td99 Privacy Policy

Throughout this Privacy Policy, the following terms carry the meanings set out below unless the context clearly requires otherwise:

• "td99" / "we" / "us" / "our" — refers to the td99 online casino and sports betting platform, operated at td99.ws and all associated subdomains and mobile interfaces.
• "Player" / "you" / "your" — refers to any individual who accesses, browses, registers on, or uses the td99 platform in any capacity.
• "Personal Data" — any information that identifies or could reasonably identify a living individual, including name, email address, mobile number, date of birth, residential address, IP address, device identifiers, and financial transaction data.
• "Processing" — any operation or set of operations performed on Personal Data, including collection, storage, use, disclosure, transfer, amendment, or deletion.
• "KYC Data" — Know Your Customer documentation and associated personal information collected for the purpose of verifying a Player's identity and age in accordance with td99's regulatory obligations.
• "Cookies" — small text files placed on a Player's device by the td99 platform for the purposes of session management, analytics, and personalisation.
• "Third-Party Processor" — any external company or service provider engaged by td99 to process Personal Data on td99's behalf under a binding data processing agreement.
• "PKR" — Pakistani Rupee, the primary transactional currency of the td99 platform.

td99 collects Personal Data from Players across several categories. The table below summarises the categories of data we collect, specific data points within each category, and the primary purpose for which each category is processed:

td99 collects Personal Data through the following channels and mechanisms:

• Direct Registration: When you create a td99 account, you directly provide Identity Data, Contact Data, and account credentials. This is the primary source of your personal information on the platform.
• KYC Submission: When you submit identity verification documents in order to process your first withdrawal, td99 collects KYC Documentation directly from you through the secure in-platform verification portal.
• Deposit & Withdrawal Transactions: Financial Data is collected when you initiate a PKR deposit via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or cryptocurrency, and when you submit withdrawal requests through the platform cashier.
• Platform Interaction: Technical Data and Usage Data are collected automatically as you navigate, play, and interact with td99.ws. This includes session logging, in-play betting activity, and click-path data recorded by our platform analytics systems.
• Support Communications: When you contact td99 via live chat or email, the content of that communication, including your queries and any personal information you choose to include, is recorded as Communications Data.
• Cookies and Tracking Technologies: When you visit td99.ws, cookies and similar tracking technologies collect Technical Data relating to your device and browsing behaviour. Full details are provided in Section 07 (Cookies & Tracking) below.

td99 processes your Personal Data on the following legal bases, each of which applies to specific processing activities as set out below:

• Contractual Necessity: Processing of Identity Data, Contact Data, and Financial Data is necessary to enter into and perform the contract between td99 and the Player as established by the td99 Terms and Conditions. Without this processing, td99 cannot create your account, accept your deposits, or pay out your winnings.
• Legal Obligation: KYC Data and Financial Data are processed to fulfil td99's legal obligations under international anti-money laundering (AML) standards, Know Your Customer (KYC) regulations, and the requirements of our operating licence. This processing cannot be refused by Players who wish to withdraw funds.
• Legitimate Interests: Technical Data and Usage Data are processed on the basis of td99's legitimate interest in maintaining platform security, detecting fraud, preventing multi-accounting, and monitoring for responsible gaming risk indicators. These interests are balanced against Players' privacy rights and are limited to what is proportionate and necessary.
• Consent: Marketing communications (including promotional emails, bonus notifications, and PSL cricket betting updates) are sent only where you have provided explicit consent at the time of registration or subsequently via the account preferences panel. You may withdraw this consent at any time.

td99 uses the Personal Data we collect for the following specific purposes. We do not use your data for any purpose incompatible with those listed below without first providing notice and, where required, obtaining your consent:

• Account Creation and Management: To register your td99 account, maintain accurate account records, process account changes, and communicate account-related notifications including security alerts and balance updates.
• Payment Processing: To process PKR deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency channels, and to process withdrawal requests to your verified payment methods in a timely manner.
• Identity and Age Verification (KYC): To verify that you are at least 21 years of age and that your identity matches the account information provided, in compliance with td99's regulatory obligations. KYC verification is mandatory before processing any withdrawal.
• Fraud Detection and Platform Security: To identify suspicious account activity, detect multi-accounting, flag unusual wagering patterns associated with bonus abuse or match-fixing, and to protect the integrity of the td99 platform for all players.
• Responsible Gaming Monitoring: To monitor wagering patterns for indicators of problem gambling behaviour, to administer self-exclusion requests, deposit limit adjustments, and cooling-off periods, and to proactively contact Players who may be at risk.
• Customer Support: To respond to your queries via live chat or email, resolve disputes, process complaints, and maintain support records required for regulatory compliance and quality assurance.
• Platform Analytics and Improvement: To understand how Pakistani players use td99, identify technical issues, optimise the user interface, and improve the quality and range of gaming content and services available on the platform.
• Marketing Communications (With Consent): To send you information about td99 promotions, welcome bonuses, PSL cricket betting offers, slot tournaments, and other platform news where you have provided consent. You may opt out at any time.
• Regulatory Record-Keeping: To maintain transaction records, KYC documentation, and communications logs for the minimum periods required by our operating licence and applicable international AML standards.

td99 does not sell or trade your Personal Data. We share your data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment Processing Partners: Financial Data is shared with payment service providers including JazzCash, EasyPaisa, and partner banking institutions (HBL, UBL, Meezan Bank) solely for the purpose of processing your PKR deposit and withdrawal transactions. These providers are bound by their own regulatory obligations regarding data security.
• KYC and Identity Verification Providers: KYC Documentation may be processed by contracted third-party identity verification service providers. These providers operate under binding data processing agreements and process your data exclusively for the purpose of age and identity verification on td99's behalf.
• Game Technology Providers: Usage Data relating to specific game sessions may be shared with third-party game software providers whose titles appear on td99, strictly for the purpose of game outcome verification, RNG auditing, and technical support.
• Fraud and AML Detection Systems: Technical Data and Financial Data may be processed by third-party fraud detection and anti-money laundering compliance platforms engaged by td99 to monitor for suspicious activity across the platform.
• Regulatory and Law Enforcement Authorities: td99 is legally obligated to disclose certain Player data to relevant financial intelligence units, licensing regulators, or law enforcement agencies where required by applicable law, court order, or regulatory directive. td99 will not notify Players of such disclosures where prohibited from doing so by law.
• Corporate Transactions: In the event of a merger, acquisition, or restructuring of the td99 business, Player data may be transferred to the acquiring or successor entity, subject to the same privacy protections described in this policy. Players will be notified of any such transfer.

td99.ws uses cookies and similar tracking technologies to operate the platform, maintain your login session, and collect analytics data. The following categories of cookies are used on the td99 platform:

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair or prevent access to the td99 platform. Disabling analytics cookies will not affect your ability to play, deposit, or withdraw.

td99 retains your Personal Data for no longer than is necessary to fulfil the purposes for which it was collected, subject to the minimum retention periods required by our operating licence and applicable AML regulations. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active account plus a minimum of five (5) years following permanent account closure. This retention period is required by international AML and KYC compliance standards.
• Financial Transaction Data: All PKR deposit and withdrawal records are retained for a minimum of five (5) years from the date of each transaction, in accordance with financial record-keeping obligations under our operating licence.
• KYC Documentation: Identity documents, CNIC scans, and proof of address records are retained for the duration of your active account plus five (5) years following closure. Copies are securely destroyed at the end of this period.
• Communications Data: Live chat transcripts and support email correspondence are retained for three (3) years from the date of the communication, to support dispute resolution and quality assurance review.
• Usage and Technical Data: Aggregated platform analytics data is retained for up to twelve (12) months in identifiable form, after which it is anonymised. Anonymised analytics data may be retained indefinitely for platform improvement purposes.
• Marketing Consent Records: Records of marketing consent (or withdrawal of consent) are retained for the lifetime of your account plus three (3) years, to provide evidence of consent status in the event of a complaint or regulatory enquiry.

When the applicable retention period expires, Personal Data is securely deleted or anonymised using processes that prevent reconstruction of identifiable information.

td99 implements a layered, defence-in-depth approach to the security of all Personal Data held on our platform. The following technical and organisational security measures are in place:

• Encryption in Transit: All data transmitted between your device and td99.ws is protected using TLS 1.2 or higher encryption. This applies to all platform pages, the account registration flow, the cashier, and live chat communications.
• Encryption at Rest: Personal Data stored in td99's databases is encrypted using AES-256 symmetric encryption. Encryption keys are managed using hardware security modules and are rotated on a regular schedule.
• Password Hashing: Account passwords are never stored in plain text. Passwords are hashed using bcrypt with a per-user salt, ensuring that even a hypothetical breach of the database would not expose Player passwords in readable form.
• Access Controls: Access to Personal Data within td99's systems is restricted to staff and contractors who have a legitimate operational need. Access is governed by role-based permissions and is subject to regular review.
• Two-Factor Authentication: td99 strongly recommends that all Players enable 2FA on their accounts. 2FA adds an additional layer of protection against unauthorised access to your account and associated personal data.
• Penetration Testing and Audits: td99's platform undergoes regular security assessments, including third-party penetration testing, to identify and remediate potential vulnerabilities before they can be exploited.
• Incident Response: In the event of a personal data breach that poses a risk to Players, td99 will notify affected Players without undue delay, and will report the breach to relevant regulatory authorities where required. Notification will include the nature of the breach, data affected, likely consequences, and measures taken.

As a td99 player, you hold the following rights in relation to your Personal Data. All data rights requests should be submitted in writing to the td99 support team at the contact details provided in Section 13. Requests will be responded to within 30 calendar days of receipt of a verified request:

• Right of Access: You have the right to request a copy of all Personal Data td99 holds about you. td99 will provide this information in a structured, readable format within 30 days.
• Right to Rectification: If any Personal Data td99 holds about you is inaccurate or incomplete, you have the right to request that it be corrected without undue delay.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where you object to processing based on legitimate interests. Please note that this right is subject to overriding legal retention obligations, including AML record-keeping requirements, which may prevent full erasure during the applicable retention period.
• Right to Restriction of Processing: You may request that td99 restrict the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending a determination of whether td99's legitimate interests override yours.
• Right to Data Portability: You may request a copy of Personal Data you provided to td99 in a structured, machine-readable format for the purpose of transferring it to another service provider.
• Right to Object: You have the right to object to processing of your Personal Data carried out on the basis of legitimate interests. You also have the absolute right to object to processing for direct marketing purposes, which td99 will action immediately upon receipt.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

td99 operates an absolute minimum age policy of 21 years. The td99 platform is not directed at, and does not knowingly collect Personal Data from, any individual under the age of 21.

Age verification is a mandatory step in the td99 account lifecycle. All withdrawal requests require submission of KYC documentation confirming that the account holder is 21 or older. Any account found to have been registered by a person under the age of 21 will be immediately suspended, all associated funds will be forfeited, and the matter will be escalated in accordance with td99's regulatory obligations.

td99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, platform functionality, data processing practices, or business operations.

When material changes are made to this Privacy Policy, td99 will notify registered Players by posting a prominent notice on the td99 platform and, where appropriate, by sending a notification to the registered email address associated with your account. The updated Privacy Policy will clearly display the effective date of the revised version.

The current version of this Privacy Policy is always accessible at td99.ws/privacy-policy. It is your responsibility to review this policy periodically to remain informed of how td99 handles your Personal Data.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or need to report a privacy concern, please contact the td99 Data Privacy team using the following details:

• Live Chat: Available 24/7 within the td99 platform. For general privacy queries and account data requests, live chat is the fastest route to our support team. Pakistani players in Karachi, Lahore, Islamabad, and Faisalabad can reach us in English or Urdu.
• Email: [email protected] — for formal written data rights requests, erasure requests, portability requests, and privacy complaints. Please include your registered account username and the nature of your request in the subject line.
• Response Time: td99 will acknowledge all privacy-related written requests within 5 business days and will provide a full substantive response within 30 calendar days of receipt of a verified request.