92koko Privacy Policy

This Privacy Policy (hereinafter "Policy") sets out how 92koko (hereinafter "the Platform", "we", "us" or "our") collects, processes, stores, shares and protects personal data relating to individuals (hereinafter "User", "you" or "Player") who access or use the 92koko online casino and sports betting platform available at 92koko.cam.

92koko is committed to handling all personal data responsibly, transparently and in accordance with applicable data protection laws and regulations. We recognise that trust is earned through consistent, respectful data stewardship — and this Policy reflects that commitment to all users of our Platform, including players based across Pakistan, from Karachi and Lahore to Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.

By accessing the Platform, creating a player account or continuing to use any of the Platform's services, you confirm that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any provision of this Policy, you must not use the Platform.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall contractual relationship between you and 92koko.

The following terms carry the meanings set out below throughout this Policy:

• Personal Data — any information that identifies or could reasonably be used to identify a natural person, directly or indirectly, including but not limited to name, email address, date of birth, device identifiers and account activity records.
• 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; in this context, 92koko is the Data Controller.
• Data Processor — a third party that processes personal data on behalf of the Data Controller, under documented instructions.
• Consent — a freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose.
• KYC — Know Your Customer; the identity verification process required of all Players during account registration and before withdrawal processing.
• Cookie — a small data file stored on your device by the Platform that helps recognise your browser or preferences across sessions.
• Data Breach — a security incident that results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

3.1 For the purposes of this Policy, 92koko is the Data Controller in respect of all personal data collected through or in connection with the Platform at 92koko.cam.

3.2 As Data Controller, 92koko determines the purposes for which personal data is collected and the means by which it is processed. Where third-party Data Processors are engaged, they operate under written data processing agreements that bind them to the same data protection standards applied by 92koko.

3.3 If you have any queries, requests or complaints relating to our processing of your personal data, you may contact us using the details set out in Section 17 (Contact Us) of this Policy.

92koko collects personal data in the following categories, depending on how you interact with the Platform:

4.1 Data You Provide Voluntarily. The majority of personal data we hold is provided directly by you during registration, the KYC process or when contacting our support team. You are not obligated to provide this data, but without certain mandatory information (such as identity and contact details), we will be unable to open or maintain your account.

4.2 Data Collected Automatically. Certain technical and usage data is collected automatically through cookies, log files and similar tracking technologies when you access the Platform. Please see Section 11 (Cookies & Tracking) for further details.

4.3 Data from Third Parties. We may receive limited personal data from identity verification service providers, fraud prevention agencies or payment processors in the course of conducting KYC checks and processing transactions. Such data is processed in accordance with this Policy.

92koko processes your personal data on one or more of the following legal bases, as applicable to each processing activity:

• Contractual Necessity — processing required to perform the contract between you and 92koko (e.g., account registration, bet placement, withdrawal processing);
• Legal Obligation — processing necessary to comply with applicable laws, including anti-money laundering (AML) obligations, KYC requirements, gaming licence conditions and tax reporting duties;
• Legitimate Interests — processing necessary for 92koko's legitimate interests where those interests are not overridden by your rights, including fraud prevention, platform security, responsible gambling monitoring and service improvement;
• Consent — processing based on your freely given, specific and informed consent, primarily in relation to optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

We use the personal data we collect for the following purposes:

7.1 We do not sell your personal data. 92koko will never sell, rent, or commercially exploit your personal data to any third party.

7.2 Authorised Third-Party Processors. We share personal data with carefully selected third-party service providers who process data on our behalf and under our documented instructions, solely to enable the Platform's operation. These include:

• Identity verification and KYC service providers;
• Payment processing and fraud prevention services;
• Cloud infrastructure and data hosting providers;
• Customer support platform providers;
• Analytics service providers (using anonymised or aggregated data where possible);
• Email and communications delivery services (for transactional and opted-in marketing communications).

All third-party processors are bound by data processing agreements requiring them to process data only as instructed, to maintain adequate security standards and not to use your data for their own independent purposes.

7.3 Legal Disclosure. We may disclose personal data to competent authorities, regulatory bodies, law enforcement agencies or courts of law where required by applicable law, a court order, or a lawful request from a regulatory authority with jurisdiction over 92koko's operations. We will not disclose more data than is strictly required to comply with such obligations.

7.4 Business Transfers. In the event of a merger, acquisition, restructuring or sale of all or substantially all of the assets of 92koko's operating entity, your personal data may be transferred to the acquiring entity, provided that the acquiring entity maintains equivalent or superior data protection standards. You will be notified of any such transfer in advance where practicable.

8.1 As an internationally operated platform, 92koko and its service providers may process your personal data in jurisdictions outside of Pakistan, including in the jurisdiction of 92koko's operating license.

8.2 Where personal data is transferred to a jurisdiction that does not have equivalent data protection laws, 92koko implements appropriate safeguards to protect the transferred data. These safeguards may include, as applicable: contractual clauses approved by relevant data protection authorities, binding corporate rules, or reliance on the adequacy decisions of the relevant regulatory body.

8.3 By using the Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan in the manner described in this Section.

9.1 92koko retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purpose of satisfying legal, accounting or reporting requirements.

9.2 Specific retention periods applicable to key data categories are as follows:

• Account and identity data: Retained for a minimum of five (5) years following account closure, or such longer period as required by applicable gaming licence conditions or AML regulations;
• Transaction and financial records: Retained for a minimum of five (5) years following the date of the transaction, in compliance with applicable financial record-keeping requirements;
• KYC documentation: Retained for the duration of the account and for a minimum of five (5) years following account closure;
• Support communications: Retained for a minimum of two (2) years following the resolution of the relevant interaction, or longer where the communication relates to an active dispute;
• Technical and usage logs: Typically retained for up to twelve (12) months, unless required for longer for security investigation purposes.

9.3 Following the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

10.1 92koko implements a range of technical and organisational security measures proportionate to the risks presented by the personal data we hold and the nature of our operations. These include:

• SSL/TLS encryption — all data transmitted between your device and the Platform is encrypted in transit;
• Data encryption at rest — sensitive stored data, including KYC documentation and financial records, is encrypted in storage;
• Two-factor authentication (2FA) — available to all Players and strongly recommended for account security;
• Access controls — internal access to personal data is restricted on a need-to-know basis, with role-based permissions and audit logging;
• Regular security testing — our systems are subject to regular vulnerability assessments and penetration testing;
• Employee training — all staff with access to personal data receive appropriate data protection and security awareness training.

10.2 Notwithstanding the above, no method of electronic transmission or storage is completely secure. 92koko cannot guarantee absolute security and accepts no liability for security breaches that occur despite our reasonable and proportionate security measures.

10.3 In the event of a personal data breach that presents a material risk to your rights and freedoms, 92koko will notify affected users without undue delay and report to relevant regulatory authorities as required by applicable law.

11.1 What Are Cookies. Cookies are small text files placed on your device by the Platform. They enable us to recognise your browser across sessions, remember your preferences and gather usage analytics that help us improve the Platform's performance and relevance.

11.2 Types of Cookies We Use. The following categories of cookies may be deployed on the Platform:

• Strictly Necessary Cookies — essential for the Platform to function correctly (e.g., session management, security tokens, login state). These cannot be disabled without affecting core functionality.
• Performance & Analytics Cookies — collect anonymised or aggregated data about how users interact with the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers in identifiable form.
• Functional Cookies — remember your preferences such as language settings, currency display (PKR) and responsible gambling tool states.
• Marketing Cookies — only deployed where you have provided explicit consent. Used to measure the effectiveness of promotional campaigns. You may withdraw consent at any time.

11.3 Managing Cookies. You can manage or delete cookies through your browser settings. Disabling strictly necessary cookies will impair the Platform's functionality. Most browsers allow you to block third-party cookies specifically while allowing first-party cookies, which we recommend as a balanced approach.

11.4 Do Not Track. Some browsers transmit "Do Not Track" signals. As there is no universally agreed standard for responding to such signals, the Platform does not alter its data collection practices in response to browser-level Do Not Track settings.

Subject to applicable law and certain exceptions (including where retention is required by legal obligation), you hold the following rights in respect of your personal data processed by 92koko:

12.1 How to Exercise Your Rights. To exercise any of the above rights, please submit a request to our support team via Live Chat or email. We will respond within thirty (30) days of receipt of a valid request. We may ask you to verify your identity before processing your request.

12.2 Complaints. If you are not satisfied with how we have handled a data protection concern, you have the right to lodge a complaint with the supervisory authority of the applicable licensing jurisdiction. Our support team can provide relevant contact information upon request.

13.1 The Platform is strictly for adults aged 18 years or older, or such higher minimum age as required by the applicable operator or license jurisdiction. 92koko does not knowingly collect personal data from individuals below the minimum age threshold.

13.2 Age verification is conducted as part of the KYC process. Where we discover that personal data has been collected from an underage individual, we will immediately close the associated account and securely delete or anonymise the relevant data, except where retention is required by applicable law.

13.3 Account holders are responsible for ensuring that minors do not access the Platform through their devices, accounts or payment methods.

14.1 92koko sends promotional communications — including information about new games, cricket and PSL season betting markets, bonus offers and platform updates — only to Players who have explicitly opted in to receive such communications during registration or through their account settings.

14.2 Opting Out. You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in the account settings dashboard;
• Clicking the unsubscribe link included in any marketing email; or
• Contacting our support team directly.

Withdrawal of marketing consent does not affect the lawfulness of processing that occurred prior to withdrawal, and does not affect the receipt of transactional communications related to your account (e.g., deposit confirmations, KYC request notifications and withdrawal updates), which are necessary for account operation.

14.3 We do not share your contact details with third-party advertisers or marketers for their independent promotional purposes.

15.1 The Platform may, from time to time, reference or display links to third-party websites, services or resources (for example, responsible gambling support organisations mentioned in the context of player protection). 92koko does not control these third-party sites and is not responsible for their privacy practices or content.

15.2 This Policy applies solely to data collected and processed by 92koko through the Platform. We strongly encourage you to review the privacy policies of any third-party services you access from or in connection with the Platform.

15.3 No personal data is shared with third parties through navigation links on the Platform without your knowledge or consent.

16.1 92koko reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our data processing practices or the nature of the Platform's services.

16.2 Where changes are material, we will provide advance notice via email to your registered address or through an on-platform notification before the revised Policy takes effect. The updated effective date will be prominently displayed at the top of this page.

16.3 Your continued use of the Platform after the effective date of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with a revised Policy, you must cease using the Platform and request account closure.

16.4 Prior versions of this Policy are retained and are available upon written request to our support team.

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by 92koko, please contact us through any of the following channels:

For formal data subject rights requests (access, erasure, portability, etc.), please submit your request in writing via email or Live Chat, along with sufficient information to verify your identity. We will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days.