Privacy Policy

This Privacy Policy ("Policy") is published by 92dadu, an English-language online gaming information and entertainment platform accessible at https://92dadu.cam ("Platform", "we", "us", "our"). It describes how we collect, receive, use, store, share, transfer and protect personal information from users ("User", "you", "your") who access the Platform.

92dadu operates as an informational platform only. We do not process gambling transactions, hold player funds or operate as a licensed gaming service. Nonetheless, our operation of this Platform involves the processing of certain categories of personal data, and we are committed to handling that data with the highest standards of care, transparency and security.

This Policy should be read alongside our Terms & Conditions. By using the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers, location data and usage behaviour.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means 92dadu, as the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third-party service provider that processes personal data on behalf of 92dadu, under our instruction and in accordance with this Policy.
• "Cookie" means a small file placed on your device by a website, used to store information about your browsing session or preferences.
• "Consent" means a freely given, specific, informed and unambiguous indication of your agreement to the processing of your personal data for a stated purpose.
• "Sensitive Personal Data" means categories of personal data that require enhanced protection, such as financial details, health information or government identity document numbers.

This Policy applies to all personal data collected by 92dadu through the Platform, including through all pages, features, forms, newsletter sign-ups and analytics tools operating on the Platform.

This Policy applies to users accessing the Platform from all geographic locations, including users based in Pakistan and other jurisdictions. Where users are located in Pakistan, we note that the Prevention of Electronic Crimes Act, 2016 (PECA) and related data protection guidelines issued by the Pakistan Telecommunication Authority (PTA) may apply. We comply with applicable data protection obligations to the best of our ability within the applicable legal framework.

This Policy does not apply to third-party gaming operator websites or services that may be referenced on the Platform. Users should consult the individual privacy policies of any operator platform they register with or provide personal data to.

The categories of personal data we may collect from or about users of the Platform are set out in the table below. We limit collection to what is reasonably necessary for the stated purposes.

We collect personal data through the following methods:

• Direct Collection: When you voluntarily contact us by email (e.g., [email protected]), you provide us with contact data such as your name and email address as part of that communication.
• Automated Collection: When you access the Platform, certain technical and usage data is automatically collected through server logs, cookies and analytics tools. This happens regardless of whether you have an account.
• Cookies and Similar Technologies: We use first-party and third-party cookies, pixel tags and local storage to collect data about how users navigate and interact with the Platform. Full details are in Section 9.
• Analytics Platforms: We may use web analytics services (such as privacy-compliant third-party analytics tools) to collect aggregated and anonymised usage statistics. These services process data under their own privacy policies and under data processing agreements with 92dadu.

We do not purchase personal data from data brokers or receive personal data from third-party sources without your knowledge.

Where applicable data protection frameworks require a legal basis for the processing of personal data, 92dadu relies on the following lawful grounds:

• Legitimate Interests: The primary legal basis for processing usage and technical data is our legitimate interest in operating and improving the Platform, ensuring its security, and understanding how users interact with our informational content. We have assessed that these interests do not override the rights and freedoms of individual users.
• Consent: Where we deploy non-essential cookies or analytics tools that require consent, we will seek your consent in a clear and granular manner before such processing begins. You may withdraw consent at any time.
• Contractual Necessity: Where you contact us regarding a service matter, processing your contact data is necessary to respond to your inquiry and fulfil our obligations to you.
• Legal Obligation: In limited circumstances, we may be required to process or disclose personal data to comply with a legal obligation imposed by applicable law, court order or competent regulatory authority.

Personal data collected by 92dadu is used exclusively for the following purposes:

• To deliver, maintain, operate and improve the Platform and its informational content for Pakistani and international audiences;
• To analyse Platform usage patterns and user behaviour in aggregate, enabling us to improve content quality and user experience;
• To respond to enquiries, support requests and communications submitted via email to [email protected];
• To detect, investigate and prevent fraudulent activity, security incidents and technical vulnerabilities affecting the Platform;
• To comply with applicable legal obligations, including responding to lawful requests from regulatory or enforcement authorities;
• To measure the effectiveness of our informational content and responsible gambling messaging;
• To generate anonymised, aggregated reporting that does not identify any individual user.

We do not use personal data for automated decision-making that produces legal or similarly significant effects on individual users. We do not use personal data for targeted advertising or profiling of individual user preferences.

92dadu does not sell, rent or disclose personal data to third parties for their own independent commercial purposes. We may share personal data in the following limited and controlled circumstances:

• Service Providers (Data Processors): We engage carefully selected third-party technology providers to support Platform operations — including hosting infrastructure, security monitoring and analytics tools. These providers access only the data necessary to perform their services and are bound by contractual data processing obligations consistent with this Policy.
• Legal Compliance: We may disclose personal data if required to do so by applicable law, court order, regulatory demand or governmental request. We will only disclose the minimum data required and, where legally permissible, will notify affected users of such requests.
• Business Continuity: In the event of a merger, acquisition, restructuring or sale of assets involving 92dadu, personal data may be transferred as part of that transaction. We will provide notice to users prior to data being transferred under such circumstances and subject to any new privacy terms.
• Protection of Rights: We may disclose data where we believe it is necessary to protect the rights, property or safety of 92dadu, our users or the public, in accordance with applicable law.

In all cases, data sharing is conducted on a minimum-necessary basis. We do not disclose granular individual user data beyond what is strictly required for the purpose.

92dadu uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that enable certain Platform functionalities and help us understand usage patterns.

You can control and manage cookies through your browser settings. Most browsers allow you to refuse all cookies, accept only certain types, or delete cookies already stored on your device. Please note that disabling strictly necessary cookies may impact the functionality of the Platform.

92dadu 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 legitimate business need.

• Usage and technical data collected through server logs and analytics tools is retained for a maximum of 24 months, after which it is anonymised or deleted.
• Contact data submitted via email support is retained for as long as necessary to resolve the relevant enquiry and for a reasonable period thereafter for quality assurance and legal compliance purposes, typically no longer than 36 months from the date of last contact.
• Cookie data is retained in accordance with the duration periods set out in Section 9.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

92dadu implements a range of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between users' browsers and our servers;
• Encryption of personal data at rest where applicable;
• Restricted access controls ensuring that personal data is accessible only to authorised personnel with a legitimate need to access it;
• Regular security reviews of our Platform infrastructure and data handling practices;
• Contractual security requirements imposed on all third-party data processors.

While we take every reasonable precaution, no system connected to the internet can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will take appropriate steps to notify affected users and relevant authorities in accordance with applicable law.

Subject to applicable law and certain limited exceptions, you hold the following rights in respect of your personal data held by 92dadu. To exercise any of these rights, contact us at [email protected] with a clear description of your request and sufficient information to verify your identity.

We will respond to all verified rights requests within 30 days of receipt. In complex or high-volume cases, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reason for it. We will not charge a fee for responding to rights requests unless they are manifestly unfounded or excessive.

The Platform is intended exclusively for adults aged 18 years or older, or the higher minimum age required by the operator's licence jurisdiction. 92dadu does not knowingly collect personal data from individuals under the age of 18.

If we become aware that personal data has been collected from a person under 18 without appropriate consent, we will take immediate steps to delete that data. If you believe that we may have inadvertently collected data from a minor, please contact us immediately at [email protected].

Parents and guardians are encouraged to monitor their children's internet usage and to make use of parental control software where appropriate to prevent access to age-restricted content.

In the course of operating the Platform and engaging third-party service providers (such as hosting, analytics and security services), personal data may be transferred to or processed in countries outside of Pakistan. Where such transfers occur, 92dadu ensures that appropriate safeguards are in place to protect your personal data to a standard consistent with this Policy.

Such safeguards may include contractual clauses binding third-party recipients to appropriate data protection standards. You may request further information about the safeguards applicable to any specific international data transfer by contacting us at the details in Section 17.

The Platform may contain informational references to third-party gaming operators. If you follow any such reference and register with or provide personal data to a third-party operator, your data will be processed by that operator under their own privacy policy — not this one.

92dadu is not responsible for the privacy practices of any third-party service. We strongly encourage you to read and understand the privacy policy of any gaming operator platform before creating an account or providing personal or financial information. This applies equally to platforms associated with payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah, which are referenced on this Platform for contextual purposes only.

92dadu reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, technological developments, legal requirements or regulatory guidance. Any revised Policy will be posted to this page with an updated effective date.

We encourage you to review this Policy periodically. Where a change is material — meaning it significantly alters your rights or our obligations — we will take reasonable steps to draw it to your attention. Continued use of the Platform following publication of a revised Policy constitutes your acceptance of the updated terms.

For any questions, concerns, complaints or requests relating to this Privacy Policy or the processing of your personal data by 92dadu, please contact us through the following channel:

92dadu serves users across Pakistan, including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. All privacy correspondence is handled in English. If you require support in Urdu, please indicate this in your initial message and we will make best efforts to accommodate your preference.