Privacy Policy

p9gam ("p9gam", "we", "us", "our") operates the online sports betting and casino platform available at https://p9gam.cam (the "Platform"). This Privacy Policy ("Policy") sets out in full the basis on which any personal data we collect from you, or that you provide to us, will be processed by p9gam. Please read this Policy carefully so that you understand our practices regarding your personal data and how we will treat it.

This Policy applies to all registered account holders, prospective registrants and visitors to the Platform, regardless of their geographic location. Where specific provisions relate to users based in Pakistan — including data-handling context relevant to players in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — those provisions are identified clearly within the relevant sections.

By registering an account on p9gam, you confirm that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the Platform.

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

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, date of birth, IP address, device identifiers and payment information.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. p9gam is the data controller for all personal data collected through the Platform.
• "Data Processor" — a third party that processes personal data on behalf of and under the instructions of a data controller.
• "KYC" — Know Your Customer: the identity and address verification process required for account activation and withdrawal approval.
• "AML" — Anti-Money Laundering: the regulatory framework requiring us to monitor transactions and report suspicious activity.
• "Cookies" — small text files stored on your device by your browser that enable the Platform to recognise you and maintain session state.
• "Platform" — the p9gam website and all associated features accessible at https://p9gam.cam.

p9gam collects personal data across several categories, depending on the nature of your interaction with the Platform. The following table summarises the categories of data collected, examples of specific data points, and the primary purpose for which each category is used.

We do not collect special categories of personal data (such as health data, biometric data for authentication, or political opinions) beyond what may be required for specific KYC processes, and only where explicitly authorised.

p9gam collects personal data through the following channels and mechanisms:

4.1 Directly from You

• When you complete the account registration form, including providing your name, date of birth, email address and contact details;
• When you submit KYC documentation such as a copy of your CNIC, passport or utility bill;
• When you make a deposit or withdrawal request through the cashier interface;
• When you contact our support team via live chat or email;
• When you configure responsible gambling settings or self-exclusion preferences in your account panel;
• When you respond to surveys, provide feedback, or participate in promotional activities.

4.2 Automatically Through Platform Use

• Technical data such as your IP address, device identifiers and session behaviour is collected automatically when you access the Platform;
• Usage data — including betting and gaming activity — is recorded automatically as you interact with the sportsbook and casino features;
• Cookies and similar tracking technologies collect session data as described in Section 10 of this Policy.

4.3 From Third Parties

• Identity verification service providers may supply supplementary identity data as part of the KYC process;
• Fraud prevention and AML screening services may provide risk scores or flagging information related to your account;
• Payment processors provide transaction confirmation data, including partial payment method references.

p9gam processes your personal data under one or more of the following lawful bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms and Conditions you have accepted, including account management, payment processing and service delivery;
• Legal Obligation: Processing required to comply with KYC, AML, responsible gambling and other regulatory obligations imposed by p9gam's operating licence and applicable law;
• Legitimate Interests: Processing carried out in our legitimate interests — including fraud prevention, Platform security, service improvement and abuse detection — where those interests are not overridden by your fundamental rights and freedoms;
• Consent: Where no other lawful basis applies, we will request your specific, informed consent before processing, which you may withdraw at any time without affecting the lawfulness of prior processing.

p9gam uses the personal data we collect for the following purposes:

• To create, verify and manage your registered Account;
• To process deposits and withdrawals, including reconciling PKR transactions and communicating with payment processors;
• To carry out identity and age verification as required by our operating licence obligations;
• To monitor your account for signs of problem gambling and to make responsible gambling tools available to you;
• To detect, investigate and prevent fraudulent activity, money laundering, bonus abuse and other prohibited conduct;
• To respond to support queries, resolve disputes and maintain complaint records;
• To communicate service updates, security alerts and policy changes to your registered email address;
• To improve the performance, usability and content of the Platform based on aggregated usage analytics;
• To comply with requests from regulatory bodies, law enforcement agencies or courts of competent jurisdiction;
• To enforce our Terms and Conditions and exercise our legal rights.

p9gam does not sell your personal data. We share your data only in the following circumstances and only to the extent strictly necessary:

7.1 Service Providers & Data Processors

We engage third-party service providers who process personal data on our behalf under written data-processing agreements that bind them to confidentiality and security standards consistent with this Policy. Categories of service providers include:

• Identity verification and KYC service providers;
• Payment processing partners (who handle transaction data but do not receive full account profiles);
• Fraud screening and AML compliance technology providers;
• Cloud hosting and data-centre operators who store Platform data in secure, access-controlled environments;
• Customer support platform providers who process support communications;
• Analytics service providers who process aggregated, pseudonymised usage data.

7.2 Regulatory & Legal Disclosure

We may disclose personal data to regulatory authorities, law enforcement agencies, financial intelligence units, or courts where we are legally required to do so. Such disclosures are made only to the minimum extent required by the applicable legal obligation.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of p9gam's business, personal data held by p9gam may be transferred to the successor entity. You will be notified of any such transfer and the privacy protections applicable to your data in advance of the change taking effect.

p9gam retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, regulatory obligation or legitimate business need. The following general retention principles apply:

• Active Account Data: Retained for the duration of your active account relationship with p9gam;
• KYC & Identity Documents: Retained for a minimum of five (5) years following the closure of your account, or longer where required by the AML obligations of our licence jurisdiction;
• Transaction Records: Retained for a minimum of five (5) years following the relevant transaction date, consistent with financial record-keeping requirements;
• Support & Complaint Records: Retained for a minimum of three (3) years following resolution of the relevant query or complaint;
• Technical & Log Data: Typically retained for up to twelve (12) months, unless extended retention is required for security investigation purposes;
• Self-Exclusion Records: Retained for the duration of the exclusion period plus an additional five (5) years to prevent re-registration during the exclusion window.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data subject's identity.

Subject to applicable law and certain limitations, you hold the following rights in respect of your personal data held by p9gam. To exercise any of these rights, please contact us at [email protected] using the subject line "Data Rights Request". We will respond within thirty (30) calendar days, and at no charge for the first request in any twelve-month period.

p9gam uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

10.1 Strictly Essential Cookies

These cookies are necessary for the Platform to function. They enable core features such as session authentication, security token validation, responsible gambling limit enforcement and account state persistence. You cannot opt out of these cookies; disabling them would prevent the Platform from operating correctly.

10.2 Functional Cookies

Functional cookies remember your preferences — such as your chosen display language, notification settings and last-visited sections of the Platform — so that your experience is consistent across sessions. These cookies do not track your activity on external websites.

10.3 Analytics Cookies

We use pseudonymised analytics data to understand how users navigate the Platform, which features are most used and where performance improvements are needed. Analytics data is aggregated and does not identify individual users. You may opt out of analytics cookies by adjusting your browser settings.

p9gam implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• 256-bit Transport Layer Security (TLS) encryption for all data in transit between your device and Platform servers;
• Encryption of sensitive data at rest, including identity documents and financial reference data;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Two-factor authentication options for player accounts and mandatory MFA for administrative access to Platform systems;
• Intrusion detection systems, DDoS mitigation and real-time security monitoring;
• Regular security assessments and penetration testing of Platform infrastructure;
• Staff training on data protection obligations and secure data-handling practices.

While we take all reasonable precautions, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in risk to your rights and freedoms, we will notify you and the relevant supervisory authority within the timeframes required by applicable law.

p9gam operates under a licence from an international jurisdiction. Your personal data may be transferred to and stored in countries outside your country of residence, including countries that may not offer the same level of data-protection legislation as your home country.

Where personal data is transferred internationally, p9gam takes steps to ensure that appropriate safeguards are in place, including contractual clauses with data processors and service providers that require them to protect your data to a standard consistent with the principles set out in this Policy.

The p9gam Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the operator/licence jurisdiction and applicable local law. We do not knowingly collect personal data from persons under the age of 18.

Where we become aware that a minor has accessed the Platform or provided personal data without the necessary parental or guardian consent and in contravention of our eligibility requirements, we will immediately suspend the relevant Account, delete the associated personal data, and return any deposits made, subject to identity confirmation.

If you are a parent or guardian and believe your child has registered an account or provided personal data on the Platform, please contact us immediately at [email protected].

p9gam reserves the right to update this Privacy Policy at any time. Where changes are material — for example, involving new categories of data collection, new sharing arrangements or changes to your rights — we will notify registered users via the email address associated with their Account and post a prominent notice on the Platform no less than fourteen (14) days before the revised Policy takes effect.

Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy. If you do not agree to the revised terms, you must cease using the Platform and may request closure of your Account in accordance with the Terms and Conditions.

The date of the most recent update to this Policy is displayed at the top of this page and in the document metadata section.

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a concern about how your personal data is being handled, please contact our support team using the details below. All data rights requests must include sufficient information to identify your Account.

If you are not satisfied with our response to a privacy concern, you may have the right to lodge a complaint with the supervisory authority in the jurisdiction of p9gam's operating licence, or with any applicable data-protection authority that holds jurisdiction over your complaint. Details of the relevant authority are available on request.