92ro Privacy Policy

1.1 For the purposes of this Privacy Policy, the data controller responsible for your personal data is 92ro, the operator of the online gaming platform accessible at 92ro.net. 92ro operates under an international gaming license and is subject to the data protection and privacy obligations imposed by that licensing authority as a condition of operation.

1.2 References to "92ro", "we", "us", or "our" in this Privacy Policy refer to the platform operator. References to "you", "your", or "the player" refer to any individual whose personal data is collected or processed by 92ro in connection with their use of the platform.

1.3 If you have questions about how 92ro processes your personal data, or if you wish to exercise any of the rights described in Section 9, you may contact the 92ro Data Protection team by email at [email protected] with "Privacy" in the subject line. We will acknowledge your inquiry within 48 hours.

2.1 92ro collects personal data through a number of channels and at various stages of the player lifecycle. The categories of personal data we collect are set out below.

Registration Data

When you create a 92ro account, we collect your full legal name as it appears on your CNIC, your date of birth, your Pakistani mobile phone number, your email address, and your current residential address. This information is required to create and operate your account and to verify that you meet the 21+ age requirement.

Identity Verification (KYC) Data

To comply with the requirements of our gaming license and to prevent money laundering and underage gambling, we collect copies of your CNIC (front and back), and where required, additional documents such as a utility bill or bank statement confirming your address, and documentation evidencing source of funds for higher-volume accounts.

Financial Data

When you make deposits or withdrawals, we collect the information necessary to process those transactions, including your JazzCash or EasyPaisa wallet number, bank account details where applicable, and transaction amounts. We do not store full payment credentials beyond what is required to process and verify transactions. USDT TRC20 wallet addresses are retained for transaction record purposes.

Gameplay and Betting Data

92ro records all gameplay activity on the platform, including all bets placed, game sessions, wager amounts, outcomes, and bonus activity. This data is essential for the operation of the platform, for the resolution of disputes, and for compliance with our licensing authority's record-keeping obligations.

Technical and Device Data

We automatically collect technical data when you access the platform, including your IP address, device type and model, operating system, browser type and version, and session duration. This data is used for security monitoring, fraud prevention, platform optimisation, and geo-restriction enforcement.

Communications Data

When you contact 92ro support via live chat, email, or any other channel, we retain records of those communications including the content, timestamps, and the support agent's responses. This data is used for quality assurance, training, and the resolution of complaints.

3.1 92ro uses personal data for the following purposes. The legal basis for each use is identified in Section 4.

4.1 Contract Performance. The majority of the personal data 92ro processes is necessary to perform the contract between you and 92ro — that is, to provide you with access to the platform, process your bets and transactions, manage your account, and deliver the gaming and betting services you have requested.

4.2 Legal Obligation. Certain processing is required by the conditions of 92ro's international gaming license or by applicable law. This includes age verification, KYC identity checks, anti-money laundering screening, record-keeping of all gaming transactions, and responsible gaming monitoring obligations.

4.3 Legitimate Interest. 92ro processes certain data on the basis of legitimate interest where that interest is not overridden by your privacy rights. This includes fraud detection, security monitoring, platform performance analytics, and the use of anonymised gameplay data to improve the product. We conduct a balancing assessment before relying on legitimate interest for any processing activity.

4.4 Consent. Where processing is based on consent — primarily for direct marketing communications — we will obtain your explicit consent before using your data for that purpose. You may withdraw your consent at any time by contacting support or by using the unsubscribe mechanism in any marketing message.

5.1 92ro does not sell or rent your personal data to third parties. We share personal data only where necessary and only with the categories of recipients described in this section.

5.2 Payment Processors. To process your PKR deposits and withdrawals, we share the minimum necessary financial data with our payment processing partners, including JazzCash, EasyPaisa, HBL, UBL, SadaPay, and Meezan Bank integration services. These processors act under contractual data processing agreements and are prohibited from using your data for any purpose other than completing your transactions.

5.3 Game Software Providers. The casino games available on 92ro are provided by third-party software companies. These providers receive limited gameplay data — such as session identifiers and wager amounts — necessary to render the game and record outcomes. They do not receive your full identity details or financial account information.

5.4 KYC and Identity Verification Services. 92ro may use third-party identity verification services to authenticate KYC documents. These services process your identity documents under strict contractual restrictions and are prohibited from retaining or using your data beyond the scope of the verification task.

5.5 Licensing Authority. As a condition of our gaming license, 92ro is required to provide player data — including transaction records, KYC documentation, and gameplay logs — to the licensing authority upon request. This sharing is a legal obligation and not subject to your consent.

5.6 Law Enforcement and Regulatory Bodies. 92ro will disclose personal data to law enforcement, financial intelligence units, or other regulatory authorities where required by law, where we are subject to a binding legal order, or where we have a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or other serious criminal activity.

5.7 No Advertising Networks. 92ro does not share your personal data with advertising networks, social media platforms, or data analytics companies for the purpose of targeted advertising. Any platform analytics we conduct use aggregated, anonymised data that cannot be used to identify individual players.

6.1 92ro uses cookies and similar tracking technologies on the platform to ensure its correct functioning, to maintain your session when you are logged in, and to collect anonymised analytics data that helps us understand how the platform is used and where improvements can be made.

6.2 Essential Cookies. These cookies are necessary for the platform to function. They maintain your login session, remember your language preference, and ensure that security features operate correctly. Essential cookies cannot be disabled without preventing you from using the platform.

6.3 Analytics Cookies. These cookies collect anonymised information about how players navigate the platform — which pages are visited most frequently, which games are accessed, and where players encounter difficulties. This data helps 92ro improve the platform experience. Analytics cookies can be declined without affecting your ability to use the platform.

6.4 Fraud Prevention Cookies. These cookies collect technical identifiers — including IP address, device fingerprint, and session behaviour signals — that are used by 92ro's fraud monitoring systems to detect and prevent prohibited conduct such as multi-accounting and automated bot activity.

7.1 92ro retains personal data for as long as your account is active and for such additional period as is required by our licensing obligations, legal requirements, or legitimate business interests.

7.2 Active Accounts. While your 92ro account is active, all account data — including identity, financial, and gameplay records — is retained to operate your account and to fulfil ongoing compliance obligations.

7.3 Post-Closure Retention. Following the closure of your account, 92ro retains the following categories of data for the periods specified:

• KYC and identity documents: 5 years from the date of account closure, as required by our gaming license's anti-money laundering obligations.
• Financial transaction records: 5 years from the date of the transaction, in accordance with financial record-keeping requirements.
• Gameplay and betting records: 3 years from the date of account closure for dispute resolution and audit purposes.
• Support communications: 2 years from the date of the communication, for quality assurance and complaint resolution purposes.
• Registration data: Retained for the minimum period required to confirm that a previously excluded or closed account is not re-registered by the same individual.

7.4 Upon expiry of the relevant retention period, personal data is securely and permanently deleted or irreversibly anonymised, such that it can no longer be associated with any identifiable individual.

8.1 92ro employs a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction.

8.2 Encryption. All data in transit between your device and 92ro servers is encrypted using TLS 1.2 or higher (256-bit). Sensitive data at rest — including stored KYC documents and payment account references — is encrypted using AES-256. Passwords are stored as salted cryptographic hashes and are never stored or transmitted in plain text.

8.3 Access Controls. Access to personal data within 92ro's internal systems is strictly limited to personnel with a legitimate need to access that data in the performance of their role. Access is controlled via role-based permissions, requires multi-factor authentication, and is subject to audit logging.

8.4 Infrastructure Security. 92ro's platform infrastructure is hosted on servers with industry-standard physical and network security controls, including firewalls, intrusion detection systems, and regular independent penetration testing.

8.5 Incident Response. 92ro maintains a documented data breach response procedure. In the event of a security incident that is likely to result in a risk to your rights and freedoms, 92ro will notify affected players without undue delay and will take all reasonable steps to contain and remediate the incident.

9.1 Subject to applicable law and the conditions of our gaming license, you have the following rights in respect of your personal data held by 92ro. To exercise any of these rights, contact the support team by email at [email protected] with "Data Rights Request" in the subject line.

10.1 92ro may send you promotional communications about bonuses, new games, PSL betting markets, seasonal promotions, and platform updates where you have given your explicit consent to receive such communications at the time of registration or via account settings.

10.2 Promotional communications are sent by email or via in-platform notification. We do not send unsolicited SMS promotional messages to your Pakistani mobile number. Any SMS sent by 92ro to your registered mobile number will be transactional in nature — such as account verification codes or security alerts — not promotional.

10.3 You may withdraw your consent for promotional communications at any time by: (a) clicking the unsubscribe link in any promotional email you receive from 92ro, or (b) contacting support at [email protected] and requesting removal from the mailing list. Withdrawal of consent for marketing will not affect the delivery of transactional and security communications, which are sent regardless of marketing preference as they relate to the operation of your account.

10.4 92ro uses engagement data — such as which promotions you have opted into and which game categories you most frequently play — to send you relevant promotional content. This is not shared with external advertisers and is used solely to ensure that the offers you receive are relevant to your actual interests on the platform.

11.1 92ro is strictly an adults-only platform. The platform is not directed at, and does not knowingly collect personal data from, any individual under the age of 21. The 21+ age requirement is enforced through age verification at registration and again at the point of the first withdrawal via CNIC verification.

11.2 If 92ro becomes aware that personal data has been collected from or in relation to an individual under the age of 21 — whether through a registration attempt, an age verification failure, or any other means — that data will be immediately deleted and the associated account will be suspended.

12.1 92ro's platform infrastructure and some of its third-party service providers — including game software providers and KYC verification services — are located outside Pakistan. As a result, your personal data may be transferred to and processed in countries other than Pakistan.

12.2 Where personal data is transferred internationally, 92ro ensures that appropriate safeguards are in place to protect that data. These safeguards include contractual data processing agreements that impose data protection obligations equivalent to those under our licensing authority's requirements, and — where applicable — standard contractual clauses or equivalent mechanisms recognised under the data protection framework of the licensing jurisdiction.

12.3 By registering an account and using the 92ro platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan as described in this section. If you have concerns about any specific international transfer, please contact us at [email protected].

13.1 The 92ro platform may contain links to pages or content relating to third-party game providers or payment services. This Privacy Policy applies solely to personal data collected and processed by 92ro in connection with your use of the platform. It does not govern the data practices of any third-party service provider, game developer, or payment processor.

13.2 Each third-party service provider that processes personal data on behalf of 92ro is required to enter into a data processing agreement with 92ro. Under that agreement, the provider is prohibited from using your personal data for any purpose other than providing the specific service for which they were engaged, and is required to maintain security standards consistent with those described in Section 8 of this Policy.

13.3 92ro conducts due diligence on all third-party service providers before engaging them to process personal data, and reviews those engagements periodically. If a provider's data protection practices fall below the standard required by 92ro or by our licensing authority, the engagement will be terminated.

14.1 92ro reserves the right to update this Privacy Policy at any time. We will notify you of material changes — that is, changes that substantially affect your privacy rights or how your data is used — by sending an email to your registered address or by displaying a prominent notice on the platform before the change takes effect.

14.2 Non-material updates — such as corrections to typographical errors, updated contact details, or clarifications that do not alter the substance of the Policy — may be made without prior notice and will be effective upon publication on this page.

14.3 We encourage you to review this Privacy Policy periodically to stay informed of how 92ro protects your personal data. The effective date at the top of this document reflects the date of the most recent material revision. Your continued use of the platform following notification of a material change constitutes your acceptance of the updated Policy.

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data 92ro holds about you, please contact us using the details below. All privacy-related inquiries are handled by the 92ro Data Protection team and will receive a substantive response within 30 days.

15.2 Email: [email protected] — please include "Privacy" in the subject line so your message is directed to the correct team without delay.

15.3 Live Chat: The 92ro support team is available 24/7 via the live chat function on the platform. For privacy-related inquiries that require written documentation, email is preferred.

15.4 Response Times: Acknowledgement of your inquiry will be provided within 48 hours. For data subject rights requests — such as access, rectification, or erasure — a substantive response will be provided within 30 calendar days of receiving your verified request. In cases of complexity, this period may be extended by a further 30 days, and you will be notified of the extension and the reason for it.