ct99 Privacy Policy — How We Protect Your Personal Data

1. Introduction

This Privacy Policy ("Policy") describes how ct99 ("ct99", "we", "us", "our") collects, uses, stores, shares, and protects the personal data of users ("you", "your", "Player") who access or use the ct99 online casino and cricket betting platform at ct99.ws ("Platform"). This Policy forms part of the ct99 Terms & Conditions and should be read alongside our Responsible Gaming Policy.

ct99 is committed to handling your personal data with integrity, transparency, and in compliance with applicable data protection standards under our international gaming licence. We recognise that players across Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and throughout Pakistan trust us with sensitive personal and financial information, and we take that responsibility seriously.

This Policy applies to all personal data collected through the ct99 website, mobile applications, customer support interactions, and any other channels through which you engage with the ct99 brand.

2. Who We Are

ct99 is the operator of the online gaming platform accessible at ct99.ws. The platform provides Pakistani Rupee (PKR)-denominated casino games, live dealer tables, PSL and international cricket betting, slot games, and related gaming services to eligible players in Pakistan and other permitted jurisdictions.

ct99 operates under an international gaming licence that imposes specific obligations with respect to the collection, retention, and protection of player data, including mandatory Know Your Customer (KYC) and Anti-Money Laundering (AML) verification procedures. These regulatory obligations form a significant part of the lawful basis upon which we process your personal data.

For all privacy-related enquiries, you may contact our Data Protection team via the contact details provided in Section 14 of this Policy.

3. Data We Collect

ct99 collects the following categories of personal data from Players:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued identity document;
• Date of birth (for age verification — players must be 21 or older);
• Residential address (city, district, province);
• National Identity Card (CNIC) number or passport number;
• Username chosen during registration.

3.2 Contact Data

• Email address (primary communication channel);
• Mobile phone number (for account security and notification purposes).

3.3 Financial Data

• Payment method details (JazzCash account number, EasyPaisa wallet, HBL/UBL/Meezan Bank account details, Raast ID) — note that ct99 does not store full card numbers;
• Transaction history including deposits, withdrawals, bonuses credited, and wager records;
• PKR account balance and gaming ledger activity.

3.4 KYC & Verification Documents

• Scanned or photographed copies of government-issued photo ID (CNIC, passport, driving licence);
• Proof of address documentation;
• Proof of payment method ownership where required for withdrawal verification;
• Selfie or liveness-check image where required by our KYC process.

3.5 Technical & Usage Data

• IP address and approximate geolocation derived therefrom;
• Device type, operating system, and browser type;
• Login timestamps and session duration;
• Pages visited, games played, and features used on the Platform;
• Betting patterns and wagering history for responsible gaming monitoring purposes.

3.6 Communications Data

• Records of live chat sessions with ct99 support agents;
• Email correspondence relating to your account;
• Voluntary feedback, survey responses, and complaint submissions.

4. How We Collect Your Data

ct99 collects your personal data through the following channels:

• Direct submission: Information you provide when completing the registration form, submitting KYC documents, making a deposit, or contacting support;
• Automated collection: Technical and usage data collected automatically via cookies, server logs, and analytics tools as you use the Platform;
• Third-party verification: Identity and address data confirmed through our licensed KYC verification providers;
• Payment processors: Transaction confirmation data received from JazzCash, EasyPaisa, Raast, 1LINK, HBL, UBL, and Meezan Bank payment infrastructure;
• Fraud and AML screening: Data received from fraud-prevention and anti-money-laundering screening services in the course of regulatory compliance checks.

5. How We Use Your Data

ct99 uses the personal data we collect for the following purposes:

Purpose	Description
Account Management	Creating, maintaining, and administering your ct99 player account throughout its lifecycle.
Identity Verification	Verifying your age (21+) and identity in compliance with KYC obligations under our gaming licence.
Payment Processing	Processing PKR deposits and withdrawals via JazzCash, EasyPaisa, and bank transfer channels.
Regulatory Compliance	Meeting AML, KYC, and responsible gaming obligations imposed by our international gaming licence.
Security & Fraud Prevention	Detecting and preventing fraudulent activity, money laundering, bonus abuse, and account takeover.
Responsible Gaming	Monitoring betting patterns to identify at-risk behaviour and applying player-requested limits or exclusions.
Customer Support	Responding to enquiries, resolving disputes, and improving the support experience.
Service Improvement	Analysing usage data in aggregate to improve Platform features, game selection, and user experience.
Promotions & Bonuses	Administering bonuses, free bets, and promotions and verifying eligibility in accordance with offer terms.
Communications	Sending transactional notifications, account alerts, and — where you have consented — promotional communications.

6. Legal Bases for Processing

ct99 processes your personal data on the following legal bases, as applicable to each processing activity:

• Contractual necessity: Processing required to perform the contract between you and ct99, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with our obligations under our international gaming licence, including KYC, AML, and responsible gaming requirements;
• Legitimate interests: Processing carried out in pursuit of ct99's legitimate business interests, including fraud prevention, Platform security, and service improvement, where such interests are not overridden by your rights and interests;
• Consent: Processing for which you have given specific, informed consent, including receipt of promotional marketing communications. You may withdraw consent at any time by contacting ct99 support or updating your account preferences.

7. Sharing Your Data

ct99 does not sell or rent your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• KYC verification providers: Licensed identity verification services used to confirm your age and identity in line with regulatory requirements;
• Payment processors: JazzCash, EasyPaisa, Raast, 1LINK, HBL, UBL, Meezan Bank, and other payment infrastructure partners necessary to process your deposits and withdrawals;
• Fraud and AML screening services: Specialist compliance technology providers used to screen transactions and accounts against sanctions lists and fraud databases;
• Game content providers: Software developers whose games are hosted on the ct99 Platform may receive anonymous session data for technical integration purposes only — they do not receive your personally identifiable information;
• Regulatory and law enforcement authorities: Where ct99 is legally required to disclose data under applicable law, court order, or directive from our licensing authority;
• IT infrastructure and security providers: Hosting, cloud storage, and cybersecurity service providers operating under binding data processing agreements with ct99.

8. Data Retention

ct99 retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and our gaming licence obligations. The following general retention periods apply:

• Account data and KYC documents: Retained for a minimum of five (5) years from the date of account closure, in accordance with AML regulatory requirements;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction;
• Communications and support records: Retained for three (3) years from the date of the communication;
• Technical and usage logs: Retained for twelve (12) months from the date of collection, after which they are aggregated and anonymised;
• Marketing consent records: Retained for the duration of consent and for two (2) years following withdrawal of consent as evidence of compliance.

Upon expiry of applicable retention periods, ct99 will securely delete or irreversibly anonymise your personal data so that it can no longer be associated with your identity.

9. Data Security

ct99 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the ct99 Platform;
• Industry-standard password hashing algorithms — ct99 does not store passwords in plaintext;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of Platform infrastructure;
• Encrypted storage of KYC documents and financial records;
• Two-factor authentication (2FA) available for all player accounts;
• Continuous monitoring for suspicious access patterns and anomalous account activity.

While ct99 takes all reasonable steps to protect your data, no online system is entirely immune to security risks. In the event of a data breach that is likely to result in a risk to your rights and freedoms, ct99 will notify affected players and relevant authorities in accordance with applicable obligations under our gaming licence.

10. Cookies & Tracking Technologies

ct99 uses cookies and similar tracking technologies on the Platform to provide core functionality, analyse usage patterns, and where applicable, personalise your experience. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These enable session management, login persistence, and security features. They cannot be disabled without affecting core Platform functionality;
• Analytical cookies: Used to collect aggregated data about how players interact with the Platform, which pages are visited most frequently, and where users encounter difficulties. This data is used to improve the ct99 experience;
• Functional cookies: Remember your preferences such as language settings, responsible gaming limits, and display preferences to provide a more personalised experience;
• Session cookies: Temporary cookies deleted when you close your browser, used to maintain your session state during active gameplay.

You may manage your cookie preferences through your browser settings. Disabling certain categories of cookies may limit your ability to use some features of the ct99 Platform. ct99 does not use advertising or cross-site tracking cookies.

11. Your Data Protection Rights

Subject to applicable law and the regulatory retention obligations imposed by our gaming licence, you hold the following rights with respect to your personal data held by ct99:

• Right of access: Request confirmation of whether ct99 processes personal data about you and, if so, receive a copy of that data;
• Right to rectification: Request correction of any inaccurate or incomplete personal data without undue delay;
• Right to erasure: Request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful — subject to overriding legal retention obligations;
• Right to restriction of processing: Request that ct99 restrict processing of your data in certain circumstances, such as while the accuracy of data is being contested;
• Right to data portability: Receive your personal data in a structured, commonly used, and machine-readable format;
• Right to object: Object to processing of your personal data for direct marketing purposes at any time, and to other processing based on legitimate interests where you have grounds related to your particular situation.

To exercise any of the above rights, please contact ct99 Data Protection using the details in Section 14. ct99 will respond to all valid requests within thirty (30) calendar days. In complex cases or where a large volume of requests is received, this period may be extended by a further sixty (60) days, of which we will notify you in advance.

12. Minors & Age Verification

The ct99 Platform is strictly intended for adults aged 21 years and over. ct99 does not knowingly collect or process personal data from individuals under the age of 21. Age verification is a mandatory step in the ct99 registration and KYC process. Where ct99 has reason to believe that a user is under 21 years of age, the account will be immediately suspended and any funds deposited will be returned to the originating payment method following verification.

If you believe that a minor has registered on the ct99 Platform using false information, please contact our support team immediately. ct99 encourages parents and guardians in Pakistan to make use of parental control software to restrict minors' access to online gaming platforms.

13. Changes to This Privacy Policy

ct99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or operational structure. Where changes are material — meaning they affect your rights or significantly alter how we use your personal data — ct99 will notify registered players by email to the address held on their account at least fourteen (14) days before the changes take effect.

Minor or administrative changes (such as formatting updates or clarifications that do not alter the substance of the Policy) may be made without prior notice, and the "Effective Date" at the top of this Policy will be updated accordingly. We encourage you to review this Policy periodically to stay informed of how ct99 protects your information.

Your continued use of the ct99 Platform after the effective date of any amended Policy constitutes your acceptance of the revised terms.

14. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or wish to raise a complaint about the handling of your personal data by ct99, please contact our Data Protection team using the following details:

• Live Chat: Available through the ct99 Platform, 9:00 AM – 12:00 AM PKT daily
• Email: [email protected]
• Subject line: Please include "Privacy Request" or "Data Subject Request" in your subject line for prompt routing

ct99 takes all privacy complaints seriously and will acknowledge receipt of your complaint within five (5) business days. Where a complaint cannot be resolved through internal channels, you may refer the matter to the relevant supervisory authority under our gaming licence.