IP addresses and any other information that can reasonably be used to identify an individual.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, restriction, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, the Data Controller is pn999.
• "Data Processor" — a third party that Processes Personal Data on behalf of the Data Controller pursuant to a data processing agreement.
• "Cookies" — small text files placed on a User's device by the Platform to facilitate session management, security and analytics.
• "KYC" — Know Your Customer; the identity, age and source-of-funds verification process required by the Operator.
• "Special Category Data" — particularly sensitive Personal Data warranting enhanced protection, such as data relating to health, biometric identity or financial vulnerability indicators.
• "Third Party" — any natural or legal person other than the User, pn999 or a Data Processor engaged by pn999.

Data We Collect

pn999 collects the following categories of Personal Data, depending on the nature of your interaction with the Platform:

3.1 — Registration Data

• Full name
• Date of birth
• Email address
• Residential address
• Username and encrypted password
• Account currency preference (e.g. PKR)

3.2 — Identity Verification (KYC) Data

• Government-issued photo identity document (e.g. Pakistani CNIC, passport)
• Proof of address documents (e.g. utility bill, bank statement)
• Selfie or liveness verification image
• Source-of-funds documentation where enhanced due diligence is required

3.3 — Financial Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method type (e.g. bank transfer, digital wallet)
• Transaction reference numbers
• Account balance history

3.4 — Usage and Technical Data

• IP address and approximate geolocation derived from IP
• Device type, operating system and browser version
• Session start and end times
• Pages visited, features used and bet history
• Cookie identifiers and session tokens

3.5 — Communications Data

• Records of Live Chat, email and support ticket correspondence
• Content of formal complaints submitted to the Operator
• Preferences for support language (English or Urdu)

3.6 — Responsible Gambling Data

• Self-imposed deposit, loss and time limits set through account settings
• Self-exclusion requests and their duration
• Any responsible gambling assessment outcomes

How We Collect Data

Personal Data is collected through the following means:

• Directly from you — during registration, account update, KYC submission, support contact or any form-based interaction on the Platform.
• Automatically — through Cookies, server logs and analytics tools when you browse or use the Platform.
• From verification partners — identity and document verification services used to conduct KYC processing may return verification outcomes and document metadata to us.
• From payment processors — payment service providers transmit transaction confirmation data, including reference numbers and payment method type, necessary to reconcile account balances.
• From fraud prevention services — third-party risk scoring and AML screening tools may provide signals about a session or transaction that are associated with a User record.

Legal Basis for Processing

Where data protection legislation requires a lawful basis for the Processing of Personal Data, pn999 relies on the following bases:

How We Use Your Data

pn999 uses Personal Data for the following purposes:

• Account administration — creating, maintaining and securing your account; processing login and password-reset requests.
• Identity and age verification — confirming that you meet the eligibility criteria in our Terms & Conditions before enabling full platform access and withdrawal functionality.
• Transaction processing — crediting deposits, processing withdrawal requests and maintaining an accurate transaction ledger.
• Fraud prevention and AML compliance — screening transactions and account behaviour against risk indicators; reporting where legally required.
• Responsible gambling — monitoring wagering patterns where this may indicate problem gambling; enforcing self-exclusion requests; administering deposit, loss and session limits.
• Customer support — responding to queries, complaints and escalations submitted through Live Chat, email or the Help Centre.
• Platform improvement — analysing aggregated usage data to identify performance issues, improve navigation and refine the game catalogue.
• Security — detecting and preventing unauthorised access, account takeover attempts and automated abuse.
• Legal compliance — retaining records as required by applicable law; responding to legally valid requests from courts, regulators or law enforcement agencies.
• Marketing communications — where you have opted in, sending promotional offers and platform updates. You may withdraw consent at any time through account settings or by contacting support.

Data Sharing & Disclosure

pn999 does not sell, rent or trade your Personal Data. We share data only in the following circumstances and only to the extent necessary for each purpose:

7.1 — Service Partners

We engage third-party service providers acting as Data Processors, including: identity verification and KYC providers; payment processing services; fraud detection and AML screening platforms; and cloud infrastructure and hosting providers. All such providers are subject to data processing agreements requiring them to process data only on our instructions and to maintain appropriate security standards.

7.2 — Payment References

Where a Pakistani payment reference such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah is used contextually on the Platform, data sharing with any such institution occurs only through the transaction mechanics of the payment method actually used at the cashier. Reference to a payment brand name does not imply any data-sharing arrangement with that brand's parent institution unless a payment transaction is specifically initiated through that channel.

7.3 — Legal Obligations

pn999 may disclose Personal Data to competent courts, law enforcement authorities, regulators or government agencies where required by a binding legal obligation, court order or regulatory instruction. We will take reasonable steps to notify affected Users of such disclosures where legally permitted to do so.

7.4 — Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of pn999's business, Personal Data held by the Operator may form part of the transferred assets. Affected Users will be notified before their data is transferred and becomes subject to a different privacy policy.

7.5 — Aggregated and Anonymised Data

We may share aggregated, anonymised statistical data with analytics partners or publish it internally for product development purposes. Such data cannot reasonably be used to identify any individual User.

International Data Transfers

pn999 operates globally and your Personal Data may be processed in jurisdictions outside your country of residence, including jurisdictions that may not offer the same level of data protection as your home jurisdiction.

Where Personal Data is transferred to a jurisdiction that lacks an adequacy decision or equivalent data protection standards relative to the Operator's primary licensing jurisdiction, pn999 will implement appropriate safeguards to protect your data. These may include standard contractual clauses, binding corporate rules or other recognised transfer mechanisms.

Pakistani users should be aware that their data will be processed outside Pakistan. As Pakistan's data protection framework continues to develop, users who have concerns about cross-border data transfers are encouraged to review the current status of the Personal Data Protection Bill and seek independent legal advice.

Data Retention

pn999 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by applicable law or legitimate business necessity. The following indicative retention periods apply:

When Personal Data is no longer required, it is securely deleted or irreversibly anonymised in accordance with our internal data disposal procedures. Anonymised data derived from User records may be retained indefinitely for statistical purposes, as it can no longer identify any individual.

Cookies & Tracking Technologies

pn999 uses Cookies and similar technologies to operate and improve the Platform. The following cookie categories are used:

10.1 — Strictly Necessary Cookies

These Cookies are essential for the Platform to function. They manage your login session, maintain security tokens, and prevent cross-site request forgery. These Cookies cannot be disabled without breaking core Platform functionality.

10.2 — Analytics Cookies

We use anonymised analytics Cookies to understand how Users navigate the Platform — which pages are visited, where sessions end, and which features are most used. This data is aggregated and does not identify individual Users. Analytics data is used solely to improve the Platform experience.

10.3 — Preference Cookies

These Cookies remember your Platform preferences, such as language selection and interface settings, so that they persist across sessions without requiring re-configuration on each visit.

10.4 — Managing Cookies

You can control Cookie settings through your browser's privacy settings. Disabling non-essential Cookies will not prevent access to the Platform, though certain preference features may not persist between sessions. Note that disabling strictly necessary Cookies will impair core Platform functionality including login and session security.

Security Measures

pn999 implements a range of technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• TLS/HTTPS encryption on all data transmitted between the User's device and Platform servers.
• Encryption at rest for sensitive data categories, including KYC documents and financial records, stored in our infrastructure.
• Role-based access controls ensuring that internal staff access Personal Data only to the extent required for their role.
• Multi-factor authentication for privileged system access within pn999's operational infrastructure.
• Vulnerability management including regular security assessments and patching of Platform components.
• Incident response procedures — in the event of a personal data breach, pn999 will assess the risk, contain the breach and notify affected Users and relevant authorities where required by applicable law.

While pn999 takes all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. Users are responsible for maintaining the confidentiality of their own login credentials. If you believe your account has been compromised, contact support immediately through the in-platform Live Chat.

Your Rights

Subject to applicable data protection law in the Operator's relevant licensing jurisdiction, you may hold the following rights with respect to your Personal Data. pn999 will assess requests under the data protection framework applicable to the Operator's primary licensing jurisdiction. Pakistani users may hold additional or different rights under Pakistani law as it develops.

To exercise any of the above rights, please contact us using the details in Section 13. We may need to verify your identity before processing a data rights request, to ensure that Personal Data is not disclosed to or deleted at the request of an unauthorised party.

Contact & Complaints

If you have any questions, concerns or requests relating to this Privacy Policy or your Personal Data, please contact the pn999 Data Protection team through the following channels. All channels are available in English; Urdu-language assistance is available on request.

Data Subject Request Response Times

pn999 will acknowledge data subject requests within 5 business days and will endeavour to respond substantively within 30 calendar days of receiving a valid, verifiable request. Where a request is complex or there are a high volume of requests outstanding, we may extend this period by a further 30 days; we will notify you of any such extension.

Complaints

If you are not satisfied with our response to a data protection concern, you may have the right to lodge a complaint with the supervisory authority responsible for data protection in the Operator's primary licensing jurisdiction. Details of the relevant supervisory authority will be provided in our response to your complaint if it is not resolved to your satisfaction. Pakistani users may wish to seek guidance on available complaint routes under developing Pakistani data protection legislation.

Changes to This Policy

pn999 reserves the right to update or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, Platform features or our data processing practices. The "Last Reviewed" date at the top of this page will be updated each time a material change is made.

Where changes are material, we will endeavour to provide reasonable advance notice through one or more of the following channels: an on-site notice on the Platform; an email to the registered Account email address; or an in-platform notification. Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

If you do not accept any material changes to this Policy, you should close your Account before the changes take effect and contact the support team to request deletion of your Personal Data where legally permitted.

We encourage all Users, including Pakistani users who may be subject to new data protection legislation as it comes into force, to review this Policy periodically. Prior versions of this Policy are available on request from our support team.