94win Privacy Policy

Introduction

94win ("we", "us", "our", "the Platform") is committed to protecting and respecting the privacy of all individuals who access and use our services at https://94win.cam. This Privacy Policy ("Policy") describes in detail the types of personal data we collect, the purposes for which we process it, with whom we share it, how long we retain it and the rights available to you in relation to your personal data.

This Policy applies to all users of the 94win platform, including registered account holders and unregistered visitors, regardless of the device or method used to access the platform. This includes users accessing from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and other locations across Pakistan, as well as internationally.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, which together form the complete framework governing your use of 94win. By accessing and using 94win, you acknowledge that you have read and understood this Privacy Policy.

Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or could reasonably identify a living natural person, directly or indirectly.
• "Data Subject" means the identified or identifiable natural person to whom the personal data relates — i.e., you, the user.
• "Data Controller" means the entity that determines the purposes and means of processing personal data. For 94win users, the Data Controller is the operator of the 94win platform.
• "Data Processor" means any person or entity that processes personal data on behalf of the Data Controller.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "KYC" means Know Your Customer — the process of verifying the identity of users for anti-money-laundering and regulatory compliance purposes.
• "Cookies" means small text files placed on your device by a website to store information about your browsing session and preferences.
• "Third Party" means any person or entity other than you, 94win or 94win's authorised data processors.

Personal Data We Collect

94win collects personal data in a number of categories, depending on the nature of your interaction with the platform. The table below sets out the main categories of personal data we collect and typical examples within each category.

How We Collect Personal Data

94win collects personal data through the following mechanisms:

• Direct collection: Information you provide when creating an account, completing KYC verification, making deposits or withdrawals, contacting our support team or updating your account settings;
• Automated collection: Technical and usage data collected automatically when you access the platform, including through cookies, web beacons, log files and similar tracking technologies;
• Third-party sources: Identity verification and fraud-prevention providers may supply additional data to supplement the information you provide directly, for KYC and AML compliance purposes;
• Payment processors: Payment processing partners provide transactional confirmations and limited payment-method identifiers to our systems as part of the deposit and withdrawal workflow;
• Analytics providers: Platform analytics tools provide aggregated behavioural data to help us understand how the platform is used and where improvements are needed.

We do not purchase personal data from data brokers or third-party list providers.

Legal Basis for Processing

Where applicable data protection law requires a legal basis for processing personal data, 94win relies on the following bases:

• Contractual necessity: Processing required to perform our contract with you — creating and managing your account, processing transactions and providing the Services described in our Terms & Conditions;
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC/AML requirements, licensing obligations and law-enforcement requests made under due legal process;
• Legitimate interests: Processing carried out for legitimate business purposes, including fraud prevention, platform security, analytics and service improvement, where such interests are not overridden by your rights and interests;
• Consent: Where we rely on your consent for specific processing activities (such as optional marketing communications), you may withdraw that consent at any time by contacting support or adjusting your account notification preferences.

How We Use Your Personal Data

94win uses personal data for the following purposes:

• Account management: Creating, maintaining and closing your player account; processing login authentication; maintaining your account preferences;
• Transaction processing: Processing deposits, withdrawals and wager settlements; maintaining an accurate transaction history;
• Identity verification: Performing KYC and AML checks as required by applicable regulations prior to withdrawal processing and in response to suspicious activity flags;
• Fraud prevention and security: Detecting, investigating and preventing fraudulent transactions, account abuse, bonus exploitation and other prohibited conduct described in our Terms & Conditions;
• Customer support: Responding to your enquiries, resolving disputes and processing responsible-gambling requests including self-exclusion;
• Platform improvement: Analysing usage patterns and technical performance to improve the platform's functionality, reliability and user experience;
• Responsible gambling: Monitoring account activity for indicators of problem gambling behaviour; applying account limits or self-exclusions as requested or as required by our responsible-gambling obligations;
• Legal and regulatory compliance: Meeting our obligations under applicable gambling regulations, data protection laws and law-enforcement requirements;
• Marketing communications (where consented): Sending promotional offers, bonus notifications and platform news where you have opted in to receive such communications. You may opt out at any time.

Data Sharing & Disclosure

94win does not sell, rent or share personal data for commercial third-party marketing purposes. We may share personal data in the following limited circumstances:

• Service providers and data processors: We engage third-party service providers who process personal data on our behalf — including payment processors, identity verification providers, cloud hosting services, fraud detection vendors and customer support platforms. These processors are bound by data processing agreements and may only process data in accordance with our instructions;
• Regulatory and law-enforcement authorities: We may disclose personal data to competent regulatory authorities, law-enforcement agencies or courts where required by applicable law, a valid legal order or a regulatory compliance obligation;
• Anti-money-laundering compliance: Transaction data and identity information may be reported to relevant financial intelligence authorities in accordance with applicable AML obligations;
• Business transfers: In the event of a merger, acquisition or sale of all or a substantial part of 94win's assets, personal data held by 94win may be transferred to the acquiring entity, subject to equivalent data protection commitments;
• Fraud prevention networks: We may share limited data with industry fraud-prevention networks to identify and prevent patterns of fraudulent activity across platforms.

In each case, data sharing is limited to the minimum necessary for the stated purpose. We do not share payment-provider credentials such as Easypaisa wallet details, JazzCash mobile numbers or bank account information with any third party beyond what is necessary to process the relevant transaction.

Data Retention

94win retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory and operational requirements. The following general retention principles apply:

• Active account data: Personal data associated with an active account is retained for the duration of the account's active status;
• Post-closure retention: Following account closure, we retain personal data for a minimum period required by applicable AML regulations and licensing obligations — typically five (5) to seven (7) years, depending on the applicable jurisdiction;
• KYC documentation: Identity and address verification documents are retained in accordance with the retention schedule required by applicable AML law;
• Transaction records: Financial transaction records, including deposit and withdrawal history, are retained for the period required by applicable financial regulations;
• Support communications: Customer support records are retained for a reasonable period to enable continuity of service and dispute resolution;
• Anonymised analytics data: Aggregated and anonymised usage data from which individual users cannot be identified may be retained indefinitely for platform improvement purposes.

When personal data is no longer required, it is securely deleted or anonymised. We do not retain data beyond what is necessary for the stated purposes or required by law.

Cookies & Tracking Technologies

94win uses cookies and similar tracking technologies to operate and improve the platform. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication tokens, security cookies and load-balancing cookies. These cannot be disabled without impairing platform functionality;
• Functional cookies: Used to remember your preferences — such as language settings, display preferences and responsible-gambling limit settings — so you do not have to re-enter them on each visit;
• Analytics cookies: Used to collect anonymised or pseudonymised data about how users navigate the platform. This helps us identify areas for improvement and understand traffic patterns. We do not use analytics cookies to build individual advertising profiles;
• Security cookies: Used to detect and prevent fraudulent activity, bot access and other security threats.

You may manage and delete cookies through your web browser settings. Please note that disabling cookies may affect the functionality of certain platform features. 94win does not use third-party advertising networks or social media tracking pixels.

Data Security Measures

94win implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• Industry-standard TLS (Transport Layer Security) encryption for all data transmitted between your device and 94win's servers;
• Encryption of sensitive data at rest, including identity documents and financial information;
• Access controls limiting personal data access to authorised staff and systems on a need-to-know basis;
• Regular security assessments and penetration testing of platform infrastructure;
• Two-factor authentication options for administrative and high-privilege account access;
• Incident response procedures for the detection, escalation and notification of personal data breaches.

International Data Transfers

As an online platform serving users internationally, 94win may transfer personal data to servers and service providers located outside of Pakistan and outside of the jurisdiction in which you reside. Such transfers occur in the following circumstances:

• Where cloud hosting or data centre infrastructure is located in a jurisdiction outside Pakistan;
• Where third-party service providers — such as identity verification vendors, payment processors or fraud-detection providers — operate from jurisdictions other than Pakistan;
• Where the operator's licensing jurisdiction differs from the jurisdiction of the user.

In all cases where personal data is transferred internationally, we take steps to ensure that adequate protections are in place, including contractual data transfer mechanisms and vendor due diligence reviews. We do not transfer data to third parties that do not provide adequate data protection commitments.

Your Rights as a Data Subject

Depending on applicable data protection law, you may have some or all of the following rights in relation to your personal data held by 94win. To exercise any of these rights, please contact our support team using the details in Section 16.

We will respond to valid data subject rights requests within a reasonable timeframe, typically within 30 days. We may request proof of identity before actioning any rights request to prevent unauthorised access to personal data.

Minors & Children's Data

94win's services are strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator license jurisdiction. We do not knowingly collect personal data from persons under this age threshold.

If we become aware that personal data has been submitted by a person under the minimum age, we will immediately take steps to close the associated account and delete the data in question. If you are a parent or guardian and believe that a minor in your care has registered an account with 94win, please contact our support team immediately.

Third-Party Links & Services

The 94win platform may from time to time contain references to or integrations with third-party services — such as payment processors, identity verification providers and customer support tools. This Privacy Policy applies only to data processed directly by 94win.

When you interact with a third-party service accessed through or referenced by the 94win platform, that service's own privacy policy will govern the processing of your data by that third party. 94win is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services you use.

References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on this platform are contextual. When you transact through a payment method associated with any of these providers, that provider's terms and privacy practices apply to the data you provide them directly. These providers are not data partners of 94win.

Updates to This Privacy Policy

94win reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or platform operations. When material changes are made, we will:

• Update the "Last updated" date at the top of this document;
• Where reasonably practicable, notify registered users via email or in-platform notification before changes take effect;
• For minor editorial clarifications, update the document without separate notification.

Your continued use of the 94win platform following any update to this Privacy Policy constitutes acceptance of the updated version. We recommend reviewing this Policy periodically, particularly if you have been away from the platform for an extended period.

Contact Us

If you have questions about this Privacy Policy, wish to exercise a data subject right, or have concerns about how your personal data is being handled, please contact 94win's support team using the details below.

We aim to acknowledge all privacy-related enquiries within five (5) business days and to provide a substantive response within thirty (30) days of receipt. For complex requests, we will notify you if an extension of this timeframe is required.