92dudo Privacy Policy — How We Handle and Protect Your Personal Data

1. Who We Are and How to Contact Us

92dudo is an online casino and sports betting platform operated by the company holding the 92dudo brand licence and accessible at 92dudo.net. For the purposes of this Privacy Policy, 92dudo acts as the data controller in respect of all personal data collected from users of the platform.

A data controller is the entity that determines the purposes for which and the means by which personal data is processed. As data controller, 92dudo is responsible for ensuring that your personal data is handled lawfully, fairly, and in a transparent manner consistent with applicable data protection principles.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 92dudo processes your personal data, you may contact our support team at the details set out in Section 14 of this Policy. We aim to respond to all privacy-related enquiries within 30 calendar days of receipt.

2. Personal Data We Collect

92dudo collects personal data that is necessary to operate the platform, comply with regulatory and licensing obligations, and provide a secure and personalised experience to each player. The categories of personal data we collect are described below.

3. How We Collect Your Data

3.1 Directly From You

The majority of personal data held by 92dudo is provided directly by you. This includes data you submit when creating a 92dudo account, completing identity verification, making a deposit or withdrawal, contacting customer support, or participating in promotions and surveys. You are not obligated to provide this data; however, failure to provide mandatory information (such as identity documents required for KYC) may prevent us from opening or maintaining your account or processing withdrawal requests.

3.2 Automatically During Platform Use

When you access and use the 92dudo platform, certain technical and usage data is collected automatically through standard server logging, cookies, and similar tracking technologies. This includes your IP address, device identifiers, browser and operating system information, pages visited, time spent on specific games, and in-session activity patterns. This data is collected to maintain platform security, detect unusual account activity, and improve the quality and performance of the platform. Please refer to Section 9 for further details on cookies.

3.3 From Third Parties

92dudo may receive personal data about you from third-party sources in limited circumstances, including:

• Identity verification service providers used to cross-check your CNIC and age confirmation;
• Payment processors including JazzCash, EasyPaisa, and banking partners, to confirm transaction completion and detect fraud;
• Fraud prevention and anti-money laundering screening services;
• Regulatory authorities or law enforcement agencies, where a legal obligation to share data exists.

In all cases, 92dudo ensures that third-party data sources operate under appropriate data protection obligations and that the data received is used only for the specific, lawful purpose for which it was obtained.

4. How We Use Your Personal Data

92dudo uses the personal data it holds for the following purposes:

4.1 Account Registration and Management

Your identity, contact, and financial data are necessary to open and maintain your 92dudo account, verify your age and identity in compliance with KYC requirements, process deposits and withdrawals to your nominated payment method, and communicate account-related information including security alerts and transaction confirmations.

4.2 Platform Operation and Service Delivery

Usage and technical data are used to deliver the 92dudo platform to your device, ensure games and betting features function correctly, maintain platform performance and uptime, and diagnose and resolve technical issues. Without this processing, the platform could not function in a reliable and consistent manner for users across Pakistan.

4.3 Regulatory Compliance and Legal Obligations

92dudo is subject to obligations under its international online gaming licence and applicable anti-money laundering frameworks. To meet these obligations, 92dudo processes your identity, financial, and usage data to conduct ongoing AML and fraud screening, maintain audit trails of all transactions and bets placed, report suspicious activity to relevant regulatory or law enforcement authorities as required by law, and fulfil any mandatory data retention requirements under applicable legislation.

4.4 Responsible Gaming

92dudo analyses player usage and betting pattern data to identify indicators of problem gambling behaviour — such as significant increases in deposit frequency, session duration, or loss chasing patterns. Where such indicators are detected, 92dudo may proactively reach out to the player with responsible gaming information or apply protective account measures in accordance with its responsible gaming policy. This processing is conducted in the genuine interest of player welfare and is required under 92dudo's licensing conditions.

4.5 Security and Fraud Prevention

Technical and usage data, together with identity information, is used to detect and prevent fraudulent account activity, multi-accounting, bonus abuse, payment fraud, and platform security breaches. 92dudo's fraud prevention systems operate continuously and may result in account investigation, suspension, or closure where irregularities are identified.

4.6 Marketing Communications

With your explicit consent, 92dudo may use your contact details and preferences to send you personalised promotional communications about bonuses, new games, cricket betting markets, and special events. You may withdraw this consent at any time — see Section 11 for details.

4.7 Platform Improvement and Analytics

Aggregated and anonymised usage data is used to understand how players interact with the 92dudo platform, identify areas for improvement, test new features, and inform future product development. This analysis does not identify you personally; it uses aggregated data patterns across the platform's player base.

5. Legal Basis for Processing

Each processing activity conducted by 92dudo rests on one of the following lawful bases:

• Contractual necessity: Processing required to perform our obligations under the 92dudo account agreement, including registering your account, processing deposits and withdrawals, and delivering games and betting services;
• Legal obligation: Processing required to comply with our regulatory and licensing obligations, including KYC identity verification, AML screening, and mandatory data retention requirements;
• Legitimate interests: Processing conducted for fraud prevention, platform security, responsible gaming monitoring, and aggregated analytics — where 92dudo's legitimate interest in operating a safe and lawful platform does not override your privacy rights;
• Consent: Processing for optional marketing communications, where you have explicitly opted in. Consent can be withdrawn at any time without affecting the lawfulness of prior processing.

92dudo does not process personal data for purposes incompatible with the purposes listed in Section 4. If a new processing purpose is identified, this Policy will be updated and you will be notified accordingly.

6. Sharing Your Personal Data

6.1 Service Providers and Data Processors

92dudo engages third-party service providers who process personal data on our behalf and strictly under our instructions. These include identity verification and KYC platform providers, payment processors (JazzCash, EasyPaisa, banking partners), fraud detection and AML screening services, cloud infrastructure and hosting providers, and customer support software providers. All service providers are bound by data processing agreements that prohibit use of your data for any purpose beyond the specific service they provide to 92dudo.

6.2 Regulatory and Law Enforcement Authorities

92dudo may be required by its licensing authority, applicable anti-money laundering regulations, or a lawful order from a government or law enforcement authority to disclose specific personal data. In all such cases, 92dudo will limit disclosure to the minimum data required to fulfil the legal obligation and will, where legally permitted to do so, notify you of the disclosure.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving 92dudo, personal data held by the platform may be transferred to the acquiring or successor entity as part of the transaction. In any such event, you will be notified prior to your data being transferred and becoming subject to a different privacy policy.

6.4 No Cross-Border Transfers Without Safeguards

Where personal data is transferred to service providers or authorities located outside the jurisdiction in which 92dudo's data is primarily stored, 92dudo ensures that appropriate safeguards are in place — including contractual protections equivalent to the standard data protection clauses recognised under applicable international frameworks — prior to any such transfer.

7. Data Retention

92dudo retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any applicable legal, regulatory, accounting, or reporting requirements. The following general retention principles apply:

• Active account data: Retained for the duration of your account and for a minimum period of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements;
• KYC and identity documents: Retained for a minimum of five (5) years following the end of the business relationship, as required under applicable AML regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Support communications: Retained for three (3) years following resolution of the relevant issue, or longer if relevant to an ongoing legal or regulatory matter;
• Marketing preferences and opt-in records: Retained for as long as you hold an account and for three (3) years following account closure;
• Technical and session logs: Retained for twelve (12) months from the date of generation, unless retention is extended due to a security investigation.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents its reconstruction or re-identification.

8. How We Protect Your Data

92dudo implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption applied to all data transmitted between your device and the 92dudo platform;
• Encryption at rest for all sensitive personal data stored on 92dudo systems, including identity documents, financial data, and account credentials;
• Access controls that restrict internal access to personal data strictly to staff whose roles require it, enforced through role-based permissions and multi-factor authentication for all administrative systems;
• Regular security audits and penetration testing conducted by independent third-party security specialists;
• Intrusion detection systems and continuous network monitoring for unauthorised access attempts;
• Segregated storage of player fund data and operational systems to limit breach blast radius;
• Staff training on data protection obligations and incident response procedures.

While 92dudo employs industry-standard security practices, no system connected to the internet can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights, 92dudo will notify you without undue delay and take all necessary remediation steps in accordance with its incident response procedures.

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They are used to recognise your browser or device, remember preferences, and collect usage information. 92dudo uses cookies and similar technologies (such as local storage and session tokens) to operate the platform effectively.

9.2 Types of Cookies Used by 92dudo

• Essential cookies: Required for the platform to function correctly. These include session authentication cookies that keep you logged in, security tokens, and cookies that remember your language and display preferences. These cookies cannot be disabled without impacting platform functionality;
• Analytics cookies: Used to collect anonymised data about how players navigate and use the platform, which pages are visited most frequently, and where users encounter difficulties. This data informs platform improvements;
• Security cookies: Used by fraud detection systems to identify unusual session behaviour, detect bot activity, and protect against account takeover attempts;
• Preference cookies: Used to remember your personalisation settings, such as preferred game categories or notification preferences, so that you do not need to reconfigure them each session.

9.3 Managing Cookies

You may adjust your browser settings to block or delete cookies at any time. Please note that disabling essential cookies will affect your ability to log in and use core platform features. Analytics and preference cookies can be disabled without impacting core functionality. Details of how to manage cookies in common browsers are available in the help sections of Chrome, Firefox, Safari, and Microsoft Edge.

10. Your Data Protection Rights

Subject to applicable data protection law and the specific circumstances of your request, you have the following rights in relation to the personal data 92dudo holds about you:

To exercise any of these rights, please contact us at [email protected] with the subject line "Data Privacy Request" and a description of your request. We will respond within 30 calendar days of receipt, and may request proof of identity before processing your request to protect your account from unauthorised access.

11. Marketing Communications

11.1 Opt-In Basis

92dudo sends promotional communications — including bonus offers, new game announcements, cricket betting promotions, and PSL special event offers — only to players who have explicitly opted in to receive them. Opting in is entirely voluntary and is not a condition of holding a 92dudo account. Marketing preferences can be set or updated at any time from within your account settings.

11.2 Withdrawing Consent

You may withdraw your consent to receive marketing communications at any time by updating your preferences in your account settings, clicking the unsubscribe link included in any marketing email, or contacting the support team at [email protected]. Withdrawal of marketing consent will take effect within 48 hours. Withdrawal of marketing consent does not affect transactional communications such as deposit confirmations, withdrawal notifications, and account security alerts, which are sent regardless of marketing preference as they form part of the platform's operational service delivery.

11.3 No Third-Party Marketing

92dudo does not sell, rent, or license your contact details to any third party for their own marketing purposes. Any promotional communication you receive in connection with 92dudo will originate from 92dudo directly and will relate to 92dudo's own products and services.

12. Children and Minors

92dudo's age verification procedures are designed to prevent underage access at the point of registration and before any withdrawal is processed. Identity documents including CNIC are required to confirm eligibility. Despite these measures, if an account belonging to an underage individual is identified at any stage, 92dudo will take immediate remedial action including account closure and data deletion, and will report the matter to the relevant regulatory authority as required by its licence conditions.

13. Changes to This Privacy Policy

92dudo reviews and updates this Privacy Policy periodically to reflect changes in how we process personal data, changes in applicable law, and changes to the platform's features and services. When material changes are made — meaning changes that affect the purposes for which your data is used or your rights in relation to it — we will notify registered players via email and/or a prominent notice displayed on the platform prior to the changes taking effect.

The "Last updated" date at the top of this Policy reflects when the most recent revision was published. We encourage you to review this Policy periodically. Your continued use of the 92dudo platform following the effective date of any update constitutes your acknowledgement of the revised Policy. If you do not agree to material changes, you may close your account as described in the Terms and Conditions.

14. How to Contact Us on Privacy Matters

For any questions, concerns, or formal requests relating to your personal data or this Privacy Policy, please contact the 92dudo data protection team using the details below. When contacting us about a data protection matter, please include your full name, registered mobile number or email address, and a clear description of your query or request to allow us to locate your records and respond efficiently.