Privacy Policy

1.Introduction

This Privacy Policy ("Policy") is published by ay999 ("Platform", "we", "us", "our"), the operator of the website located at https://ay999.cam. It sets out how ay999 collects, processes, stores, discloses and safeguards personal data provided by or generated through the activities of registered users ("User", "you", "your") of the Platform.

ay999 is an English-language online gaming information and entertainment platform targeting Pakistani users across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. This Policy applies to all data processing activities undertaken by ay999 in connection with your use of the Platform, including account registration, gameplay, deposits, withdrawals and customer support interactions.

By registering an account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and you consent to the collection and use of your personal data as described herein. If you do not accept this Policy, you must not access or use the Platform.

2.Definitions

The following terms are used throughout this Policy and carry the meanings set out below:

• "Personal Data" means any information that identifies or can reasonably be used to identify a natural person, directly or indirectly, including name, email address, date of birth, IP address, device identifiers and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, alteration, retrieval, consultation, use, disclosure, transmission or erasure.
• "Data Controller" means ay999, which determines the purposes and means of Processing of Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of ay999 under a data processing agreement.
• "KYC" means Know Your Customer — the identity verification process ay999 applies to confirm user eligibility and comply with anti-money laundering requirements.
• "Cookies" means small data files placed on your device by the Platform to support functionality, session management and analytics.
• "Special Category Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, health information, biometric data or data concerning a person's sex life or sexual orientation. ay999 does not intentionally collect Special Category Data.

3.Data We Collect

ay999 collects the following categories of Personal Data:

ay999 does not intentionally collect Special Category Data. If you voluntarily disclose health-related information in a support context (for example, in relation to a responsible gambling request), that disclosure is processed only for the purpose of providing the requested support.

4.How We Collect Data

ay999 collects Personal Data through the following means:

• Direct input: Information you provide when registering an account, completing KYC, submitting a support request or filling out any Platform form.
• Automated technologies: Cookies, server logs, pixel tags and similar tracking technologies that collect Technical Data and Usage Data automatically when you access the Platform.
• Third-party providers: Identity verification agencies, payment processors and fraud-prevention services may share data with ay999 in connection with account verification and transaction processing.
• Public sources: Publicly available information may be used to verify identity details provided during KYC, or to support anti-fraud and AML compliance obligations.

5.Purpose & Legal Basis for Processing

ay999 processes your Personal Data for the following purposes, on the indicated legal bases:

• Account registration and management — to create and administer your Account, authenticate your identity and enable Platform access. Legal basis: Performance of contract.
• Identity verification (KYC / AML) — to comply with anti-money laundering obligations and to verify that you meet minimum age requirements for gambling services. Legal basis: Legal obligation.
• Processing deposits and withdrawals — to facilitate PKR-denominated transactions through available payment channels, verify transaction authenticity and detect fraud. Legal basis: Performance of contract; legitimate interests.
• Platform personalisation — to tailor content, game recommendations and promotional information to your activity patterns and account preferences. Legal basis: Consent or legitimate interests.
• Customer support — to respond to queries, complaints and account-related requests received via live chat or email. Legal basis: Performance of contract.
• Responsible gambling monitoring — to identify patterns indicative of problem gambling and to apply responsible gambling interventions where appropriate. Legal basis: Legitimate interests; legal obligation.
• Security and fraud prevention — to monitor for suspicious activity, prevent account takeover and investigate potential breaches of the Terms & Conditions. Legal basis: Legitimate interests; legal obligation.
• Legal and regulatory compliance — to meet reporting obligations, respond to lawful requests from regulatory authorities or law enforcement agencies, and defend legal claims. Legal basis: Legal obligation.

6.Data Sharing & Disclosure

ay999 does not sell, rent or trade your Personal Data. We may share your data only with the categories of recipients described below, and only to the extent necessary for each stated purpose:

• Service Providers and Data Processors: Third-party vendors engaged to provide services on behalf of ay999, including KYC and identity verification providers, payment processing infrastructure, cloud hosting providers, customer support tooling, anti-fraud services and analytics platforms. All such processors are bound by data processing agreements requiring them to handle your data in accordance with this Policy.
• Payment Partners: Where a deposit or withdrawal is processed through a payment channel — which may include payment rails familiar to Pakistani users such as Easypaisa, JazzCash, Raast, or bank transfers through institutions like HBL, UBL, Meezan Bank or Bank Alfalah — the relevant financial institution will receive the transaction data necessary to execute the instruction. This reference does not imply any endorsement or partnership between ay999 and these institutions. Users must consult the provider's own privacy notice regarding their data-handling practices.
• Regulatory and Law Enforcement Authorities: ay999 may disclose Personal Data to governmental, regulatory or law enforcement authorities where required to do so by applicable law, court order or legal process.
• Business Transfers: In the event of a merger, acquisition, asset sale or restructuring involving ay999, your Personal Data may be transferred to the relevant successor entity, subject to equivalent data protection commitments.
• Professional Advisers: Legal advisers, auditors and compliance consultants engaged by ay999 may have access to Personal Data where strictly necessary for the provision of their services and subject to professional confidentiality obligations.

7.International Data Transfers

ay999 operates internationally and your Personal Data may be transferred to and processed in countries other than your country of residence, including countries that may not provide the same level of data protection as Pakistan or the jurisdiction in which you are located.

Where such transfers occur, ay999 will implement appropriate safeguards to protect your Personal Data, which may include contractual clauses, data processing agreements with equivalent protective standards, or reliance on applicable legal transfer mechanisms. By using the Platform, you acknowledge and consent to the international transfer of your Personal Data as described in this clause.

8.Data Retention

ay999 retains Personal Data for as long as your Account remains active, plus such additional period as is required to comply with legal, regulatory, audit and dispute-resolution obligations. The following general retention guidelines apply:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, to meet AML and regulatory record-keeping obligations.
• Financial transaction data: Retained for a minimum of five (5) to seven (7) years following the date of the transaction, in line with applicable financial record-keeping requirements.
• Support and communications data: Retained for a minimum of two (2) years from the date of the interaction, or longer if the subject matter relates to an unresolved legal or compliance matter.
• Technical and usage data: Retained in aggregated or anonymised form for analytical purposes beyond the retention period applicable to identifiable data. Identifiable technical data is retained for up to twelve (12) months.

Following the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

9.Cookies & Tracking Technologies

ay999 uses cookies and similar technologies to support the operation and improvement of the Platform. The following categories of cookies may be used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens and load-balancing cookies. These cannot be disabled without preventing core Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, account display options and responsible gambling limit configurations.
• Analytics Cookies: Used to collect aggregated data about how users interact with the Platform, including pages visited, session duration and navigation paths. This data is used in anonymised or pseudonymised form to improve Platform performance.
• Marketing and Targeting Cookies: Where applicable and subject to your consent, used to deliver relevant promotional communications and measure the effectiveness of marketing activity.

You may manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect Platform functionality. Where your consent is required for specific cookies, ay999 will provide a mechanism for you to indicate your preferences.

10.Security Measures

ay999 implements technical and organisational security measures designed to protect your Personal Data against accidental loss, unauthorised access, alteration, disclosure or destruction. These measures include:

• HTTPS/TLS encryption for all data in transit between your device and our servers.
• Encryption and hashing of sensitive data at rest, including password storage.
• Access controls limiting employee access to Personal Data to those with a legitimate operational need.
• Regular internal and external security assessments and penetration testing.
• Incident response procedures for identifying, containing and notifying data breaches within applicable timeframes.

Whilst ay999 takes reasonable steps to protect your data, no method of electronic transmission or storage is entirely secure. Users are responsible for maintaining the confidentiality of their own account credentials and for notifying ay999 promptly if they suspect unauthorised access.

11.Your Data Rights

Subject to applicable law and the conditions described below, you have the following rights in relation to your Personal Data held by ay999:

To exercise any of the above rights, submit a written request to [email protected]. ay999 will respond within 30 days of receiving a valid, verifiable request. We may require proof of identity before processing a rights request. Where a request is complex or numerous, the response period may be extended by up to a further 60 days with notice.

Certain rights are subject to limitations where ay999 has overriding legitimate interests or legal obligations — for example, the right to erasure does not apply to data retained for AML compliance or active dispute resolution.

12.Children & Minors

The ay999 Platform is strictly for adults aged 18 years or older — or the higher minimum age required by the operator/licence jurisdiction. The Platform is not directed at, and does not knowingly collect Personal Data from, individuals under the applicable minimum age.

If ay999 becomes aware that Personal Data has been collected from an individual below the minimum age without verifiable parental or guardian consent, that data will be deleted as promptly as practicable. If you believe that a minor may have accessed the Platform using your credentials or registered an account, please notify us immediately at [email protected].

13.Third-Party Links & Services

The Platform may reference third-party services, including payment providers familiar to Pakistani users such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah, as well as sports organisations including the Pakistan Super League (PSL) and ICC-affiliated tournaments. These references are for contextual and educational purposes only.

ay999 is not responsible for the privacy practices, content or data handling of any third-party service. Where you interact with a third-party service — for example, when initiating a payment through an external wallet or bank — that interaction is governed by the third party's own privacy policy and terms of service. ay999 encourages you to review those documents before providing personal or financial data to any third party.

14.Policy Amendments

ay999 reserves the right to update or amend this Privacy Policy at any time. Where material changes are made — for example, changes to the categories of data collected, new purposes of processing or new categories of recipients — ay999 will notify registered users by email or through a prominent notice on the Platform at least 14 days prior to the amendments taking effect, except where a shorter timeframe is required by law.

The "Effective Date" at the top of this Policy reflects the date the current version entered into force. Your continued use of the Platform after the effective date of any amended Policy constitutes acceptance of the revised terms. If you do not accept the amended Policy, you must cease using the Platform and may request Account closure.

15.Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the way ay999 processes your Personal Data, please contact us using the details below. All privacy-related communications must be submitted in English and should clearly describe the nature of your query or request.

Please note: the support email address above is displayed as plain text only and is not a clickable link. Copy and paste the address into your email client. Do not submit data rights requests through social media or unofficial channels.