92bar Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 92bar ("Company", "we", "us", "our") collects, uses, stores, discloses, and protects the personal data of individuals ("Player", "User", "you") who access or use the online casino and sports betting platform available at 92bar.ws ("Platform"). This Policy applies to all users of the Platform regardless of the device or method through which they access it.

92bar is committed to handling your personal data responsibly, transparently, and in compliance with the data protection obligations imposed by its international gaming licence authority. By registering a 92bar account or otherwise using the Platform, you confirm that you have read and understood this Policy and that you consent to the collection and use of your data as described herein.

This Policy should be read together with our Terms & Conditions, which also form part of your agreement with 92bar. In the event of any conflict between this Policy and the Terms & Conditions on data-related matters, this Policy shall prevail.

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2. Data Controller

For the purposes of applicable data protection law, the data controller responsible for your personal information is 92bar, operating the Platform at 92bar.ws under international gaming licence oversight. All data protection queries, subject access requests, and complaints should be directed to our dedicated privacy contact at [email protected], clearly marked "Privacy — Data Request" in the subject line.

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3. Personal Data We Collect

92bar collects the minimum personal data necessary to operate your account, process your transactions, and comply with our regulatory obligations. The categories of personal data we collect include:

We do not knowingly collect special category data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) beyond what may be incidentally apparent from identity documents submitted for KYC purposes, and we do not use such data for profiling or any purpose beyond regulatory identity verification.

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4. How We Collect Your Data

92bar collects your personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or filling in any form on the Platform.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including via cookies, server logs, and device fingerprinting technologies used for fraud prevention.
• Third-party verification: Identity and address verification data obtained from KYC/AML service providers engaged by 92bar for compliance purposes, operating under equivalent data protection standards.
• Payment processors: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency payment gateways when you make deposits or withdrawals.

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5. How We Use Your Personal Data

92bar uses your personal data only for the following purposes:

• Creating, verifying, and managing your 92bar player account
• Processing deposits and withdrawals in PKR via your chosen payment method
• Verifying your identity and age (21+) in compliance with our gaming licence obligations
• Detecting, investigating, and preventing fraud, money laundering, and other prohibited conduct
• Monitoring your gaming activity for responsible gaming purposes, including identifying signs of problem gambling and applying any self-imposed limits or exclusions you have requested
• Providing customer support via live chat and email
• Sending transactional communications related to your account (e.g., deposit confirmations, withdrawal notifications, security alerts)
• Sending promotional communications about 92bar bonuses, offers, and new features — but only where you have opted in to receive such communications and subject to your right to opt out at any time
• Complying with legal obligations imposed by our international gaming licence and applicable anti-money laundering regulations
• Resolving disputes and enforcing our Terms & Conditions

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6. Legal Basis for Processing

92bar processes your personal data on the following legal bases, depending on the nature of the processing activity:

• Contractual necessity: Processing required to perform the contract between you and 92bar — including account creation, payment processing, and the provision of gaming services.
• Legal obligation: Processing required to comply with regulatory requirements under our international gaming licence, including KYC/AML verification, age checks, and responsible gaming monitoring.
• Legitimate interests: Processing necessary for 92bar's legitimate business interests, including fraud prevention, platform security, and improvement of the Platform, where such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed consent — primarily in the context of marketing communications and optional analytics. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

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7. Data Sharing & Disclosure

92bar does not sell, rent, or share your personal data with third parties for their own marketing or commercial purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency payment processors — solely to facilitate your deposits and withdrawals.
• KYC/AML providers: Identity verification and anti-money laundering screening services engaged by 92bar to fulfil its licence compliance obligations.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers operating under binding contractual data protection obligations on 92bar's behalf.
• Gaming software providers: Game developers and live dealer studios whose games are hosted on the 92bar platform, where sharing of session data is technically necessary for game delivery.
• Regulatory and law enforcement authorities: Where required by our gaming licence authority, a court order, or applicable law — including disclosures required under anti-money laundering or counter-terrorism financing regulations.
• Professional advisers: Lawyers, auditors, and insurers, where disclosure is necessary and subject to professional confidentiality obligations.

All third parties with whom we share personal data are required to handle that data in accordance with applicable data protection standards and are prohibited from using it for any purpose beyond that for which it was shared.

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8. International Data Transfers

As 92bar operates under an international gaming licence and uses globally distributed infrastructure, your personal data may be transferred to and processed in countries outside Pakistan. Where such transfers occur, 92bar ensures that appropriate safeguards are in place to protect your data, including:

• Transfers to countries recognised as providing an adequate level of data protection by the relevant licensing authority
• Data processing agreements incorporating standard contractual clauses approved by relevant data protection authorities
• Binding corporate rules where applicable within the 92bar group of companies

By using the 92bar platform, you acknowledge that your personal data may be transferred, stored, and processed in jurisdictions outside Pakistan. 92bar takes all reasonable steps to ensure that any such transfers are subject to appropriate protections consistent with this Policy.

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9. Data Retention

92bar retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying our legal, regulatory, accounting, and reporting obligations. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your active account plus a minimum of 5 years after account closure, as required by our gaming licence and AML obligations.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, in line with standard financial record-keeping requirements.
• Gaming history: Retained for a minimum of 3 years from the date of each gaming session, for responsible gaming monitoring and dispute resolution purposes.
• Support communications: Retained for a minimum of 2 years from the date of last communication, for quality assurance and compliance purposes.
• Marketing consent records: Retained for the duration of your consent plus 1 year after withdrawal, to evidence compliance with marketing consent requirements.

When personal data is no longer required, it is securely deleted or anonymised in accordance with our internal data destruction procedures.

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10. Security Measures

92bar implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit TLS encryption for all data in transit between your device and 92bar servers
• AES-256 encryption for sensitive data at rest, including identity documents and financial records
• Multi-factor authentication options for player accounts
• Role-based access controls limiting data access to authorised personnel only
• Regular third-party penetration testing and security audits of the Platform
• Real-time intrusion detection and anomaly monitoring systems
• Comprehensive staff training on data handling and privacy obligations

While 92bar takes all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 92bar will notify affected players and the relevant regulatory authority within the timeframes required by applicable law.

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11. Cookies & Similar Technologies

92bar uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without impairing Platform functionality.
• Analytical cookies: Used to collect anonymised data about how players navigate and use the Platform, enabling us to identify areas for improvement and optimise the user experience. No personally identifiable information is shared with analytics providers.
• Fraud prevention cookies: Used alongside device fingerprinting to detect suspicious activity, multiple account registrations from a single device, and other forms of abuse or fraud.

92bar does not use advertising or cross-site tracking cookies. You can control cookie settings through your browser preferences. Note that disabling essential cookies may prevent certain features of the Platform from functioning correctly.

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12. Your Data Rights

Subject to applicable law and our regulatory obligations, you have the following rights regarding the personal data 92bar holds about you:

• Right of access: You may request a copy of the personal data we hold about you (a "Subject Access Request"). We will respond within 30 days of receipt.
• Right to rectification: You may request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected. Note that we may be required to retain certain data to comply with our legal and regulatory obligations even after account closure.
• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances, such as while a dispute about accuracy is being resolved.
• Right to data portability: Where processing is based on your consent or contractual necessity and carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing of your personal data where we rely on legitimate interests as the legal basis, and we will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us at [email protected] with the subject line "Privacy — Data Request". We may need to verify your identity before processing your request. There is no charge for exercising your rights, and we will respond within 30 days in the majority of cases.

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13. Protection of Minors

The 92bar platform is strictly restricted to persons aged 21 years and above. 92bar does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the data, and where applicable return any deposited funds.

If you are a parent or guardian and believe that a person under 21 in your care has registered an account on 92bar, please contact us immediately at [email protected] so that we can take prompt action.

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14. Changes to This Privacy Policy

92bar reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or operational procedures. Where changes are material, we will provide advance notice by email to your registered address and/or by displaying a prominent notice on the Platform for a minimum of 7 days before the updated Policy takes effect.

The date of the most recent revision is always shown at the top of this Policy. Your continued use of the 92bar platform after the effective date of any amendment constitutes your acknowledgement of the revised Policy. If you do not agree with the changes, you should stop using the Platform and request account closure.

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15. Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way 92bar handles your personal data, please contact us through any of the following channels:

• 📧 Email: [email protected] (subject line: "Privacy — Data Request")
• 💬 Live Chat: Available 24/7 via the chat icon on the 92bar platform
• ⏱️ Response Times: Under 3 minutes via Live Chat | Under 2 hours via Email

We take all privacy complaints seriously and will investigate your concern thoroughly. If you are not satisfied with our response, you have the right to escalate your complaint to the data protection supervisory authority in the jurisdiction applicable to your situation or to the dispute resolution body specified by our gaming licence authority.