89atm Privacy Policy

This Privacy Policy ("Policy") is issued by 89atm ("89atm", "we", "us", or "our") and applies to all individuals who visit, register on, or use the 89atm online casino and sports betting platform at 89atm.club ("Platform"), including Pakistani Members accessing the Platform from Karachi, Lahore, Islamabad, Faisalabad, and all other cities across Pakistan. Please read this Policy carefully before using the Platform. By registering an account or continuing to use the Platform, you acknowledge that you have read, understood, and agreed to the data practices described in this Policy.

1 Who We Are

89atm is an internationally licensed online gaming operator providing cricket betting, live casino, slots, sports betting, and related entertainment services to eligible Members. 89atm acts as the data controller in respect of all personal data collected through the Platform. For all privacy-related queries, including data access requests and complaints, please contact our dedicated data protection team at the address provided in Section 14 of this Policy.

2 Data We Collect

89atm collects different categories of personal data depending on the nature of your interaction with the Platform. The table below summarises the main categories of data we collect and the primary purpose for which each category is used:

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where identity documents provided during KYC incidentally contain such information — in which case we process only the minimum necessary fields for verification purposes.

3 How We Collect Data

89atm collects personal data through the following channels:

• Direct Interactions: When you register an account on 89atm, complete the KYC verification process, make a deposit or withdrawal, contact our support team, or respond to a survey or promotion, you directly provide us with personal data.
• Automated Technologies: When you access the Platform, our servers automatically record technical data including your IP address, device fingerprint, browser type, and session activity. We use cookies and similar tracking technologies as described in Section 7.
• Payment Providers: When you transact via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, or Mastercard, our payment processing partners share transaction confirmation data with 89atm to credit your account and verify payment authenticity.
• Identity Verification Partners: 89atm works with certified third-party KYC service providers who assist in verifying the authenticity of identity documents submitted by Members during the verification process.
• Fraud Prevention Systems: Our fraud detection systems gather behavioural and technical signals during your Platform sessions to identify unusual or suspicious activity patterns.

4 How We Use Your Data

89atm uses your personal data for the following purposes. We do not use your data for any purpose not listed here without first obtaining your explicit consent or as required by applicable law:

• Account Creation and Management: To register your 89atm account, verify your identity, manage your profile, and maintain the ongoing integrity of your account.
• Processing Transactions: To process PKR deposits and withdrawals via your preferred payment method (JazzCash, EasyPaisa, bank transfer, or card), to detect and prevent fraudulent transactions, and to maintain accurate financial records.
• Platform Delivery: To provide you with access to cricket betting, live casino, slots, and all other gaming products on the 89atm Platform, and to personalise your gaming experience based on your preferences and activity history.
• KYC and AML Compliance: To verify your identity and age (21+), to comply with anti-money laundering obligations under our international gaming licence, and to fulfil any reporting obligations to our licensing authority.
• Responsible Gaming: To monitor your gaming activity for signs of problem gambling behaviour, to enforce deposit limits and self-exclusion requests, and to send responsible gaming reminders where appropriate.
• Customer Support: To respond to your queries, complaints, and support requests efficiently and to maintain a record of your communication history for quality assurance purposes.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates by email or SMS — but only where you have given explicit opt-in consent and only for 89atm's own products and services.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, bonus abuse, and other prohibited conduct as described in the 89atm Terms & Conditions.
• Legal Obligations: To comply with applicable legal, regulatory, and licensing requirements, including responding to lawful requests from regulatory authorities.

5 Legal Basis for Processing

89atm processes your personal data on the following legal bases, in accordance with internationally recognised data protection principles:

• Performance of a Contract: The majority of our processing activities — including account management, transaction processing, and Platform delivery — are necessary to perform the contract between 89atm and you as a Member under our Terms & Conditions.
• Compliance with Legal Obligations: KYC verification, AML monitoring, age verification, and regulatory reporting are carried out because we are legally required to do so under the requirements of our international gaming licence.
• Legitimate Interests: Fraud prevention, platform security, and responsible gaming monitoring activities are carried out on the basis of 89atm's legitimate business interests, balanced against your right to privacy. We carry out these activities in the least intrusive manner possible.
• Consent: Marketing communications by email or SMS are sent only where you have given explicit, freely-given, and informed consent. You may withdraw your marketing consent at any time by updating your preferences in your account settings or by contacting support.

6 Data Sharing & Disclosure

89atm shares your personal data only with the following categories of recipients and only to the extent strictly necessary for the stated purpose:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard receive the minimum transaction data required to process your deposit or withdrawal requests. These providers have their own privacy policies governing their processing activities.
• KYC and Identity Verification Partners: Certified third-party identity verification services receive copies of your submitted identity documents solely for the purpose of confirming their authenticity and verifying your eligibility to use the Platform.
• Fraud Prevention & Security Providers: Specialist anti-fraud and cybersecurity vendors may receive technical and behavioural data about your Platform sessions to assist in the detection and prevention of fraudulent activity.
• Licensing and Regulatory Authorities: 89atm is required by the terms of its international gaming licence to provide certain data to the relevant licensing authority upon request. This may include account activity data, KYC records, and financial transaction data.
• Legal and Law Enforcement Authorities: Where legally required to do so by court order, subpoena, or other lawful process, 89atm may disclose personal data to law enforcement or judicial authorities. We will notify you of any such disclosure unless legally prohibited from doing so.
• Professional Advisers: Our legal, accounting, and compliance advisers may access relevant personal data where strictly necessary for the performance of their professional services, subject to confidentiality obligations.

All third-party service providers with whom 89atm shares personal data are required to process that data in accordance with applicable data protection standards and are contractually prohibited from using it for any purpose other than the one for which it was shared.

7 Cookies & Tracking Technologies

89atm uses cookies and similar tracking technologies on the Platform to ensure its proper functioning, to enhance your user experience, and to support our security and fraud prevention systems. The following types of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They include session authentication cookies that keep you logged into your account and security cookies that protect against cross-site request forgery attacks. These cookies cannot be disabled without impairing basic Platform functionality.
• Performance Cookies: These cookies collect anonymised data about how you interact with the Platform — which pages you visit most, how long sessions last, and where errors occur. This data helps us improve the Platform's performance and user experience.
• Functional Cookies: These cookies remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations, to provide a more personalised experience on return visits.
• Analytics Cookies: We use first-party analytics tools to understand aggregate usage patterns across the Platform. No data from analytics cookies is shared with third-party advertising networks.

You can manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of the Platform. 89atm does not use third-party advertising cookies or retargeting pixels.

8 Data Retention

89atm retains your personal data for as long as your account remains active and for a defined period after account closure, in accordance with our legal and regulatory obligations. The following retention periods apply:

• Account and Identity Data: Retained for a minimum of five (5) years following account closure, as required by our international gaming licence for AML compliance and regulatory audit purposes.
• Financial Transaction Data: Retained for a minimum of five (5) years following each transaction date, in compliance with financial record-keeping requirements under our operating licence.
• Gaming Activity Data: Retained for up to five (5) years following the relevant gaming session or bet, for responsible gaming monitoring, dispute resolution, and regulatory reporting purposes.
• Customer Support Communications: Retained for up to three (3) years following the closure of a support ticket, for quality assurance and dispute reference purposes.
• Marketing Consent Records: Retained for the duration of your consent and for up to two (2) years after withdrawal of consent, as evidence of compliance with marketing regulations.
• Self-Exclusion Records: Retained indefinitely to prevent self-excluded Members from re-registering on the Platform under different identities.

9 Your Data Rights

As a Member of 89atm, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact our data protection team using the details in Section 14. We will respond to all valid requests within 30 days of receipt:

10 Data Security

89atm implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our security framework includes the following measures:

• SSL/TLS Encryption: All data transmitted between your device and the 89atm Platform is encrypted in transit using industry-standard TLS 1.3 protocols. Look for the padlock icon in your browser's address bar when using the Platform.
• Encryption at Rest: Sensitive data fields — including CNIC numbers, financial account details, and KYC documents — are encrypted at rest in our database using AES-256 encryption.
• Access Controls: Access to personal data within 89atm's systems is strictly limited to authorised personnel on a need-to-know basis. All staff access is logged and subject to regular audit.
• Two-Factor Authentication (2FA): 89atm supports and encourages the use of two-factor authentication for all Member accounts as an additional layer of identity protection.
• Regular Security Audits: Our Platform infrastructure and data handling procedures are subject to regular independent security audits and penetration testing under the requirements of our international gaming licence.
• Incident Response: In the event of a personal data breach that poses a risk to your rights and freedoms, 89atm will notify the relevant regulatory authority and, where required, affected Members without undue delay.

While 89atm takes every reasonable precaution to protect your data, no internet transmission or digital storage system is completely immune to risk. You are responsible for maintaining the confidentiality of your own account credentials and for notifying 89atm immediately if you suspect unauthorised access to your account.

11 Children's Privacy

The 89atm Platform is strictly intended for use by individuals who are 21 years of age or older. 89atm does not knowingly collect or process personal data from any person under the age of 21. Age verification checks are conducted during registration and before the first withdrawal is processed to enforce this restriction.

If 89atm discovers that personal data has been collected from an individual under the age of 21 — whether through fraudulent registration, shared device access, or any other means — the associated account will be immediately suspended, all data will be handled in accordance with our responsible gaming and KYC policies, and any deposited funds will be returned to the relevant payment method after identity verification. If you are a parent or guardian and believe a minor has registered on 89atm using your device or payment method, please contact our support team immediately via live chat or email.

12 International Data Transfers

As an internationally licensed operator, 89atm may transfer personal data to servers and service providers located outside Pakistan. Where such transfers occur, 89atm ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy. These safeguards may include contractual data transfer agreements with our service providers that incorporate internationally recognised standard contractual clauses for data protection.

89atm's primary data processing infrastructure is located in jurisdictions with established data protection frameworks. All third-party service providers engaged by 89atm who receive personal data are contractually required to maintain data protection standards consistent with this Policy and applicable international data protection principles.

13 Changes to This Policy

89atm reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, new products or services, or evolving legal and regulatory requirements. Any material changes to this Policy will be communicated to registered Members by email notification to the registered email address and by publishing the updated Policy on this page with a revised "Last Updated" date at the top.

Where a change materially affects your rights or the way we process your personal data, we will provide a minimum of 14 days' advance notice before the change takes effect. Your continued use of the 89atm Platform following the publication of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you may close your account by contacting our support team.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or 89atm's data processing practices, or if you wish to exercise any of the data rights described in Section 9, please contact our data protection team through any of the following channels:

• Live Chat: Available directly on the 89atm Platform, 8:00 AM – 2:00 AM PKT daily. This is the fastest way to reach our team for urgent privacy-related matters.
• Email: [email protected] — please include "Privacy Request" in the subject line and provide your registered username and the nature of your request. We aim to acknowledge all privacy requests within 24 business hours.
• Support Hours: 8:00 AM to 2:00 AM Pakistan Standard Time (PKT), seven days a week.

When submitting a data rights request, please be prepared to verify your identity by providing your registered username and the last four digits of your CNIC to ensure we process your request accurately and securely.