How s9game Keeps Your Personal Data Safe

1 Introduction & Scope

s9game is Pakistan's premier online casino and sports betting platform, serving adult players across Karachi, Lahore, Islamabad, Faisalabad, and beyond. The protection of your personal data is a responsibility we take seriously at every level of our organisation — from the engineers who build our platform to the support agents who respond to your queries.

This Policy applies to all personal data collected by s9game through the following channels: the s9game website at https://s9game.club; all associated mobile and web application interfaces; communications via live chat, email, or telephone; and any promotional or marketing activities conducted by s9game on its own platforms. This Policy does not apply to third-party websites or services that may be linked from s9game marketing materials or referenced for player support purposes.

Throughout this Policy, "personal data" means any information that can identify you as an individual, either directly (such as your full name or CNIC number) or indirectly (such as your device identifier or IP address when combined with other data we hold). "Processing" means any operation performed on personal data, including collection, storage, use, sharing, and deletion.

2 Data Controller Information

For the purposes of applicable data protection legislation, s9game acts as the data controller in respect of all personal data collected from players and prospective players via the s9game platform. As data controller, s9game determines the purposes for which your personal data is collected and the means by which it is processed.

Where s9game engages third-party service providers to process personal data on its behalf (for example, payment processors or KYC verification partners), those providers act as data processors and are bound by contractual obligations that require them to process personal data only on s9game's documented instructions and in accordance with applicable data protection law.

3 Data We Collect

s9game collects personal data through several distinct channels and for specific, defined purposes. The categories of personal data we collect are set out in the table below:

3.1 Data You Provide Directly

The majority of personal data s9game holds is provided directly by you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotional activity. You are not obligated to provide personal data, but certain data is required to access specific features of the platform — for example, KYC identity documents are required before withdrawal privileges can be granted.

3.2 Data Collected Automatically

When you visit the s9game platform, our systems automatically collect certain technical data, including your IP address, device identifiers, browser characteristics, and session activity logs. This data is collected to maintain platform security, detect fraud, and analyse platform performance. It is not used to build marketing profiles without your consent.

3.3 Data from Third Parties

s9game may receive limited personal data from trusted third-party partners, including KYC verification service providers (who confirm identity document authenticity), payment processors (who confirm transaction status), and fraud prevention services (who flag suspicious activity patterns). s9game verifies that all third-party data sources operate lawfully and maintain appropriate data protection standards.

4 How We Use Your Data

s9game uses personal data for the following specific and documented purposes:

• Account Management: Creating, maintaining, and securing your s9game account, including verifying your identity during registration and login.
• Service Delivery: Processing deposits and withdrawals, settling bets, awarding bonuses, and delivering all features of the s9game platform to you.
• KYC & Age Verification: Verifying that you are aged 21 or above and that your identity documents are authentic, as required by our international gaming licence.
• Legal & Regulatory Compliance: Meeting our obligations under applicable anti-money laundering (AML) regulations, our gaming licence conditions, and any lawful requests from competent authorities.
• Fraud Prevention & Security: Detecting and investigating suspicious account activity, duplicate registrations, collusion, bonus abuse, and other forms of fraud or cheating on the platform.
• Responsible Gaming: Monitoring gaming patterns to identify signs of problem gambling, administering deposit limits, cooling-off periods, and self-exclusion requests made by players.
• Customer Support: Responding to your enquiries, resolving complaints, and improving the quality of our support services based on interaction records.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent to receive such communications. You may withdraw this consent at any time.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, and the overall player experience for users across Pakistan.

5 Legal Basis for Processing

s9game processes personal data on one or more of the following legal bases, depending on the specific purpose of processing:

• Contractual Necessity: Processing that is necessary to perform the contract between you and s9game — including account creation, deposit and withdrawal processing, bet settlement, and customer support — is carried out on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with AML regulations, gaming licence conditions, KYC verification requirements, and any other applicable legal obligations is carried out on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics is carried out on the basis of s9game's legitimate interests, subject to a balancing test that confirms those interests do not override your fundamental privacy rights.
• Consent: Processing for direct marketing communications and certain non-essential cookies is carried out on the basis of your explicit consent. You may withdraw consent at any time by updating your marketing preferences within your account settings or by contacting support.

6 Sharing & Disclosure of Personal Data

6.1 Third-Party Service Providers

s9game shares personal data with a limited number of carefully selected third-party service providers who assist us in delivering our services. These providers include: payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other approved payment partners); KYC and identity verification service providers; fraud detection and anti-money laundering screening tools; cloud hosting and infrastructure providers; and customer support platform providers. All third-party processors are bound by contractual data processing agreements that restrict their use of your data to the purposes specified by s9game.

6.2 Regulatory & Law Enforcement Disclosure

s9game may be required to disclose personal data to gaming regulators, financial intelligence units, or law enforcement authorities where required by applicable law or a lawful court order. We will inform you of any such disclosure where we are legally permitted to do so.

6.3 No Sale of Personal Data

7 Data Retention

s9game retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or our gaming licence conditions. The following retention periods apply as a general guide:

Once the applicable retention period has expired and there is no ongoing legal, regulatory, or contractual requirement to retain the data, s9game will securely delete or anonymise your personal data. Anonymised data (which can no longer identify you) may be retained indefinitely for statistical and analytical purposes.

8 Security Measures

s9game implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS Encryption: All data transmitted between your browser or app and the s9game servers is protected by Transport Layer Security (TLS 1.2 or higher) encryption, indicated by the padlock icon in your browser address bar.
• Password Hashing: Account passwords are never stored in plain text. They are processed using a one-way cryptographic hashing algorithm with a unique salt per account, ensuring that even in the event of a data breach, passwords cannot be recovered from stored hashes.
• Access Controls: Access to personal data within s9game's internal systems is restricted to staff members who require it to perform their job function. All internal access is logged and subject to periodic review.
• Infrastructure Security: s9game's platform is hosted on enterprise-grade cloud infrastructure with intrusion detection systems, distributed denial-of-service (DDoS) protection, and automated threat monitoring.
• Regular Security Audits: Our platform undergoes periodic penetration testing and security assessments conducted by independent third-party security specialists.
• Incident Response: s9game maintains a documented data breach response procedure. In the event of a data breach that poses a risk to players, we will notify affected individuals and the applicable regulatory authority within the timeframe required by applicable law.

9 Cookies & Tracking Technologies

The s9game platform uses cookies and similar tracking technologies to deliver a functional, secure, and personalised gaming experience. A cookie is a small text file placed on your device by a website server. Cookies cannot execute programs or deliver viruses to your device, and they can only be read by the server that placed them.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the s9game platform to function correctly. They enable core features such as secure login sessions, navigation between pages, and shopping cart / cashier functionality. These cookies cannot be disabled without impairing platform functionality.
• Functional Cookies: These cookies remember your preferences — such as your preferred language, display settings, and responsible gaming tool configurations — to personalise your experience on subsequent visits.
• Analytical Cookies: We use analytical cookies to understand how players interact with the s9game platform — which pages are most visited, how long sessions last, and where players encounter difficulties. This data is used exclusively to improve platform design and performance. Analytical data is aggregated and anonymised where possible.
• Marketing & Session Cookies: Where you have given your consent, s9game may use session-based cookies to track referral sources and ensure that promotional offers are attributed correctly. These cookies do not track your activity across unaffiliated third-party websites.

9.2 Managing Cookies

You can manage your cookie preferences at any time through the cookie consent banner displayed on your first visit to the s9game platform, or by adjusting the settings in your web browser. Please note that disabling strictly necessary cookies may prevent some features of the platform from functioning correctly. For detailed guidance on managing cookies in your specific browser, please refer to the browser's official help documentation.

10 Your Privacy Rights

Subject to applicable data protection law and certain legal exceptions, s9game players have the following privacy rights in relation to their personal data:

• Right of Access: You have the right to request a copy of all personal data that s9game holds about you. We will provide this within 30 calendar days of receiving a valid request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure: You may request that s9game delete your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and there is no other legal basis for processing), or where the data has been processed unlawfully. Please note that this right is subject to our legal and regulatory retention obligations — in particular, AML regulations require us to retain certain financial records for a minimum of five years regardless of account status.
• Right to Restriction: You may request that s9game restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to Object: You have the right to object to processing based on s9game's legitimate interests at any time. You also have an absolute right to object to processing for direct marketing purposes, which will be honoured without question.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please submit a written request to our Data Protection team at the email address listed in Section 2. We may ask you to verify your identity before processing a rights request. If you are not satisfied with our response, you have the right to lodge a complaint with the applicable data protection supervisory authority.

11 Protection of Minors

s9game operates an age-restricted platform that is strictly prohibited for individuals under the age of 21. We take the protection of minors extremely seriously and implement multiple layers of controls to prevent underage access to our gaming services.

During the registration process, all applicants are required to confirm that they are aged 21 or above. Before withdrawal privileges are granted, every s9game player must complete a KYC verification process that includes submission of a valid government-issued identity document confirming date of birth. Accounts where the KYC process reveals that the registered player is under 21 will be closed immediately, all gaming activity will be voided, and any deposited funds will be returned to the source payment method.

Parents and guardians who are concerned about underage access to online gambling platforms are encouraged to use parental control software to restrict access to gambling websites on shared or family devices. s9game also recommends keeping account login credentials strictly private and logging out of your account after every session on shared devices.

12 International Data Transfers

s9game operates as an internationally licensed online gaming platform, and some of our service providers and infrastructure partners are located in countries outside Pakistan. As a result, your personal data may be transferred to and processed in countries that have different data protection standards from those applicable in Pakistan.

Where such international transfers occur, s9game ensures that appropriate safeguards are in place to protect your personal data. These safeguards may include: standard contractual clauses approved by relevant data protection authorities; binding corporate rules where transfers occur within a group of companies; or the use of service providers located in countries that have been assessed as providing an adequate level of data protection.

13 Policy Updates

s9game reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our gaming licence conditions. Where changes are material — meaning they could significantly affect your privacy rights or the way your personal data is used — we will provide reasonable advance notice by email to your registered address or via a prominent notice on the s9game platform.

The updated Privacy Policy will take effect on the date stated in the "Last Updated" notice at the top of this page. Your continued use of the s9game platform after that date constitutes your acceptance of the updated Policy. If you do not agree with any changes to this Policy, you should stop using the platform and may request account closure in accordance with our Terms & Conditions.

We recommend that you review this Privacy Policy periodically to stay informed about how s9game protects your personal data. The version of this Policy currently published at https://s9game.club/privacy-policy supersedes all prior versions.

14 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or about the way s9game processes your personal data, we encourage you to contact us in the first instance using the details below. Our Data Protection team is committed to responding to all privacy-related enquiries promptly and thoroughly.

We aim to acknowledge all written privacy enquiries within 48 hours and to provide a substantive response within 30 calendar days. Where a request is particularly complex or where a large volume of requests has been received, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it before the initial 30-day period expires.

If you are not satisfied with our response to your complaint or data subject rights request, you have the right to escalate the matter to the applicable data protection supervisory authority in your jurisdiction. s9game will cooperate fully with any investigation conducted by a supervisory authority in connection with a player complaint.