Privacy Policy

This Privacy Policy ("Policy") describes how 99as ("Platform", "we", "us", "our"), accessible at https://99as.cam ("Website"), collects, processes, stores, shares and protects personal data relating to individuals who access or use the Website ("Users", "you", "your").

99as is an English-language online betting and casino information platform designed primarily for users in Pakistan. We provide educational and informational content about sports betting, live casino, slot games and responsible gambling. We do not operate as a gambling operator, bookmaker or casino, and we do not process financial transactions on behalf of any betting operator.

We are committed to handling personal data responsibly, transparently and in accordance with applicable data protection principles. This Policy applies to all Users of the Website, regardless of their geographic location, and should be read in conjunction with our Terms & Conditions.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" — Any information that identifies or can reasonably be used to identify a living individual, either directly or in combination with other data. This includes names, email addresses, IP addresses and device identifiers.
• "Processing" — Any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" — The entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, 99as acts as the Data Controller in respect of data collected via the Website.
• "Data Processor" — Any third party that processes Personal Data on behalf of the Data Controller, under instruction and subject to appropriate contractual safeguards.
• "Cookies" — Small text files placed on a User's device by a website to store session information, preferences or tracking data.
• "Consent" — A freely given, specific, informed and unambiguous indication of agreement to the Processing of Personal Data for a stated purpose.
• "Sensitive Data" — A subset of Personal Data warranting enhanced protection, including but not limited to health data, financial account details, and data relating to minors.

99as collects the minimum Personal Data necessary to operate the Website and deliver its informational services. The categories of data we may collect are as follows:

We collect Personal Data through the following means:

• Automatic collection: When you access the Website, our servers and analytics tools automatically record technical and usage data such as your IP address, device type, browser information, pages visited and session duration. This occurs each time any page of the Website is loaded.
• Cookies and similar technologies: The Website may use first-party cookies and, in limited circumstances, third-party cookies from analytics services. These are used to maintain session continuity, analyse aggregate traffic patterns and improve the Website experience. See Section 9 for full details on our Cookie use.
• Direct communications: If you contact us by email at [email protected], we collect the email address and any Personal Data you voluntarily include in your message, such as your name or the nature of your query.
• Consent-based interactions: Where the Website includes optional preference settings or newsletter sign-up fields (static display only — no backend data submission occurs via this Website), any data you choose to enter and explicitly submit via a verified channel is collected with your consent.

99as processes Personal Data only for the following specific, legitimate purposes:

• Platform operation: To deliver, maintain and improve the Website and its content, including diagnosing technical errors, monitoring server performance and ensuring page availability for users across Pakistan and other regions.
• Analytics and performance: To understand how users interact with the Website in aggregate — which pages are most visited, typical navigation paths, device types used — in order to improve content relevance and user experience.
• Security and fraud prevention: To detect and prevent abusive or fraudulent activity, including bot traffic, scraping, denial-of-service attempts or any conduct prohibited under our Terms & Conditions.
• Communications: To respond to enquiries sent to [email protected], including questions about the Website, responsible gambling resources, or privacy rights requests.
• Legal compliance: To meet any legal obligations that apply to 99as as a data controller, including responding to lawful requests from competent authorities where required.
• Responsible gambling awareness: To serve geolocation-relevant notices or responsible gambling reminders where technically possible, supporting our commitment to user wellbeing.

Where applicable data protection law requires a legal basis for processing Personal Data, 99as relies on one or more of the following:

• Legitimate interests: Processing technical, usage and analytics data to operate, secure and improve the Website, provided those interests are not overridden by your rights and interests.
• Consent: Where you have explicitly consented to a specific use of your Personal Data — for example, acceptance of non-essential cookies or voluntary submission of contact information.
• Legal obligation: Where processing is necessary to comply with a legal requirement binding on 99as, such as responding to a lawful data access request from a competent authority.
• Contractual necessity: Where processing is necessary to fulfil obligations arising from the agreement constituted by your acceptance of these Terms — for example, processing your IP address to deliver the Website to your device.

99as retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention principles are:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. You may request earlier deletion of your Personal Data by contacting us — see Section 12 for your rights and Section 16 for contact details.

99as does not sell, rent, lease or otherwise commercially transfer your Personal Data to third parties. We may share Personal Data in the following limited circumstances only:

• Service providers acting as Data Processors: We engage trusted third-party service providers to assist in operating the Website — for example, hosting infrastructure providers and analytics platforms. These providers process data strictly on our instructions, under contractual obligations of confidentiality, and are not permitted to use the data for their own purposes.
• Legal requirements: Where we are compelled by a lawful court order, regulatory directive or other binding legal obligation to disclose data to a competent authority. We will, where legally permitted, notify affected Users of such requests.
• Business transfers: In the event that 99as undergoes a corporate restructuring, merger or acquisition, Personal Data held by 99as may form part of the transferred assets. Any new controller will be required to honour the commitments made in this Policy.
• Protection of rights: Where disclosure is necessary to protect the rights, property or safety of 99as, its Users, or the public — for example, in response to a credible security threat or fraud investigation.

99as uses cookies and similar tracking technologies on the Website. Cookies are small text files placed on your device when you visit a website. They allow the Website to remember your session state and help us understand how users interact with our content.

The cookies we use fall into the following categories:

• Strictly necessary cookies: Required for the Website to function correctly. These cannot be disabled without breaking core Website functionality. They include session management cookies and security tokens.
• Analytics cookies: Used to collect anonymous, aggregated data about how users navigate the Website — page views, session duration, device type and referral source. This data helps us improve the Website experience. Individual users are not identified by analytics data.
• Preference cookies: Used to remember settings or choices you make on the Website — such as language preference or display options — so you do not need to re-enter them on each visit.

We do not use cookies for behavioural advertising, retargeting or any form of cross-site tracking of individual users for commercial profiling purposes.

As an online platform, it is possible that Personal Data collected via the Website may be processed on servers located outside Pakistan. Where such transfers occur, 99as takes reasonable steps to ensure that appropriate safeguards are in place to protect Personal Data to a standard consistent with this Policy.

Safeguards may include contractual protections with our service providers (such as standard contractual clauses or equivalent data processing agreements) that require those providers to protect Personal Data to at least the standard described in this Policy.

By using the Website, you acknowledge and consent to the possible transfer of your Personal Data to servers located in other countries for the operational purposes described in Section 5.

The Website is strictly intended for adults aged 18 years and above, or the higher minimum age required by any applicable jurisdiction or operator licence. 99as does not knowingly collect, process or store Personal Data from individuals under the age of 18.

If we become aware that Personal Data has been collected from a minor without appropriate parental or guardian consent, we will take immediate steps to delete that data from our systems.

Subject to applicable data protection law, you have the following rights in relation to your Personal Data held by 99as. We are committed to facilitating the exercise of these rights promptly and without undue restriction.

To exercise any of the above rights, please contact us at [email protected] with a clear description of your request. We aim to respond to all valid data rights requests within 30 days. We may request verification of your identity before actioning a request to prevent unauthorised access to your data.

99as implements technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, alteration or destruction. Our security practices include:

• Transmission of data between your browser and our servers over HTTPS using TLS (Transport Layer Security) encryption;
• Restricted access controls ensuring that only authorised personnel can access systems processing Personal Data;
• Regular review of access permissions and security configurations;
• Server-side firewalls, intrusion detection and monitoring to identify anomalous activity;
• Periodic assessment of our data processing practices and third-party service provider security standards.

The Website may contain references to third-party websites, platforms or services (including online betting operators, payment service providers or sports organisations). These references are for informational and contextual purposes only.

99as has no control over and assumes no responsibility for the privacy practices, data handling, content or security of any third-party website or service. The inclusion of a reference to or description of a third-party platform on this Website does not constitute an endorsement of that platform's privacy practices.

We strongly recommend that you review the privacy policy of any third-party platform before providing your personal information or engaging with their services. This is particularly important for any online gambling operator whose platform you may consider joining based on information found on the 99as Website.

99as reserves the right to update or revise this Privacy Policy at any time. When we make material changes, we will update the Effective Date shown at the top of this page.

We encourage Users to review this Policy periodically to remain informed of how we handle Personal Data. Where changes are significant, we will endeavour to communicate them via a prominent notice on the Website.

Your continued use of the Website following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with any changes, you should discontinue use of the Website and may contact us to request deletion of your Personal Data.

If you have any questions, concerns or requests relating to this Privacy Policy or the way 99as handles your Personal Data, please reach out to us using the contact details below. We are committed to addressing all privacy-related enquiries promptly and respectfully.

For matters relating to responsible gambling and user wellbeing, please also visit our Responsible Gambling page. For general platform terms, see our Terms & Conditions.