Your Data, Your Rights —
Protected by s9gam

1. Who We Are & How to Contact Us

s9gam is an online gaming platform operating at https://s9gam.pro, serving players across Pakistan including Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and Multan. s9gam operates under an international gaming licence that mandates robust data protection standards as a condition of continued operation.

For the purposes of this Privacy Policy, s9gam is the data controller — meaning we determine the purposes and means by which your personal data is processed. If you have any questions, concerns, or requests relating to this Privacy Policy or the personal data s9gam holds about you, please contact our dedicated data protection team using the following details:

This Privacy Policy was last reviewed and updated on 1 January 2026. It applies to all personal data collected through the s9gam website, mobile-optimised platform, customer support channels, and any other touchpoint through which s9gam interacts with players or prospective players.

2. Data We Collect

s9gam collects personal data through several distinct channels. The categories of data collected, and the circumstances in which they are collected, are set out below.

Data You Provide Directly:

• Registration Data: Full legal name, date of birth, Pakistani mobile number, email address, and preferred username provided when you create your s9gam account.
• KYC Verification Data: CNIC number, CNIC scan (front and back), proof of address documentation, selfie photographs, and payment method ownership evidence submitted during the identity verification process.
• Financial Data: Payment method details including JazzCash mobile wallet numbers, EasyPaisa account references, HBL, UBL, or Meezan Bank account identifiers, and transaction history associated with your s9gam account. Full bank account numbers and card numbers are not stored directly by s9gam — these are handled by our licensed payment processing partners.
• Communication Data: The content of messages exchanged with s9gam's customer support team via live chat or email, including any attachments you submit.
• Responsible Gaming Data: Any deposit limits, loss limits, self-exclusion requests, or cooling-off periods you voluntarily set through your account dashboard.

Data Collected Automatically:

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers collected each time you access the s9gam platform.
• Usage Data: Pages visited, games played, session durations, bet histories, bonus activations, and click-stream data reflecting how you interact with the s9gam platform.
• Cookie Data: Data collected through cookies and similar tracking technologies as described in Section 6 of this policy.

Data from Third Parties:

• Identity verification data returned by our KYC processing partners confirming the validity of your CNIC and proof of address documents.
• Fraud screening signals provided by our licensed payment processors to assist in detecting unauthorised transactions on your account.
• Responsible gaming flags from self-exclusion registers where s9gam is required to cross-reference player registrations under our gaming licence obligations.

3. How We Use Your Data

s9gam uses personal data for the following specific purposes. We do not use your data for any purpose not listed here without first seeking your explicit consent or updating this Privacy Policy in accordance with Section 12.

Where s9gam relies on legitimate interest as the legal basis for processing, we have conducted a balancing test to confirm that our interests do not override your fundamental rights and freedoms. You may request a copy of any legitimate interest assessment by contacting our support team.

4. Legal Basis for Processing

s9gam processes personal data under one or more of the following legal bases, in line with internationally recognised data protection standards applicable under our gaming licence jurisdiction:

• Contract Performance: Processing is necessary to perform the contract between you and s9gam — i.e., to operate your account, process your transactions, and deliver the gaming services you have registered to use.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including anti-money-laundering obligations, gaming licence conditions, age verification requirements, and tax reporting requirements.
• Legitimate Interest: Processing is necessary for s9gam's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — provided those interests are not overridden by your data protection rights.
• Consent: For specific processing activities — in particular, direct marketing communications — s9gam relies on your freely given, specific, and informed consent. You may withdraw consent at any time by adjusting your marketing preferences in your account settings or by contacting our support team.

5. Data Sharing & Third Parties

s9gam does not sell, rent, or trade your personal data to any third party for commercial purposes. Data is shared with third parties only in the circumstances listed below, and only to the extent strictly necessary for each specific purpose:

• Payment Processors: s9gam shares financial and identity data with licensed payment processing partners — including those facilitating JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank transactions — solely to process your deposit and withdrawal requests and to conduct fraud screening on those transactions.
• KYC Verification Partners: Identity documents submitted during KYC verification are processed by s9gam's licensed identity verification service providers. These partners are bound by strict data processing agreements and are prohibited from using your data for any purpose beyond CNIC and document validation.
• Regulatory Authorities & Law Enforcement: s9gam is legally required to disclose certain data to gaming regulators, financial intelligence units, and law enforcement agencies where required by applicable law, court order, or regulatory direction. s9gam will notify you of any such disclosure where legally permitted to do so.
• Responsible Gaming Registers: Where required by our gaming licence, s9gam cross-references player registrations against self-exclusion registers. This involves a limited and secure data transfer to the relevant register operator.
• Cloud Infrastructure Providers: s9gam uses cloud-based hosting and data storage services to operate the platform. These providers act as data processors under contractual agreements that mandate GDPR-aligned data protection standards.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of s9gam's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and provided with an opportunity to request deletion before the transfer is completed.

All third-party data processors engaged by s9gam are subject to written data processing agreements that bind them to use your data only for the specific purpose for which it was shared, to maintain appropriate security standards, and to delete or return the data upon termination of the processing relationship.

6. Cookies & Tracking Technologies

The s9gam platform uses cookies and similar tracking technologies to deliver core platform functionality, measure performance, and — where you have given consent — serve personalised content and marketing communications. The categories of cookies in use are as follows:

• Strictly Necessary Cookies: These cookies are essential for the s9gam platform to function correctly. They maintain your login session, remember your language preferences, and enable core security features. These cookies cannot be disabled without preventing access to the platform.
• Performance & Analytics Cookies: These cookies collect anonymised data about how players interact with the s9gam platform — including which pages are visited most frequently and where technical errors occur — to help us continuously improve the platform experience. We only deploy these cookies with your consent.
• Functional Cookies: These cookies remember your preferences — such as your preferred deposit method or session display settings — to provide a more personalised gaming experience on return visits.
• Marketing Cookies: Where you have explicitly opted into marketing communications, s9gam may use cookies to track which promotions you have viewed or engaged with, enabling us to avoid sending you offers you have already seen. These cookies are only active where marketing consent has been granted.

You can review and adjust your cookie preferences at any time by accessing the cookie settings panel available in the footer of every s9gam page. You may also manage cookies through your browser settings; however, disabling strictly necessary cookies will impair platform functionality.

7. Data Retention Periods

s9gam retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law and our gaming licence conditions. The table below sets out the standard retention periods applied to each category of data:

Upon expiry of the applicable retention period, s9gam will either securely delete your personal data or anonymise it in a manner that prevents re-identification. Where deletion is not immediately possible due to backup storage cycles, the data will be isolated and protected from any further active processing until deletion is completed.

8. Data Security Measures

s9gam implements a layered security architecture to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. The following technical and organisational measures are in place across all s9gam systems:

• Transport Encryption: All data transmitted between your device and s9gam's servers is protected by TLS 1.3 with 256-bit AES encryption. The s9gam platform enforces HTTPS across all pages with HTTP Strict Transport Security (HSTS) enabled.
• At-Rest Encryption: Personal data stored in s9gam's databases is encrypted at rest using AES-256. Encryption keys are managed through a dedicated key management system with strict access controls and regular rotation schedules.
• Access Controls: Access to systems containing personal data is restricted to authorised s9gam personnel on a strict need-to-know basis. All internal access is authenticated via multi-factor authentication and logged for audit purposes.
• Penetration Testing: s9gam's platform and infrastructure undergo regular independent penetration testing and vulnerability assessments to proactively identify and remediate security weaknesses before they can be exploited.
• Fraud Monitoring: Automated real-time monitoring systems scan for unusual account activity, unauthorised login attempts, and suspicious transaction patterns, with alerts escalated to s9gam's security team for immediate investigation.
• Incident Response: s9gam maintains a documented data breach response procedure. In the event of a breach affecting your personal data, s9gam will notify affected players and relevant regulatory authorities within the timeframes required by our gaming licence obligations.

9. Your Data Rights

As a player registered with s9gam, you hold the following rights over your personal data. These rights are enforceable and s9gam is committed to honouring every valid request within the timeframes specified below.

• Right of Access (Subject Access Request): You may request a copy of all personal data s9gam holds on you. We will provide this in a structured, commonly used format within five (5) business days of receiving your verified request.
• Right to Rectification: If personal data s9gam holds about you is inaccurate or incomplete, you may request that it be corrected. Corrections to account-critical data such as your name or date of birth may require re-submission of KYC documentation.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where: (a) the data is no longer necessary for the purpose it was collected; (b) you withdraw consent and no other legal basis for processing applies; or (c) the data has been unlawfully processed. Note that s9gam cannot delete data where retention is required by gaming licence conditions or applicable law.
• Right to Restrict Processing: You may request that s9gam restricts processing of your data — meaning we may store it but not actively use it — while a rectification request or objection is being considered.
• Right to Data Portability: You may request an export of your personal data in a machine-readable format (JSON or CSV) for transfer to another provider. This right applies to data you provided directly and that is processed on the basis of consent or contract.
• Right to Object: You may object to processing based on legitimate interest or to direct marketing at any time. Marketing objections are actioned within 48 hours. Other objections will be assessed and responded to within five (5) business days.
• Rights Related to Automated Decision-Making: Where s9gam uses automated systems to make decisions that significantly affect you — such as account suspension for fraud detection — you have the right to request human review of that decision.

To exercise any of the above rights, contact s9gam's support team at [email protected] with the subject line "Data Rights Request — [Your Account ID]" and specify which right you wish to exercise. We may ask you to verify your identity before processing your request. There is no fee for exercising your rights, and s9gam will never penalise you for doing so.

10. Children & Underage Players

s9gam operates an online gaming platform that is strictly restricted to individuals aged 21 years and above. The collection of personal data from persons under the age of 21 is not permitted under any circumstances, and s9gam implements multiple layers of age verification to enforce this restriction.

During the registration process, all prospective players are required to confirm that they are aged 21 or above. This declaration is followed by a mandatory KYC identity verification process in which s9gam verifies the player's date of birth against a valid CNIC or equivalent identity document before any real-money gaming activity is permitted.

If s9gam discovers or reasonably suspects that a player is under the age of 21 — at any point during the account lifecycle — the following actions will be taken immediately:

• The account will be suspended pending investigation.
• All real-money activity will be frozen.
• Any deposits made will be returned to the original payment method after verification.
• The account will be permanently closed and the registration data flagged in s9gam's internal age restriction database to prevent re-registration.

If you are a parent or guardian and believe that a minor in your care has registered or attempted to register with s9gam, please contact our support team immediately at [email protected]. We will investigate the matter and take appropriate action as a priority, typically within 24 hours of receipt of your report.

11. International Data Transfers

s9gam operates under an international gaming licence and, as a result, some personal data processed in connection with your account may be transferred to, stored in, or processed in countries outside Pakistan. This may occur, for example, when s9gam uses cloud infrastructure providers or KYC verification partners whose processing facilities are located in jurisdictions other than Pakistan.

Where such international transfers take place, s9gam ensures that adequate protections are in place to maintain a level of data protection equivalent to internationally recognised standards. The safeguards we rely upon include:

• Standard Contractual Clauses (SCCs): Where data is transferred to third-party processors in countries without an equivalent adequacy determination, s9gam relies on standard contractual clauses approved under applicable data protection frameworks to govern the transfer.
• Adequacy Decisions: Where transfers are made to countries that have been determined to provide an adequate level of data protection by relevant regulatory bodies, s9gam relies on that adequacy determination as the transfer mechanism.
• Data Processing Agreements: All international data processors engaged by s9gam are required to execute binding data processing agreements that mandate GDPR-aligned security standards and restrict onward transfers of your data.

You may request details of the specific transfer mechanisms applied to any particular international processing activity by contacting s9gam's data protection team at [email protected].

12. Changes to This Policy

s9gam reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, our gaming licence conditions, our data processing practices, or the services we offer. The "Last Updated" date at the top of this document will be revised each time an amendment is made.

Where a proposed amendment is material — meaning it significantly affects your rights or how your personal data is processed — s9gam will provide not less than fourteen (14) days' advance notice via a prominent notice on the platform and, where practicable, via email notification to your registered address before the revised policy takes effect.

Non-material amendments — such as typographical corrections or clarifications that do not change the substance of how data is processed — may be published without advance notice and will take effect immediately upon publication.

Your continued use of the s9gam platform following the publication of any revised Privacy Policy constitutes your acknowledgement of the updated policy. If you do not agree with the revised terms, you should cease using the platform and may request account closure and data deletion in accordance with Section 9 of this policy.