Privacy Policy — 99sb

1. Introduction

This Privacy Policy ("Policy") describes how 99sb ("we", "us", "our"), the operator of the website located at https://99sb.cam (the "Website"), collects, uses, stores, discloses and otherwise processes personal data in connection with your use of the Website.

This Website is an English-language informational resource for Pakistani players seeking guidance on online sports betting, live casino platforms and responsible gambling practices. We do not operate a gambling platform, accept deposits or hold player funds. As such, the personal data we handle is limited in scope and purpose compared with an operator directly providing gambling services.

By accessing or using this Website, you acknowledge that you have read and understood this Policy. If you do not agree to the practices described herein, please discontinue use of the Website. This Policy should be read alongside our Terms & Conditions.

2. Definitions

The following terms have the meanings given below throughout this Policy:

3. Data Controller

99sb is the Data Controller in respect of personal data processed through this Website. All enquiries relating to data protection, requests to exercise your rights, or concerns about how your data is handled should be directed to us using the contact details provided in Section 17 of this Policy.

We are committed to processing personal data lawfully, fairly and transparently, and only for the purposes described in this Policy.

4. Data We Collect

99sb collects only the minimum data required to operate this informational Website effectively. The categories of data we may collect are as follows:

4.1 Technical & Usage Data (Automatically Collected)

• IP address (typically anonymised at the point of collection);
• Browser type, version and language preference;
• Device type and operating system;
• Pages visited, time on page and navigation paths within the Website;
• Referring URL (the website from which you arrived);
• Date and time of access;
• General geographic location derived from anonymised IP data (country or region level only — we do not pinpoint your city within Pakistan, such as Karachi, Lahore or Islamabad, using this mechanism).

4.2 Contact Enquiry Data (Voluntarily Provided)

If you contact us by email at the address published on this Website, we will receive the personal data you choose to include in that communication, which may include your name and email address. We do not solicit or request sensitive personal data such as CNIC numbers, passport copies, financial account details or gambling account credentials through any contact channel. If you inadvertently include such data in a communication to us, we will not retain it beyond what is necessary to respond to your enquiry.

4.3 Data We Do Not Collect

The following categories of data are not collected by 99sb through this Website under any circumstances:

• Payment card numbers, bank account details or mobile money wallet credentials (e.g., Easypaisa, JazzCash, Raast);
• CNIC numbers, passport numbers or any other government-issued identity document data;
• Gambling account usernames or passwords;
• Biometric data or liveness check results;
• Special categories of personal data as defined under applicable data protection law (e.g., health data, racial or ethnic origin, religious beliefs).

5. How We Collect Data

We collect data through the following mechanisms:

• Automatic collection via server logs and analytics tools: When you visit any page of the Website, our servers and analytics tools automatically record technical and usage data as described in Section 4.1.
• Cookies and similar technologies: The Website uses cookies to improve user experience and understand content performance. Full details are in Section 8.
• Direct communication: When you choose to contact us by email, we receive the personal data contained in that message.

We do not collect data through forms that require login credentials, financial details or identity document uploads. Any visible form-style elements on this Website are static informational layouts and do not transmit data to our servers.

6. Legal Basis for Processing

Where applicable data protection law requires a legal basis for processing personal data, 99sb relies on the following bases:

7. How We Use Your Data

The data we collect is used exclusively for the following purposes:

• Website operation and performance: To serve pages correctly, diagnose technical issues and maintain site security;
• Analytics and content improvement: To understand which guides, sections and topics are most useful to Pakistani players so we can produce better informational content;
• Responding to enquiries: To reply to questions or concerns submitted directly to us by email;
• Legal compliance: To comply with applicable legal obligations, including responding to lawful requests from authorities where required;
• Fraud and abuse prevention: To identify and address misuse or unauthorised access to the Website.

We do not use your data for automated decision-making, profiling in connection with gambling behaviour, or any form of targeted advertising. We do not use data collected through this Website to build marketing lists for gambling operators.

8. Cookies & Tracking Technologies

The Website uses cookies and similar technologies. A cookie is a small text file stored on your device when you visit a website. Cookies allow the site to recognise your browser and remember certain information about your visit.

8.1 Types of Cookies We Use

8.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You may choose to disable cookies entirely, accept only certain types or delete existing cookies at any time. Please note that disabling strictly necessary cookies may affect the functionality of this Website. Browser-based cookie controls are available in the settings or preferences menu of your browser. Instructions vary by browser — consult your browser's help documentation for guidance.

We do not use cookies to track your activity on third-party gambling platforms or to create behavioural advertising profiles.

9. Data Sharing & Disclosure

99sb does not sell, rent or trade personal data to third parties. We may share data in the limited circumstances described below:

9.1 Service Providers (Data Processors)

We may engage third-party service providers who process data on our behalf under written agreements — for example, analytics platforms that help us understand Website traffic. These providers act only on our instructions and are not permitted to use your data for their own purposes. We select providers that offer appropriate data protection standards.

9.2 Legal and Regulatory Disclosure

We may disclose personal data where required to do so by applicable law, court order or the request of an authorised government or law enforcement authority. We will make reasonable efforts to notify you of such disclosures where legally permitted to do so.

9.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of assets involving 99sb, personal data held at that time may be transferred to the successor entity, subject to equivalent privacy protections. Users will be notified of any material change in data controller identity through an update to this Policy.

9.4 Payment Provider References

References on this Website to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah and other Pakistani payment services are made purely as contextual references in editorial content. 99sb does not share personal data with any of these payment providers. These entities are not data processors for 99sb and they do not receive user data through this Website.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our retention practices are as follows:

• Technical and analytics data: Retained in aggregated or anonymised form for up to 24 months to support content improvement analysis, after which it is deleted or further anonymised;
• Email enquiry records: Retained for up to 12 months from the date of final correspondence, after which records are deleted unless a legal obligation requires longer retention;
• Cookie data: Subject to the retention periods specified in the cookie table in Section 8;
• Legally required records: Where applicable law requires us to retain certain records for a specified period, we will do so and delete them promptly once that obligation expires.

11. Data Security

We implement appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration or disclosure. These measures include but are not limited to:

• Serving the Website exclusively over HTTPS with a valid TLS/SSL certificate;
• Restricting access to systems that handle personal data to authorised personnel only;
• Applying access controls and authentication requirements to administrative systems;
• Conducting periodic reviews of our data handling practices.

No transmission of data over the internet is completely secure. While we take all reasonable steps to protect personal data, we cannot guarantee absolute security against all possible threats. In the event of a data breach that is likely to result in risk to your rights and freedoms, we will take steps to contain and assess the breach and notify relevant parties as required by applicable law.

12. International Data Transfers

This Website is operated for an audience primarily based in Pakistan. Some of the service providers we use may process data in countries outside Pakistan. Where such transfers occur, we take steps to ensure that adequate protections are in place, which may include contractual clauses with the receiving party that reflect applicable data protection standards.

By using this Website, you acknowledge that your data may be transferred to and processed in countries other than Pakistan. Where such transfers take place, we apply the protections described above.

13. Your Rights

Depending on applicable law, you may have the following rights in relation to personal data we hold about you. To exercise any of these rights, please contact us using the details in Section 17. We will respond to verified requests within a reasonable timeframe.

Please note that the availability and scope of these rights may vary depending on your location and the applicable law. We will assess each request individually and respond in accordance with our legal obligations.

14. Minors

This Website is intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator or licensing jurisdiction. We do not knowingly collect personal data from persons under the age of 18. If you believe that a minor has provided personal data to us, please contact us immediately at the address in Section 17 and we will take prompt steps to delete that data.

Parents and guardians are responsible for ensuring that minors in their care do not access this Website. 99sb does not operate a parental controls system. We recommend using third-party parental control software to restrict access to online gambling content for minors.

15. Third-Party Websites & References

This Website contains references and descriptive information about third-party online gambling platforms, payment services and technology providers for purely informational and editorial purposes. 99sb is not responsible for the privacy practices of any third party. This Privacy Policy applies solely to data collected through the 99sb Website at https://99sb.cam.

If you navigate from this Website to any third-party operator or service, you will be subject to that party's own privacy policy and terms of service. We encourage you to review those documents carefully before providing personal data to any external platform.

16. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law or operational requirements. When we make material changes, we will update the "Last reviewed" date displayed at the top of this page.

Your continued use of the Website following any update constitutes your acknowledgement of the revised Policy. We recommend reviewing this page periodically. If a change is particularly significant, we may provide a more prominent notice on the Website.

17. Contact Us

For any questions, concerns or requests relating to this Privacy Policy or your personal data, please contact us using the details below. This is a plain text contact reference — the email address is not a clickable link.

If you are not satisfied with our response to a privacy concern, you may have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction. We will cooperate fully with any such authority in the investigation of a complaint.