td99 Privacy Policy

1 Overview

1.1 td99 is committed to handling the personal data of all players — including those in Karachi, Lahore, Faisalabad, Islamabad, and across Pakistan — with transparency, care, and respect. This Policy has been drafted to explain our data practices in plain terms while maintaining the legal precision required of a licensed online gaming operator.

1.2 td99 acts as the data controller in respect of personal data collected from players during account registration, gameplay, and transactions on the td99 platform.

1.3 This Policy should be read alongside the td99 Terms and Conditions and Responsible Gaming Policy, both of which are available on this website.

2 Data We Collect

2.1 td99 collects the following categories of personal data from players:

Category	Examples
Identity Data	Full legal name, date of birth, national ID number or CNIC, gender
Contact Data	Email address, mobile phone number, residential address including city (e.g. Lahore, Karachi)
Account Data	Username, hashed password, account preferences, communication settings
Financial Data	JazzCash or EasyPaisa wallet identifiers, bank account details (HBL, UBL, Meezan Bank), PKR deposit and withdrawal history
Verification Data	Copies of government-issued ID, proof of address documents submitted during KYC
Gameplay Data	Bet history, game sessions, win/loss records, bonus usage, wagering activity
Technical Data	IP address, device type and model, operating system, browser type, session timestamps, login history
Communication Data	Records of live chat interactions, support tickets, email correspondence with td99
Marketing Data	Promotional preferences, campaign interaction history, opt-in/opt-out status

2.2 td99 does not intentionally collect special categories of sensitive personal data (such as health, religious, political, or biometric data) from players. If any such data is inadvertently received, it will be deleted promptly.

3 How We Collect Your Data

3.1 td99 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, using live chat support, or responding to promotional communications.
• Automated collection: Technical data collected automatically when you access td99.asia, including via cookies, log files, and analytics tools.
• Third-party sources: Identity and fraud-screening data received from KYC verification partners, payment processors (including JazzCash and EasyPaisa), and fraud prevention databases where applicable.

4 Purpose of Processing Your Data

4.1 td99 uses the personal data it collects for the following purposes:

• Creating, managing, and maintaining your td99 Account;
• Processing PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and bank transfer;
• Verifying your identity and age (21+ requirement) through our KYC process;
• Detecting and preventing fraud, money laundering, and other financial crimes;
• Complying with our obligations under our international gaming licence and applicable laws;
• Providing customer support through live chat and other channels;
• Personalising your experience on the td99 platform based on gameplay preferences;
• Sending account-related communications, including transaction confirmations and security alerts;
• Sending promotional communications where you have opted in or where otherwise permitted;
• Monitoring and improving platform performance, security, and user experience;
• Administering responsible gaming tools, including deposit limits and self-exclusion;
• Investigating and resolving complaints and disputes.

5 Legal Basis for Processing

5.1 td99 processes personal data on the following legal bases:

• Performance of a contract: Processing necessary to create and administer your td99 Account, process transactions, and deliver the services you have requested.
• Legal obligation: Processing required to comply with anti-money laundering (AML) legislation, gaming licence conditions, age verification requirements, and tax reporting obligations.
• Legitimate interests: Processing for fraud detection, platform security, responsible gaming monitoring, and business analytics — where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where your freely given and informed consent has been obtained.

6 How We Share Your Data

6.1 td99 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the following limited circumstances:

• Payment processors: Financial data is shared with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment partners strictly to process your PKR transactions.
• KYC and identity verification providers: Identity and verification documents are shared with certified third-party verification services to fulfil our age and identity check obligations.
• Game providers: Gameplay data may be shared with licensed game studios whose titles are integrated into the td99 platform, solely for the purpose of game delivery and RNG audit compliance.
• Fraud prevention services: Relevant technical and financial data may be shared with fraud prevention databases to protect the platform and its players from financial crime.
• Regulatory and legal authorities: We may disclose personal data to regulators, law enforcement agencies, or courts where required by law or a valid legal order.
• Corporate transactions: In the event of a merger, acquisition, or sale of td99 assets, personal data may be transferred as part of that transaction, subject to equivalent privacy protections being maintained.

7 Data Retention

7.1 td99 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law, licensing conditions, or regulatory guidance.

7.2 The following general retention periods apply:

• Account and identity data: Retained for the lifetime of your td99 Account plus a minimum of five (5) years following account closure, to meet AML and gaming licence record-keeping requirements.
• Financial and transaction data: Retained for a minimum of seven (7) years from the date of the transaction, in line with standard financial record-keeping obligations.
• KYC verification documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Gameplay data: Retained for the lifetime of the account and for five (5) years following closure, to support dispute resolution and responsible gaming monitoring.
• Marketing preferences and communication records: Retained until you withdraw your consent, plus a reasonable period thereafter to process the opt-out.

7.3 Where personal data is no longer required for any lawful purpose, td99 will securely delete or anonymise it.

8 Security of Your Data

8.1 td99 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the td99 platform;
• Encryption of sensitive data fields at rest, including financial identifiers and identity document references;
• Access controls restricting internal access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of the td99 platform;
• Two-factor authentication options available to all registered players;
• Monitoring systems to detect and respond to suspicious account activity.

8.2 While td99 takes all reasonable precautions to safeguard your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own login credentials and for notifying td99 promptly of any suspected unauthorised access to your Account.

9 Cookies and Tracking Technologies

9.1 td99 uses cookies and similar technologies on td99.asia for the following purposes:

• Strictly necessary cookies: Essential to platform functionality, including session management, login persistence, and security operations. These cannot be disabled.
• Performance cookies: Used to collect aggregated, anonymised data about how players interact with td99.asia, to help us improve platform performance and navigation.
• Functional cookies: Used to remember your preferences, such as language settings and game history display options.
• Marketing cookies: Used to track campaign effectiveness and, where you have consented, to deliver relevant promotions. These are only activated with your consent.

9.2 You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may impair your ability to use the td99 platform.

10 International Data Transfers

10.1 As an internationally licensed online gaming platform serving players in Pakistan, td99 may transfer personal data to servers and service providers located outside Pakistan. Where such transfers occur, td99 takes steps to ensure that appropriate safeguards are in place, including contractual protections and data processing agreements that require the recipient to maintain standards of data protection equivalent to those described in this Policy.

11 Minors and Age Restriction

11.1 If you are a parent or guardian and believe that a person under 21 in your care has registered an account on td99, please contact our support team immediately via live chat so the account can be closed without delay.

12 Your Rights in Respect of Your Personal Data

12.1 Depending on applicable law and the specific circumstances, you may have the following rights in respect of personal data held about you by td99:

• Right of access: You may request confirmation of whether td99 holds personal data about you and, if so, a copy of that data.
• Right to rectification: You may request that inaccurate or incomplete personal data held about you be corrected.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to td99's legal retention obligations.
• Right to restrict processing: You may request that td99 restrict the processing of your personal data in certain circumstances, for example while a correction request is being verified.
• Right to data portability: You may request that td99 provide a copy of personal data you have provided in a structured, machine-readable format.
• Right to object: You may object to processing of your personal data carried out on the basis of legitimate interests, and to processing for direct marketing purposes.
• Right to withdraw consent: Where processing is based on your consent (e.g. marketing emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

12.2 To exercise any of the above rights, please contact the td99 support team via live chat. We will respond to verifiable requests within thirty (30) days. We may request proof of identity before processing a rights request to prevent unauthorised disclosure.

13 Marketing Communications

13.1 td99 may send you marketing communications by email or SMS where you have opted in to receive them, or where permitted under applicable law for existing customers.

13.2 You can opt out of marketing communications at any time by following the unsubscribe instructions in any marketing email, or by contacting td99 support via live chat and requesting to be removed from marketing lists. Opting out of marketing will not affect account-related communications such as transaction confirmations, security alerts, or support responses.

13.3 td99 does not share player contact details with third parties for marketing purposes.

14 Third-Party Services and Links

14.1 The td99 platform integrates third-party services for payment processing, game delivery, and analytics. While td99 takes care in selecting reputable partners, this Policy applies only to data processing conducted by td99 directly. Third-party services operate under their own privacy policies, which td99 does not control.

14.2 td99 does not include external links to third-party websites within the main platform content. Any data shared with payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank) is governed by the data processing agreements td99 holds with those providers.

15 Changes to This Privacy Policy

15.1 td99 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email to their registered address and/or by a prominent notice on the td99 platform.

15.2 The effective date at the top of this document reflects when the current version of the Policy entered into force. Continued use of the td99 platform after a Policy update constitutes acceptance of the revised Policy. You should review this page periodically to stay informed of any changes.

16 Contact Us

16.1 If you have any questions, concerns, or requests relating to this Privacy Policy or td99's data practices, please contact us through the live chat support function available 24/7 on the td99 platform.

16.2 Our data protection contact can also be reached at the email address below. This address is for privacy-related enquiries only:

16.3 td99 will acknowledge all privacy-related enquiries within five (5) business days and aim to provide a full response within thirty (30) days of receipt.