Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 92apk ("we", "us", "the Platform", "92apk") collects, processes, stores, shares and protects personal data relating to users ("you", "User", "Player") of the website located at https://92apk.cam and all associated services, mobile applications and Platform features.

92apk is an English-language online betting information and platform site primarily targeting Pakistani users. We recognise that users in Pakistan and across the region entrust us with sensitive personal and financial information, and we take that responsibility seriously. This Policy is designed to be transparent, readable and comprehensive — not buried in impenetrable legal language.

This Policy should be read alongside our Terms & Conditions, which govern the overall use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions regarding data matters, this Policy takes precedence.

2. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, IP address, device identifiers and financial information.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure and deletion.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this context, 92apk.
• "Data Processor" means any third party that processes Personal Data on behalf of 92apk under a contractual arrangement.
• "Cookies" means small text files placed on your device by the Platform to store preferences, session information and analytical data.
• "KYC Data" means documentation and information collected as part of Know Your Customer identity verification, including government-issued ID, proof of address and source-of-funds information.
• "Special Category Data" means sensitive personal data that requires heightened protection, such as health-related information submitted in connection with responsible gambling self-exclusion requests.

3. Data We Collect

92apk collects Personal Data in several categories depending on how you interact with the Platform. The table below summarises the primary categories of data we hold.

Where you provide us with data relating to third parties — for example, a referral contact — you confirm that you have their permission to share that data with us and that you have informed them of this Policy.

4. How We Collect Data

92apk collects Personal Data through the following channels and mechanisms:

• Direct submission: When you register an Account, complete KYC verification, make a deposit or withdrawal, contact support or participate in a promotion.
• Automated collection: Through Cookies, tracking pixels, server logs and similar technologies that record your interactions with the Platform automatically.
• Third-party sources: From identity verification providers, fraud-screening services, payment processors and publicly available sources where we are lawfully permitted to do so.
• Device and browser signals: Your device may transmit technical information such as IP address, geolocation data (where permitted and enabled), and hardware identifiers when you access the Platform.
• Responsible gambling interactions: If you set deposit limits, request a cooling-off period or submit a self-exclusion request, we record that information to honour your instructions and monitor compliance.

5. Data Processing

92apk processes your Personal Data for the following purposes. Each purpose is tied to a specific lawful basis, which is described in Section 6.

1. Account Management: Creating, maintaining and securing your Account, authenticating your identity at login, and managing Account settings and preferences.
2. Service Delivery: Enabling you to place bets, access casino games, receive winnings, and interact with all features of the Platform, including sports markets covering Pakistan cricket, PSL T20, ICC tournaments, international football and live sports.
3. KYC & Age Verification: Verifying that you meet the minimum age requirement of 18 years (or the higher minimum required by the operator/licence jurisdiction) and confirming your identity in accordance with regulatory obligations.
4. Financial Processing: Processing deposits, withdrawals and refunds. Payment method references — including contextual mentions of Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are recorded for transaction history purposes. These references do not imply endorsement of gambling by those providers.
5. Fraud Prevention & AML: Monitoring transactions and account activity to detect and prevent fraud, money laundering, collusion and other prohibited conduct, including multi-accounting.
6. Responsible Gambling: Operating player protection tools including deposit limits, session timers, cooling-off periods and self-exclusion. Monitoring betting patterns to identify potential problem gambling indicators and intervene where appropriate.
7. Customer Support: Responding to your queries, complaints and support requests. Support is provided in English, with Urdu assistance available on request.
8. Marketing Communications: Sending you promotional offers, Platform updates and event notifications — but only where you have given explicit consent. You may withdraw consent at any time via your Account settings.
9. Analytics & Product Development: Understanding how the Platform is used, identifying areas for improvement, and personalising the user experience based on aggregated, anonymised behavioural data.
10. Legal & Regulatory Compliance: Meeting obligations under applicable licensing conditions, responding to lawful requests from regulatory or law enforcement authorities, and maintaining records required by law.

6. Legal Basis

Where data protection legislation applies, 92apk relies on one or more of the following lawful bases when processing your Personal Data:

• Contractual Necessity: Processing required to provide the services you have signed up for — account management, bet settlement, payment processing and customer support.
• Legal Obligation: Processing required to comply with applicable laws, licensing conditions, anti-money laundering regulations and regulatory reporting requirements.
• Legitimate Interests: Processing that serves 92apk's legitimate business interests — including fraud prevention, platform security, and analytics — where those interests are not overridden by your rights.
• Consent: Processing that relies on your freely given, specific and informed consent — primarily marketing communications and non-essential Cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Vital Interests: In exceptional circumstances, processing may be necessary to protect your vital interests or those of another person — for example, where a responsible gambling concern requires urgent intervention.

7. Data Sharing

92apk does not sell your Personal Data to third parties. We may, however, share your data with the following categories of recipients where necessary and lawful:

• Identity Verification Providers: Third-party KYC and age verification services that process your identity documents on our behalf.
• Payment Processors: Entities that facilitate deposit and withdrawal transactions. Financial data shared is limited to what is strictly necessary to complete the transaction.
• Fraud & Security Services: Specialist providers that help detect and prevent fraudulent activity, money laundering and account abuse.
• IT & Hosting Providers: Cloud infrastructure and data centre operators that store Platform data on our behalf, subject to contractual data protection obligations.
• Customer Support Platforms: Live chat and ticketing tools that process communication data to facilitate support interactions.
• Analytics Providers: Services that help us understand Platform usage patterns using aggregated and, where possible, anonymised data.
• Regulatory & Law Enforcement Authorities: Where we are legally required to disclose data — for example, in response to a court order, regulatory investigation or anti-money laundering obligation.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of 92apk's business, your data may be transferred to the successor entity subject to equivalent privacy protections.

8. Cookies & Tracking

92apk uses Cookies and similar tracking technologies to operate the Platform, remember your preferences and understand how the site is used. The following categories of Cookies may be placed on your device:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session Cookies that keep you logged in and security Cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred currency display (PKR) and responsible gambling limit configurations.
• Analytical Cookies: Collect anonymised data about how users navigate the Platform — pages visited, time spent and interaction patterns — to help us improve the user experience.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of campaigns. These are only placed where you have given explicit consent.

You may manage your Cookie preferences through your browser settings. Disabling certain Cookies may affect the functionality of the Platform. Strictly Necessary Cookies cannot be disabled as they are required for the Platform to operate securely.

9. Data Retention

92apk retains Personal Data for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations and resolve any outstanding disputes or complaints. The following general retention periods apply:

• Account and Registration Data: Retained for the lifetime of your Account and for a minimum of five (5) years following Account closure, in line with standard AML and regulatory record-keeping obligations.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification or Account closure, whichever is later.
• Financial Transaction Records: Retained for a minimum of five (5) years to satisfy anti-money laundering and financial regulatory requirements.
• Betting and Gaming History: Retained for the lifetime of the Account and for a minimum of two (2) years following closure for dispute resolution purposes.
• Marketing Consent Records: Retained for as long as you hold an Account and for three (3) years following withdrawal of consent, as evidence of your opt-in status.
• Support Communications: Retained for two (2) years from the date of the last interaction for quality assurance and dispute resolution.
• Anonymised Analytics Data: May be retained indefinitely as it no longer constitutes Personal Data.

Where data is no longer required, it is securely deleted or irreversibly anonymised in accordance with our internal data destruction procedures.

10. Data Security

92apk implements a range of technical and organisational measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform.
• Encryption of stored sensitive data, including hashed and salted password storage — your plaintext password is never stored.
• Role-based access controls that restrict staff access to Personal Data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments and penetration testing of Platform infrastructure.
• Multi-factor authentication options for User Accounts to reduce the risk of unauthorised access.
• Incident response procedures to detect, investigate and report data breaches in accordance with applicable regulatory timelines.

11. Your Rights

Subject to applicable data protection legislation and any overriding legal obligations, you may have the following rights in relation to your Personal Data:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data. You can update many details directly through your Account settings.
• Right to Erasure: In certain circumstances, you may request deletion of your Personal Data. This right is subject to exceptions where retention is required by law — for example, AML record-keeping obligations that apply regardless of Account closure.
• Right to Restriction: You may request that we restrict the processing of your data in certain circumstances, for example while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on your consent or on a contract, you may request a copy of your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests. You have an unconditional right to object to processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us using the details in Section 15. We will respond to verified requests within a reasonable timeframe in accordance with applicable legal requirements. We may need to verify your identity before processing any request.

12. Minors

The Platform is strictly for adults aged 18 and over, or the higher minimum age required by the applicable operator or licence jurisdiction. 92apk does not knowingly collect Personal Data from persons under the age of 18.

If we become aware that Personal Data has been collected from a minor without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated Account. If you believe that we may have inadvertently collected data from a minor, please contact us immediately at the details provided in Section 15.

Parents and guardians in Pakistan who are concerned about a minor's access to online gambling platforms are encouraged to use parental control software and to visit our Responsible Gambling page for further guidance.

13. International Transfers

92apk may transfer your Personal Data to third-party service providers located in countries outside of Pakistan. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place to protect your data, including:

• Entering into contractual arrangements with recipients that impose data protection obligations equivalent to those described in this Policy.
• Transferring data only to jurisdictions that provide an adequate level of data protection in accordance with applicable standards.
• Ensuring that Data Processors acting on our behalf are contractually bound to process data only on our documented instructions.

By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in countries outside Pakistan. Where you have concerns about international data transfers, please contact us using the details in Section 15.

14. Policy Amendments

92apk reserves the right to update or revise this Privacy Policy at any time. Where changes are material — for example, changes to the categories of data we collect, the purposes for which we process it, or the third parties with whom we share it — we will make reasonable efforts to notify registered Users in advance by displaying a prominent notice on the Platform or by sending an email to the address associated with your Account.

The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the Platform following the publication of a revised Policy constitutes your acceptance of the changes. We recommend reviewing this page periodically to stay informed of how we handle your data.

If you do not accept a revised Policy, you must stop using the Platform and may request Account closure by contacting our support team.

15. Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how we have handled your Personal Data, please contact our support team. All contact details are provided as plain text only and are not clickable links.

When submitting a data rights request, please include your full name, Account username and a description of your request so that we can verify your identity and process your submission promptly. We may request additional information to confirm your identity before acting on any request.

For queries related to responsible gambling data — such as self-exclusion records, limit settings or account history — please visit our Responsible Gambling page or raise the matter directly with live chat support.