s9gam Privacy Policy

This Privacy Policy ("Policy") describes how s9gam ("s9gam", "we", "us", or "our") collects, processes, stores, and discloses personal information relating to individuals who register an account, access the Platform, or otherwise interact with s9gam's services at s9gam.bio and any associated mobile interfaces (collectively, the "Platform").

This Policy applies to all registered players, prospective users, and visitors to the s9gam Platform, including Pakistani players who access s9gam under applicable international licensing frameworks. By registering an account or continuing to use the Platform after being presented with this Policy, you acknowledge that you have read and understood how s9gam processes your personal data.

This Policy should be read alongside the s9gam Terms and Conditions and Responsible Gaming Policy, both of which are incorporated by reference and together constitute the complete agreement governing your use of the s9gam Platform.

For the purposes of this Policy, s9gam acts as the data controller in respect of the personal information collected from users of the Platform. This means s9gam is responsible for determining the purposes and means by which your personal data is processed.

Where s9gam engages third-party service providers to process personal data on its behalf (for example, payment processors, identity verification providers, or analytics platforms), those third parties act as data processors operating under written data processing agreements with s9gam that impose obligations consistent with this Policy.

You may contact s9gam's data privacy point of contact at any time by writing to [email protected] with the subject line "Data Privacy Enquiry". s9gam will acknowledge all data-related communications within five business days.

s9gam collects the following categories of personal data, depending on the nature of your interaction with the Platform:

s9gam collects personal data through the following channels and mechanisms:

• Direct Collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or updating your account settings.
• Automatic Technical Collection: Data collected automatically when you access the Platform, including server logs, session identifiers, IP addresses, device fingerprinting data, and cookies placed on your browser or device.
• Third-Party Sources: Where required for identity verification or fraud prevention, s9gam may receive data from third-party KYC service providers, payment processors, or publicly available databases. Any third-party data source is subject to appropriate data sharing agreements.
• Responsible Gaming Interactions: When you activate deposit limits, self-exclusion tools, or session limits, s9gam records the settings and timestamps of those responsible gaming elections for regulatory compliance purposes.

s9gam does not collect data from social media platforms unless you have explicitly connected a social login method to your s9gam account. s9gam currently does not offer social login functionality and collects no social media data passively.

s9gam processes personal data for the following purposes:

• Account Management: Creating, maintaining, verifying, and closing player accounts on the s9gam Platform.
• Service Delivery: Enabling access to cricket betting markets, PSL live betting, casino games, slot titles, arcade products, and all other Platform features.
• Payment Processing: Facilitating PKR deposits via JazzCash, EasyPaisa, HBL, UBL, SadaPay, and USDT TRC20, and processing withdrawal requests to verified payment methods.
• Identity Verification and KYC: Verifying player age (21+ requirement), identity, and source of funds as required by applicable regulatory frameworks and s9gam's internal compliance policies.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, bonus abuse, multi-accounting, and other prohibited conduct on the Platform.
• Responsible Gaming: Administering deposit limits, loss limits, session time controls, self-exclusion requests, and reality check notifications elected by players or applied by s9gam's responsible gaming team.
• Customer Support: Responding to enquiries, complaints, and dispute notifications submitted via live chat or email.
• Marketing Communications: Sending promotional materials, bonus notifications, PSL campaign updates, and product announcements — but only to players who have given explicit consent and only through the channels consented to.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the Platform's performance, user experience, game selection, and payment processing speed.
• Legal and Regulatory Compliance: Meeting obligations imposed by applicable licensing authorities, responding to lawful requests from competent authorities, and maintaining records as required by law.

s9gam processes personal data on the following lawful bases as recognised under applicable international data protection frameworks:

• Contract Performance: Processing necessary to deliver the services described in the s9gam Terms and Conditions — including account management, payment processing, and access to Platform features.
• Legal Obligation: Processing required to comply with applicable regulations — including KYC, anti-money laundering, and record retention obligations imposed by s9gam's licensing framework.
• Legitimate Interests: Processing conducted to protect s9gam's platform integrity and the interests of all registered players — including fraud detection, security monitoring, and platform analytics. s9gam applies a legitimate interests assessment before relying on this basis and ensures that processing does not override the fundamental rights and freedoms of data subjects.
• Consent: Processing for marketing communications and non-essential cookies, where explicit consent has been obtained. Consent can be withdrawn at any time from within your s9gam account settings or by contacting support.

s9gam does not sell personal data. s9gam may share personal data with the following categories of third parties, strictly as required to operate the Platform or comply with applicable obligations:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, SadaPay, and USDT TRC20 processors receive the transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are independently regulated.
• Identity Verification Providers: Third-party KYC and anti-money laundering service providers receive identity and verification documents where required to complete player verification processes.
• Platform Technology Providers: s9gam uses third-party hosting, content delivery, and software infrastructure providers who may process technical data (including IP addresses and session data) in the course of delivering Platform services.
• Game Content Providers: Certain aggregated, anonymised game session data is shared with licensed game studios for RTP reporting and technical support purposes. No personally identifiable information is shared with game providers.
• Regulatory and Law Enforcement Authorities: s9gam will disclose personal data to competent regulatory authorities or law enforcement agencies where required by law, pursuant to a valid legal order, or where s9gam has a good-faith belief that disclosure is necessary to protect against fraud, money laundering, or serious harm.

s9gam retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, or to satisfy applicable legal, regulatory, and licensing retention obligations. The following indicative retention periods apply:

• Account and Identity Data: Retained for the duration of the active account relationship, plus a minimum of five years following account closure to meet anti-money laundering and licensing regulatory obligations.
• Transactional and Betting Records: Retained for a minimum of five years from the date of the transaction, in accordance with standard financial record-keeping requirements applicable under s9gam's licensing framework.
• Communication Data (Support Interactions): Retained for three years from the date of the interaction, unless the communication relates to an open dispute or investigation in which case it is retained until final resolution.
• Technical and Session Data: Retained for a maximum of thirteen months from collection, after which it is aggregated, anonymised, or deleted.
• Verification Documents (KYC): Retained for five years following account closure, as required by applicable anti-money laundering regulations.
• Marketing Preference Data: Retained until you withdraw consent. Following consent withdrawal, a record of the withdrawal date is retained to evidence compliance.

Upon expiry of the applicable retention period, personal data is securely and permanently deleted or irreversibly anonymised. Anonymised data may be retained indefinitely for statistical and analytical purposes, as it no longer constitutes personal data.

s9gam implements a layered approach to data security, combining technical, organisational, and procedural controls designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. Key measures include:

• 256-bit TLS encryption on all data transmitted between player devices and s9gam servers.
• Encryption at rest for sensitive stored data, including passwords (bcrypt hashing), financial account references, and identity verification documents.
• OTP-based two-factor authentication available for all s9gam accounts, strongly recommended for all Pakistani players.
• Automated detection systems monitoring for suspicious login attempts, unusual account activity, and indicators of credential stuffing or brute-force attacks.
• Role-based access controls restricting s9gam staff access to personal data to those with a documented operational need.
• Regular internal security audits and periodic independent penetration testing of Platform infrastructure.
• Staff data protection training and a mandatory incident response procedure covering data breach identification, containment, and notification.

Despite these measures, no data transmission over the internet or electronic storage system is completely secure. s9gam will notify affected players of any data breach that is likely to result in a high risk to their rights and freedoms, in accordance with applicable legal requirements.

Subject to applicable law and certain exceptions, registered s9gam players hold the following rights in relation to their personal data:

s9gam uses cookies and similar tracking technologies to operate the Platform, personalise your experience, and analyse usage patterns. Cookies are small data files placed on your device when you access the Platform. The following categories of cookies are used by s9gam:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without preventing use of the Platform.
• Functional Cookies: Enable Platform features such as remembering your language preference, game filter settings, and responsible gaming limit configurations between sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how players interact with the Platform — including most-visited pages, session duration, and error frequency — to help s9gam improve the Platform over time.
• Marketing Cookies: Used to deliver relevant promotional content to players who have consented to marketing communications. These are only activated with your explicit consent.

You may manage cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from using the core s9gam Platform, but may affect the availability of certain personalisation features.

s9gam's services are strictly for individuals aged 21 years and above. s9gam does not knowingly collect or process personal data relating to persons under the age of 21. Age verification is a mandatory step in the s9gam account registration and KYC process.

Where s9gam discovers that personal data has been collected from an individual under the age of 21 — whether through fraudulent registration or any other means — s9gam will immediately suspend the associated account, delete the personal data to the extent not required by regulatory retention obligations, and handle any associated balance in accordance with applicable regulatory guidance.

As an internationally operating platform serving players including those based in Pakistan, s9gam may transfer personal data across international borders — for example, to cloud infrastructure providers, payment processors, or KYC verification services that operate data centres outside Pakistan.

Where such transfers occur, s9gam ensures that appropriate safeguards are in place to protect the transferred personal data to a standard at least equivalent to the protections described in this Policy. Applicable safeguards may include standard contractual clauses, data processing agreements, or adequacy determinations applicable to the destination jurisdiction.

By registering an s9gam account, you acknowledge that your personal data may be transferred and processed outside your country of residence, including to jurisdictions with data protection regimes that differ from those in Pakistan. s9gam implements the safeguards described above to protect your data in all such circumstances.

s9gam reserves the right to update or revise this Privacy Policy at any time. Where changes are material — for example, where we introduce a new category of data collection or change the lawful basis for a significant processing activity — s9gam will notify registered players via email or in-platform notification at least 14 days before the changes take effect.

Non-material amendments — such as typographical corrections, reformatting, or clarifications that do not affect the substance of the Policy — may be published without prior notice. The "Last Reviewed" date displayed at the top of this page will be updated whenever any revision is made.

Continued use of the s9gam Platform following the effective date of any Policy revision constitutes your acceptance of the revised Policy. If you do not accept a revised Policy, you should close your s9gam account before the revised Policy takes effect.

If you wish to exercise any of your data subject rights, have a question about how s9gam handles your personal data, or wish to make a complaint regarding s9gam's data protection practices, please contact s9gam using the following channels:

• Email: [email protected] — please use the subject line "Data Privacy Request" or "Data Protection Complaint" so your message is routed to the appropriate team.
• Live Chat: Available 24/7 from within your logged-in s9gam account. For data-related enquiries, live chat agents will escalate to the data privacy team where the matter cannot be resolved at first contact.

s9gam will acknowledge all data privacy requests within five business days and will endeavour to provide a substantive response — or request any additional information needed — within 30 days of acknowledgement. Where a request is particularly complex or involves a large volume of data, the response period may be extended by a further 30 days, with notice provided to you.

If you believe that s9gam's processing of your personal data infringes applicable data protection law and you are not satisfied with s9gam's internal response, you may have the right to lodge a complaint with the relevant supervisory authority or data protection regulator applicable in your jurisdiction.