Privacy Policy – 92 Dada and How We Handle Your Personal Data

1. Who We Are

92 Dada is an online gaming and sports betting platform serving the Pakistani market at https://92dada.bet. When this Privacy Policy refers to "92 Dada", "we", "us", or "our", it refers to the operating entity behind the 92 Dada platform. When it refers to "you", "your", or "player", it refers to you as a registered account holder or visitor to the platform.

For data protection purposes, 92 Dada acts as the data controller for all personal information collected through the platform. This means we determine the purposes and means by which your personal data is processed and we are responsible for ensuring it is handled lawfully and in accordance with applicable data protection standards.

If you have any questions about how 92 Dada handles your data, you can contact our Data Privacy team at any time at support@92dada.bet with the subject line "Privacy Enquiry".

2. What Personal Data We Collect

92 Dada collects only the data we genuinely need to provide you with a safe, functional, and legally compliant gaming experience. The categories of personal data we collect are:

We do not collect sensitive personal data such as health information, religious beliefs, or biometric data except where specifically required by law or regulation and with your explicit consent.

3. How We Collect Your Data

92 Dada collects personal data through the following channels:

• Direct collection: Data you actively provide during registration, KYC verification, deposit and withdrawal processes, and when contacting customer support.
• Automated collection: Technical and usage data collected automatically when you use the platform through cookies, log files, and similar tracking technologies. See Section 9 for full cookie details.
• Third-party sources: Identity verification data from KYC providers we use to confirm the accuracy of documents you submit. Fraud and risk data from payment processors where relevant to protecting your account or the platform's integrity.

4. Why We Use Your Personal Data

Every piece of data 92 Dada collects has a specific, documented purpose. We do not collect data speculatively or hold it "just in case". The primary purposes for which we use your data are:

• Account creation and management: Setting up, verifying, and maintaining your 92 Dada account so you can access the platform securely.
• Processing transactions: Handling your deposits, bets, game play, and withdrawal requests accurately and in PKR without error.
• Identity and age verification: Confirming that you are who you say you are and that you meet the minimum age requirement of 18 years.
• Fraud and security: Detecting and preventing fraudulent account activity, unauthorised access, money laundering, and other illegal activity on the platform.
• Responsible gaming: Monitoring usage patterns to identify signs of problem gambling behaviour and, where appropriate, proactively offering support tools to affected players.
• Customer support: Responding to your queries, resolving disputes, and providing assistance with your account.
• Platform improvement: Understanding how players use the platform so we can improve features, fix bugs, and develop new games and products that Pakistani players actually want.
• Legal compliance: Meeting our obligations under applicable gaming regulation, anti-money laundering requirements, and tax reporting where applicable.
• Communications: Sending you account notifications, transaction confirmations, and where you have opted in, promotional information about 92 Dada offers.

5. Legal Basis for Processing

92 Dada processes your personal data under the following legal grounds, depending on the specific purpose:

• Contract performance: Processing necessary to deliver the services described in the Terms and Conditions you agreed to at registration – including running your account, processing transactions, and settling bets.
• Legal obligation: Processing required by applicable law, including KYC identity verification, anti-money laundering checks, and regulatory reporting.
• Legitimate interests: Processing carried out for fraud prevention, platform security, and improving the service, where those interests are not overridden by your rights and interests.
• Consent: Processing based on your explicit consent, such as receiving marketing communications. You may withdraw consent for marketing at any time by contacting support@92dada.bet or using the unsubscribe option in our emails.

6. Who We Share Your Data With

92 Dada does not sell, rent, or trade your personal data to any third party. We share data only in the following specific and necessary circumstances:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, and card processing partners receive the minimum data required to process your deposits and withdrawals. They are bound by their own privacy and security obligations.
• KYC and identity verification providers: Third-party services used to verify your identity documents during the KYC process. These providers are contractually required to process your data only for verification purposes.
• Regulatory and law enforcement authorities: We share data with gaming regulators, financial intelligence units, or law enforcement agencies where legally required or where there is a legitimate legal obligation to do so.
• IT and infrastructure providers: Hosting, cloud storage, and security providers who process data on our behalf under contractual data processing agreements that restrict their use of your data.
• Fraud prevention services: Industry fraud prevention networks that allow gaming platforms to share confirmed fraud data to protect all players and platforms from known bad actors.

7. International Data Transfers

Some of 92 Dada's service providers and technical infrastructure are located outside Pakistan. Where your personal data is transferred to a country that does not have equivalent data protection standards to those that apply to our platform, we ensure that appropriate safeguards are in place.

These safeguards typically include contractual clauses requiring the recipient to protect your data to the same standard that applies under this Privacy Policy, or reliance on the recipient being located in a jurisdiction with recognised adequate data protection frameworks.

If you would like more information about the specific safeguards in place for any particular data transfer, please contact us at support@92dada.bet.

8. How Long We Keep Your Data

92 Dada keeps your personal data for as long as necessary to fulfil the purpose for which it was collected, and for as long as required by applicable law. The general retention guidelines we follow are:

• Account data: Retained for the lifetime of your account and for a minimum of five years after account closure to meet anti-money laundering and regulatory record-keeping requirements.
• Transaction and betting records: Retained for a minimum of five years from the date of the transaction.
• KYC documents: Retained for a minimum of five years from the date of verification, or longer if required by applicable regulation.
• Support communications: Retained for three years from the date of the interaction unless the communication relates to a dispute that is still open or being reviewed.
• Technical and log data: Typically retained for 12 months from collection for security and platform improvement purposes.
• Marketing consent records: Retained for the period of active consent plus three years to demonstrate compliance.

When retention periods expire, data is securely deleted or anonymised so it can no longer be linked to you. Data that has been anonymised may be retained indefinitely for statistical and analytical purposes.

9. Cookies and Tracking Technologies

92 Dada uses cookies and similar technologies to make the platform work correctly and to understand how players use it. A cookie is a small text file stored on your device when you visit a website. Here are the types of cookies we use:

You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect platform functionality. Most modern mobile browsers on Android and iOS include cookie management options in their privacy or site settings menu.

10. Your Data Rights

You have clear rights over your personal data held by 92 Dada. These rights can be exercised free of charge by contacting us at support@92dada.bet with the subject line "Data Rights Request". We will respond within 30 days of receiving a valid request.

Please note that some rights may be limited where we are required by law to retain certain data, for example transaction records held for anti-money laundering compliance purposes. We will always explain clearly if a right cannot be fully exercised in a specific case and why.

11. Children and Minors

92 Dada is strictly an 18+ platform. We do not knowingly collect, store, or process personal data belonging to anyone under the age of 18. If you are under 18, you must not attempt to create an account, deposit funds, or place any bet on the platform.

If 92 Dada becomes aware that an account belongs to a person under 18, the account will be immediately suspended, any remaining balance will be withheld pending investigation, and any personal data relating to that minor will be deleted as quickly as legally possible.

If you have reason to believe that a minor has registered an account on 92 Dada, please contact us immediately at support@92dada.bet so we can investigate and take appropriate action.

12. How We Protect Your Data

Protecting your personal data is a core operational responsibility at 92 Dada. The technical and organisational measures we maintain include:

• TLS/SSL encryption: All data transmitted between your device and 92 Dada's servers is encrypted using industry-standard Transport Layer Security protocols.
• Encrypted data storage: Sensitive data including payment details and KYC documents is stored in encrypted form. Encryption keys are managed separately from the data they protect.
• Access controls: Personal data is accessible only to 92 Dada staff and systems that genuinely need it to perform their function. Access is logged and regularly reviewed.
• Regular security testing: The platform undergoes regular vulnerability assessments and penetration testing to identify and address security weaknesses before they can be exploited.
• Incident response: We maintain a documented data breach response procedure. In the event of a breach that is likely to affect your rights and freedoms, we will notify you and relevant authorities in accordance with applicable requirements without undue delay.

No security system is completely impenetrable. You also have a role to play in keeping your account secure. Use a strong, unique password for your 92 Dada account, enable two-factor authentication if offered, and never share your login credentials with anyone.

13. Changes to This Privacy Policy

92 Dada may update this Privacy Policy from time to time to reflect changes in our practices, the services we offer, or applicable legal requirements. The "Last Updated" date at the top of this page will always reflect when the policy was most recently revised.

For material changes – meaning changes that significantly affect how your data is used or your rights under this policy – we will notify registered account holders via email at least seven days before the changes take effect. For minor clarifications or corrections that do not substantively change the policy's meaning, we may update without separate notification beyond the change in the "Last Updated" date.

We recommend bookmarking this page and reviewing it periodically, particularly if you are a regular 92 Dada player. Continued use of the platform after a revised policy takes effect constitutes acceptance of the updated terms.

14. Contact Us and Complaints

If you have any questions about this Privacy Policy, how 92 Dada handles your personal data, or if you want to exercise any of your data rights, please contact us through the following channels:

• Email: support@92dada.bet (subject line: "Privacy Enquiry" or "Data Rights Request")
• Live Chat: Available in your account dashboard 24 hours a day, 7 days a week for straightforward privacy queries.
• Response time: We aim to respond to all privacy-related enquiries within 24 hours and to complete formal data rights requests within 30 days of receipt.

If you are not satisfied with how 92 Dada has handled a privacy concern, you have the right to escalate your complaint to the relevant data protection authority in the jurisdiction applicable to our operating licence. We will always provide you with the relevant contact details if asked.

This Privacy Policy was last reviewed and updated in January 2025 and supersedes all previous versions.