Privacy Policy

Introduction

hc99 (accessible at hc99.cam) is an online gaming and sports betting information platform serving adult users across Pakistan. We understand that your personal data is important, and we take our responsibility to protect it seriously. This Privacy Policy sets out, in plain and formal terms, exactly how we handle the information you share with us — whether you are simply browsing the platform, registering an account, or making use of any of our betting guides and review features.

This policy applies to all personal data collected through hc99.cam, including any data submitted via account registration, identity verification, financial transactions, customer support interactions, and general platform usage. It covers data collected from users located in Pakistan — including those accessing hc99 from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, and Peshawar — as well as users accessing the platform from other locations.

We do not sell personal data to third parties. We do not use your data for purposes beyond those described in this policy without first seeking your consent or establishing another valid legal basis for processing.

Definitions

For the purposes of this Privacy Policy, the following terms carry 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, date of birth, device identifiers, and financial details.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, and deletion.
• "Data Controller" means hc99, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" means any third party that processes personal data on behalf of hc99 under a data processing agreement.
• "User" means any individual who accesses hc99.cam, whether or not they hold a registered account.
• "KYC" means Know Your Customer identity and age verification procedures required under applicable anti-money laundering and responsible gambling obligations.
• "Cookie" means a small data file placed on your device by a website to store preferences, session information, or analytical data.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data for a stated purpose.

Data We Collect

We collect the following categories of personal data, limited to what is necessary for the purposes described in this policy:

We do not intentionally collect sensitive personal data (such as biometric data, health information, or political opinions) unless specifically required for regulatory purposes, in which case we will seek your explicit consent.

How We Collect Your Data

hc99 collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC, making deposits or withdrawals, or contacting our support team.
• Automated collection: Technical and usage data collected automatically as you interact with the platform, including via cookies and server logs.
• Third-party sources: Identity verification data received from KYC partners; fraud prevention data from risk management providers; payment confirmation data from payment processors. Payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, and Bank Alfalah are used as familiar processing references for Pakistani users only and do not imply those providers endorse gambling.
• Publicly available sources: In limited circumstances, we may supplement your data with information from public registers or databases for compliance purposes.

Legal Basis for Processing

hc99 processes personal data only where a valid legal basis exists. The primary legal bases on which we rely are:

• Contractual necessity: Processing required to fulfil our contractual obligations to you as a registered user, including account management, transaction processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, and tax obligations.
• Legitimate interests: Processing carried out in pursuit of our legitimate business interests — such as fraud prevention, platform security, and service improvement — where those interests are not overridden by your rights.
• Consent: Processing for purposes such as marketing communications or non-essential cookies, where we have obtained your prior consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

How We Use Your Data

Personal data collected by hc99 is used for the following specific purposes:

• Creating and managing your hc99 account, including verifying your identity and confirming your eligibility to use the platform.
• Processing financial transactions, including deposits and withdrawals denominated in PKR, and maintaining accurate transaction records.
• Conducting KYC verification to meet regulatory requirements and prevent underage gambling, fraud, and money laundering.
• Providing customer support and responding to your enquiries, complaints, or responsible gambling requests.
• Personalising your experience on the platform, including displaying content and offers relevant to your sports interests — such as Pakistan cricket, PSL/T20, and ICC tournaments.
• Monitoring platform usage to detect and prevent fraud, bonus abuse, collusion, and other prohibited conduct as described in our Terms & Conditions.
• Sending you service-related communications, including account alerts, transaction confirmations, and policy update notices.
• Complying with applicable law and cooperating with regulatory or law enforcement authorities where legally required.
• Analysing aggregated, anonymised usage data to improve the platform's features, performance, and responsible gambling safeguards.

We will not use your personal data for automated decision-making that produces significant legal effects without giving you the opportunity to request human review of that decision.

Data Sharing & Disclosure

hc99 does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances and only to the extent necessary:

• Service providers: Trusted third-party vendors who process data on our behalf under binding data processing agreements — including KYC verification partners, payment processors, cloud hosting providers, and analytics platforms. These providers are permitted to use your data only for the purposes specified by hc99.
• Regulatory and legal compliance: We may disclose personal data to relevant regulatory authorities, law enforcement bodies, or courts where required to do so by applicable law or a valid legal order.
• Business transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections. We will notify you of any such transfer.
• Protection of rights: We may disclose data where we reasonably believe disclosure is necessary to protect the rights, property, or safety of hc99, our users, or the public.

International Data Transfers

hc99 operates on a global infrastructure. As a result, your personal data may be transferred to and processed in countries outside Pakistan. Where such transfers occur, hc99 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required in your home jurisdiction.

Safeguards for international transfers include:

• Standard contractual clauses approved by relevant data protection authorities, incorporated into agreements with data processors located in other jurisdictions.
• Transfer only to jurisdictions that maintain adequate data protection standards as assessed by hc99 or relevant regulatory guidance.
• Technical security measures — including encryption and access controls — applied consistently regardless of where data is processed.

If you have questions about the specific safeguards applied to the transfer of your data, you may contact us at [email protected].

Data Retention

hc99 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the satisfaction of any legal, regulatory, accounting, or reporting requirements.

Our general retention approach is as follows:

• Account data: Retained for the duration of your account and for a minimum period of five (5) years following account closure, to satisfy AML and regulatory record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, or longer where required by applicable law.
• KYC documentation: Retained for the period required by applicable identity verification regulations, typically five (5) years following the end of the business relationship.
• Support and communications data: Retained for a period of two (2) years from the date of last interaction, unless a complaint or legal matter requires longer retention.
• Technical and usage data: Typically retained in identifiable form for up to thirteen (13) months, after which it is anonymised or deleted.

When data is no longer required, hc99 securely deletes or anonymises it in accordance with our internal data disposal procedures.

Cookies & Tracking Technologies

hc99 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit hc99.cam. They allow us to recognise your browser, remember your preferences, and analyse how the platform is used.

We use the following types of cookies:

• Essential cookies: Strictly necessary for the platform to function. These enable core features such as session management, login state, and security. They cannot be disabled without impairing platform functionality.
• Analytics cookies: Used to collect aggregated, anonymised information about how users interact with hc99 — such as pages visited and session duration — to help us improve the platform.
• Preference cookies: Used to remember your settings and display preferences, such as language or region selection, across sessions.
• Marketing cookies: Where consent has been obtained, used to deliver relevant promotional content based on your interaction with the platform. These are not set without your prior consent.

You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the platform. Your cookie preferences can also be updated via our cookie consent interface where available.

Children's Privacy

hc99 is strictly an adults-only platform. We do not knowingly collect personal data from individuals under the age of 18, or the higher minimum age required by the applicable laws of a user's jurisdiction. All users are required to confirm their age during registration, and we conduct KYC verification to enforce this requirement.

If we become aware that personal data has been collected from a minor without verifiable parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor may have registered on the platform, please contact us immediately at [email protected].

Security Measures

hc99 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your browser and our servers.
• Encryption of sensitive data — including financial information and identity documents — at rest using industry-standard algorithms.
• Strict access controls ensuring that personal data is accessible only to authorised personnel who require it for their specific roles.
• Regular internal security reviews, vulnerability assessments, and penetration testing of our platform infrastructure.
• Incident response procedures to detect, contain, and notify affected users and relevant authorities in the event of a personal data breach, in accordance with applicable law.

While we take every reasonable precaution, no system is entirely immune to security risks. We encourage you to use a strong, unique password for your hc99 account and to contact us immediately if you suspect any unauthorised activity.

Your Rights

Subject to applicable law and verification of your identity, you hold the following rights in relation to the personal data hc99 holds about you:

• Right of access: You may request a copy of the personal data we hold about you, along with information about how it is being used.
• Right to rectification: You may request the correction of inaccurate or incomplete personal data without undue delay.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to restrict processing: You may request that we temporarily halt the processing of your personal data in certain circumstances — for example, while you contest its accuracy.
• Right to data portability: Where processing is based on consent or contract and carried out by automated means, you may request that we provide your data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing carried out on the basis of legitimate interests, including profiling, where your individual circumstances warrant it.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond to all verifiable requests within thirty (30) days. Where a request is complex or numerous, we may extend this period by a further thirty (30) days with notice.

Third-Party Links

hc99.cam may contain references to third-party platforms, games, or services. Where links to external websites are present, please be aware that those sites are governed by their own privacy policies, for which hc99 bears no responsibility. We recommend reviewing the privacy policy of any third-party site you visit.

hc99 does not control the data practices of third-party platforms and cannot guarantee their compliance with applicable privacy standards. Accessing a third-party platform from hc99.cam is done entirely at your own risk and discretion.

Policy Updates

hc99 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will update the effective date at the top of this page and, where appropriate, notify registered users via their registered email address.

Your continued use of hc99.cam following publication of an updated Privacy Policy constitutes your acknowledgement of the revised terms. We recommend checking this page periodically to stay informed. The current version of this policy will always be accessible at hc99.cam/privacy-policy.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how hc99 handles your personal data, please reach out to our team:

Our support team serves users across Pakistan — including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, and Peshawar — and is available to assist with any privacy-related enquiry.