n99 Privacy Policy

1 Introduction & Data Controller

n99 ("n99", "we", "our", "us") is committed to protecting the privacy and personal data of all individuals who access or use the n99 platform at n99.bio ("Platform"). This Privacy Policy is issued in accordance with applicable data protection principles and governs the collection, processing, storage, and disclosure of personal data submitted to or collected by n99 in connection with your use of the Platform.

For the purposes of this Policy, n99 is the data controller responsible for your personal data. By registering an account on n99, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2 Data We Collect

n99 collects personal data in the following categories, depending on how you interact with the Platform:

n99 does not collect sensitive personal data categories (such as racial or ethnic origin, health data, or biometric data for identification purposes) except where strictly required for identity verification under applicable regulatory obligations, and only with your explicit consent.

3 How We Use Your Data

n99 uses your personal data only for specific, legitimate purposes. The primary purposes for which we process your data are:

1. Account Registration & Management: To create, maintain, and administer your n99 account, including processing your registration, verifying your identity, managing your login credentials, and communicating account-related information.
2. Payment Processing: To process deposits and withdrawal requests via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and other supported payment methods. Financial data is shared with the applicable payment processor solely for transaction execution.
3. KYC & Fraud Prevention: To verify your identity in compliance with applicable anti-money laundering (AML) and Know Your Customer (KYC) obligations. n99 may use third-party KYC service providers to assist with document verification and liveness checks.
4. Platform Operation & Improvement: To deliver the betting, casino, and gaming services you request; to personalise your experience; to monitor Platform performance; and to identify and resolve technical issues.
5. Responsible Gaming Compliance: To enforce deposit limits, self-exclusion periods, and other responsible gaming controls you have activated, and to identify potentially problematic gambling patterns where required by regulatory obligations.
6. Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only if you have consented to receiving such communications. You may withdraw consent at any time through your account settings.
7. Legal & Regulatory Compliance: To comply with applicable laws, regulations, court orders, and requests from regulatory or law enforcement authorities, including AML reporting obligations.

4 Legal Bases for Processing

n99 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and n99 — including account creation, payment processing, and service delivery.
• Legal Obligation: Processing necessary for n99 to comply with applicable law, including AML/KYC obligations, responsible gaming regulations, and tax reporting requirements.
• Legitimate Interests: Processing necessary for n99's legitimate business interests, including fraud prevention, Platform security, and service improvement — where these interests are not overridden by your fundamental rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and optional data uses. You may withdraw consent at any time without affecting prior processing.

5 Data Sharing & Third Parties

n99 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your data with the following categories of third parties, strictly for the purposes described in this Policy:

• Payment Processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and crypto payment gateways — for the sole purpose of executing your deposit and withdrawal instructions.
• KYC & Identity Verification Providers: Third-party services engaged by n99 to perform CNIC verification, document authentication, and liveness checks in accordance with applicable regulatory requirements.
• Game Providers: Casino game providers whose titles are hosted on or integrated into the n99 Platform may receive session and technical data necessary to deliver the game experience. These providers are contractually prohibited from using your data for their own marketing.
• Technology & Infrastructure Providers: Cloud hosting, content delivery, analytics, and cybersecurity service providers engaged by n99 under data processing agreements that restrict use of your data to n99's instructions.
• Regulatory & Law Enforcement Authorities: n99 will disclose personal data to competent authorities when required by law, court order, or regulatory directive, and where n99 has a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or other illegal activity.

All third parties with whom n99 shares personal data are required to implement appropriate security measures and to process your data only in accordance with n99's instructions and applicable data protection law.

6 Cookies & Tracking Technologies

n99 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function — including session management, login state, and security tokens. These cannot be disabled without impairing Platform functionality.
• Analytics Cookies: Used to understand how players navigate the Platform, which features are most used, and where technical issues occur. Data collected is aggregated and anonymised where possible.
• Preference Cookies: Used to remember your Platform settings, language preferences, and display options between sessions.
• Marketing Cookies: Used to deliver relevant promotional content on the Platform. These are only set with your consent and can be withdrawn at any time through your browser or account settings.

You may control cookie preferences through your browser settings. Blocking essential cookies will impair your ability to log in to or use the n99 Platform.

7 Data Retention

n99 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required for AML compliance.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required for financial regulatory compliance.
• KYC Documents: Retained for a minimum of five (5) years from account closure or the last transaction, whichever is later.
• Support Communications: Retained for three (3) years from the date of the interaction.
• Marketing Consent Records: Retained for three (3) years from the date of consent or withdrawal of consent.

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

8 Security Measures

n99 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Key measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the n99 Platform;
• Encrypted storage of passwords using salted cryptographic hashing — n99 staff cannot view your password in plain text;
• Two-factor authentication (2FA) available for all accounts via SMS OTP;
• Role-based access controls limiting staff access to personal data to those with a legitimate operational need;
• Regular third-party security audits and penetration testing of the Platform infrastructure;
• Automated suspicious login detection and account lockout after repeated failed authentication attempts.

While n99 takes all reasonable precautions, no data transmission or storage system is completely impenetrable. In the event of a data breach that poses a risk to your rights and freedoms, n99 will notify affected users and relevant authorities in accordance with applicable law.

9 Your Rights

Subject to applicable law, you have the following rights in relation to your personal data held by n99:

1. Right of Access: You may request a copy of the personal data n99 holds about you.
2. Right to Rectification: You may request correction of inaccurate or incomplete personal data.
3. Right to Erasure: You may request deletion of your personal data where n99 no longer has a legal basis to retain it. Note that regulatory retention obligations may prevent full erasure in certain cases.
4. Right to Restriction: You may request that n99 restrict processing of your personal data in certain circumstances, such as while a rectification request is being assessed.
5. Right to Data Portability: You may request a machine-readable copy of personal data you have provided to n99, for transfer to another service provider.
6. Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. Marketing objections will be actioned immediately.
7. Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact n99 at [email protected]. n99 will respond to all data rights requests within thirty (30) calendar days.

10 Children's Privacy

The n99 Platform is strictly intended for persons aged 18 years or older. n99 does not knowingly collect personal data from individuals under the age of 18. If n99 becomes aware that personal data has been collected from a minor, such data will be deleted immediately and the associated account will be permanently closed. If you are a parent or guardian and believe your child has registered on n99, please contact our support team at [email protected] immediately.

11 International Data Transfers

n99 may transfer personal data to servers or service providers located outside Pakistan. Where such transfers occur, n99 ensures that appropriate safeguards are in place to protect your data, including contractual clauses requiring the recipient to apply data protection standards equivalent to those described in this Policy. By using the n99 Platform, you consent to such transfers as necessary for the operation of the Platform and processing of your transactions.

12 Changes to This Privacy Policy

n99 reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered users via the mobile number or email address on file, or by posting a prominent notice on the Platform, no less than seven (7) days before the effective date of the change. Continued use of the Platform after the effective date of any amendment constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically.

13 Contact & Complaints

For any questions about this Privacy Policy, to exercise your data rights, or to report a privacy concern, please contact n99's Data Protection team:

• Email: [email protected]
• Live Chat: Available 24/7 within your logged-in n99 account
• Response Time: All data rights requests will receive an initial acknowledgement within 72 hours and a substantive response within 30 calendar days.

If you are not satisfied with n99's handling of a privacy complaint, you may escalate the matter to the applicable data protection authority in your jurisdiction.