Privacy Policy
for s92bat Users

1. Introduction

This Privacy Policy ("Policy") sets out how s92bat, operating under the domain s92bat.cam ("the Platform", "we", "us" or "our"), collects, uses, stores, discloses and otherwise processes the personal data of individuals who access or use our Services.

s92bat is an English-language online sports betting and gaming platform designed for users in the Pakistani market. While Pakistan has its own personal data protection framework currently in development, we align our data-handling practices with broadly recognised international standards for data protection and privacy.

By registering an account on s92bat or by continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood its contents. This Policy forms part of, and should be read alongside, our Terms & Conditions.

2. Definitions

In this Policy, the following terms carry the meanings specified below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address and financial transaction data.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, deletion and all intermediate steps.
• "Data Subject" means the individual to whom Personal Data relates — in the context of this Platform, this is you, the registered user or website visitor.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, s92bat (s92bat.cam) is the Data Controller.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a contractual arrangement.
• "Cookies" means small text files placed on your device by a website for the purpose of storing information about your visit and preferences.
• "KYC" means Know Your Customer — the identity and age verification process required before certain account functions are enabled.
• "AML" means Anti-Money Laundering — the legal and procedural framework applied by s92bat to detect and prevent financial crime.
• "Services" means the sports betting, casino gaming and ancillary features available through the Platform.

3. Data Controller

For the purposes of this Policy, s92bat operating under s92bat.cam acts as the Data Controller in respect of the Personal Data of all registered users and website visitors. As Data Controller, we determine the purposes and means by which your Personal Data is processed and bear responsibility for its lawful and transparent handling.

All data protection enquiries, subject access requests and complaints relating to the processing of your Personal Data should be directed to us via the contact details set out in Section 16 of this Policy.

4. Data We Collect

We collect Personal Data through the following channels and in the following categories:

4.1 Data You Provide Directly

• Registration data: full name, date of birth, email address, residential address and, where provided, mobile number.
• KYC verification documents: copies of government-issued identity documents, proof of address and, where required, proof of payment method.
• Account preferences and responsible gambling settings (e.g., deposit limits, self-exclusion requests).
• Communications you send to us via Live Chat, email or our Help Centre.
• Any information you voluntarily provide during surveys, promotions or feedback requests.

4.2 Data Collected Automatically

• Technical data: IP address, device type and model, operating system, browser type and version.
• Usage data: pages visited, features accessed, session duration, click-paths and betting or gaming activity logs.
• Cookies and similar tracking technologies (see Section 9).
• Geolocation data at the country or region level, derived from your IP address.

4.3 Data Received from Third Parties

• Identity verification data from third-party KYC service providers engaged by s92bat to assist with age and identity checks.
• Fraud prevention and AML screening data from third-party financial compliance services.
• Technical and security data from our hosting, infrastructure and cybersecurity providers.

5. Legal Basis for Processing

s92bat processes your Personal Data on one or more of the following legal bases, depending on the nature and purpose of each processing activity:

• Contractual Necessity: Processing required to perform the contract between you and s92bat — including operating your account, processing deposits and withdrawals and providing access to the Services.
• Legal Obligation: Processing necessary to comply with applicable legal and regulatory requirements, including KYC verification, AML monitoring and record-keeping obligations imposed by the Platform's licensing jurisdiction.
• Legitimate Interests: Processing based on our legitimate interests in operating a secure, fair and commercially viable platform — including fraud prevention, security monitoring, technical performance analysis and responsible gambling enforcement. Where legitimate interests are relied upon, we have assessed that these do not override your fundamental rights and freedoms.
• Consent: Where processing is based on your freely given, specific and informed consent — for example, in relation to certain marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

6. How We Use Your Personal Data

s92bat uses the Personal Data we hold for the following purposes:

• To register and manage your account on the Platform.
• To verify your identity and age in accordance with our KYC obligations.
• To process deposits, withdrawals and other financial transactions denominated in PKR.
• To detect, investigate and prevent fraud, money laundering and other prohibited conduct in accordance with our AML programme.
• To enforce our Terms & Conditions, including investigation of suspected breaches and bonus abuse.
• To provide and improve customer support via Live Chat, email and our Help Centre.
• To administer responsible gambling tools, including deposit limits, loss limits, session reminders and self-exclusion requests.
• To communicate with you about your account, transactions, security alerts and important policy updates.
• To send promotional communications and marketing materials where you have provided your consent or where we have a legitimate interest in doing so and you have not opted out.
• To analyse usage patterns and improve the Platform's performance, content and user experience for players across Pakistan, including users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.
• To comply with our legal, regulatory and contractual obligations.

7. Data Sharing & Disclosure

s92bat does not sell, rent or trade your Personal Data to any third party for their own independent marketing or commercial purposes. We may disclose your Personal Data in the following limited circumstances:

7.1 Service Providers and Data Processors

We engage a limited number of trusted third-party service providers who process data on our behalf and under our instruction. These include KYC verification providers, payment processing infrastructure providers, cybersecurity and fraud-prevention services, cloud hosting providers and customer support technology platforms. All such providers are bound by data processing agreements that restrict their use of your data to the specific services they provide to s92bat.

7.2 Legal and Regulatory Obligations

We may disclose your Personal Data to law enforcement agencies, courts, regulators or other competent authorities where we are required to do so by applicable law, court order or in connection with the investigation of suspected criminal activity or serious regulatory breaches.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of the assets of s92bat, your 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 arrangements that result from it.

7.4 With Your Consent

We may share your Personal Data with third parties in circumstances not covered by the above categories where you have provided your explicit consent for us to do so. You may withdraw such consent at any time.

8. Data Retention

s92bat retains Personal Data only for as long as is necessary for the purposes set out in this Policy or as required by applicable legal, regulatory or contractual obligations. Our general data retention principles are as follows:

• Account data and KYC records: Retained for the duration of your account relationship with s92bat and for a minimum of five (5) years following account closure, to satisfy AML and regulatory record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction in accordance with standard financial compliance practices.
• Customer support communications: Retained for up to two (2) years from the date of last communication, unless a longer period is required due to an open dispute or investigation.
• Marketing preference data: Retained until you withdraw your consent or opt out, after which it will be deleted or anonymised within a reasonable period.
• Technical and usage logs: Typically retained for up to twelve (12) months, unless required for longer periods for fraud prevention, security investigations or legal proceedings.

At the end of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised such that it can no longer be associated with an identifiable individual.

9. Cookies & Tracking Technologies

s92bat uses cookies and similar tracking technologies to operate the Platform, personalise your experience and analyse usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled. They include session authentication cookies, security tokens and load-balancing cookies.
• Functional Cookies: Used to remember your preferences, such as language settings, responsible gambling tool configurations and display preferences. Disabling these may affect your experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate and interact with the Platform. This helps us identify improvements and optimise performance for users across Pakistan.
• Marketing and Targeting Cookies: Used only where you have provided consent, to deliver relevant promotional content. You may withdraw consent for these cookies at any time via your browser settings.

Most web browsers allow you to control cookies through browser settings. Restricting or deleting cookies may affect the functionality of certain parts of the Platform. For further guidance on managing cookies, please consult your browser's help documentation.

10. Data Security

s92bat implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• TLS/SSL encryption for all data in transit between your device and the Platform.
• At-rest encryption for stored personal and financial data.
• Access controls restricting Personal Data to authorised personnel on a need-to-know basis.
• Regular security assessments and vulnerability testing of our infrastructure.
• Incident response procedures for detecting and managing personal data breaches.

While we take these measures seriously, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorised access to your account.

11. Your Rights as a Data Subject

Subject to applicable law and our legal retention obligations, you hold the following rights with respect to your Personal Data held by s92bat:

To exercise any of the above rights, please contact us using the details in Section 16. We may need to verify your identity before processing your request. We will respond to all valid requests within 30 days. In complex cases, this may be extended by a further 60 days, in which case we will notify you of the extension and the reasons for it.

12. Children's Privacy

s92bat is strictly an adults-only platform. We do not knowingly collect or process Personal Data from individuals under the age of 18, or the higher minimum age required by the operator's licensing jurisdiction. Age verification is a mandatory step in the registration process.

If we become aware that we have inadvertently collected Personal Data from a person under the applicable minimum age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately using the details in Section 16.

Being aged 18 or over does not, of itself, make gambling lawful in Pakistan. Players are responsible for independently assessing their legal position under applicable local law.

13. Third-Party Links and Services

The Platform may reference third-party brands and services in a contextual capacity — for example, payment brands widely recognised in Pakistan such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are cited for contextual purposes only. None of these institutions endorse s92bat or have any data-processing relationship with us on behalf of users.

This Policy applies only to Personal Data processed by s92bat through the Platform. We are not responsible for the privacy practices of any third-party website, service or application that may be accessible from or referenced on the Platform. If you navigate to a third-party service, we strongly recommend reviewing that party's privacy policy independently.

14. Pakistan Context

s92bat's primary user base consists of individuals located in Pakistan, including players from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We recognise that Pakistan's data protection legislative framework is evolving, and we are committed to aligning our data practices with applicable requirements as they develop.

At present, s92bat processes Personal Data in accordance with the standards described in this Policy and, where applicable, in accordance with the requirements of the jurisdiction in which we hold our operating licence. We do not claim oversight or regulation by any Pakistani government body in relation to data protection.

Given the nature of online gambling services and applicable Pakistani law, including the Prevention of Gambling Act 1977, users in Pakistan should be aware that accessing and using s92bat may itself carry legal implications. This Policy addresses data privacy only and does not constitute legal advice on gambling legality.

15. Amendments to This Policy

s92bat reserves the right to update or revise this Privacy Policy at any time. Where revisions are material — meaning they substantively affect how your Personal Data is processed or the rights available to you — we will endeavour to notify registered users via the email address associated with their account prior to the changes taking effect.

The updated Policy will be published on the Platform with a revised effective date. Your continued use of the Platform following publication of any revised Policy constitutes your acknowledgement of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your information.

16. Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or wish to make a complaint about our data-handling practices, please contact us through the following channels:

• Live Chat: Available 24/7 via the Help Centre on the Platform — the fastest route for urgent data queries.
• Email: [email protected] (plain text — not a clickable link)

Our support team operates in English. Urdu-language data protection assistance can be requested via Live Chat during designated hours. We will acknowledge your request promptly and aim to provide a substantive response within 30 days.

For further information about your data protection rights or to understand how to navigate your rights under applicable law, we recommend consulting a qualified legal adviser in your jurisdiction.