92stark Privacy Policy — Your Data, Your Rights

This Privacy Policy applies to all services operated by 92stark under the domain 92stark.app, including the website, mobile-optimised platform, and any associated applications or promotional pages. 92stark is the data controller responsible for the personal information of all registered players and visitors to the platform.

We know that privacy can feel like a dry subject, but for Pakistani players using an online gaming platform it matters a great deal. When you hand over your mobile number, your payment details, or any personal information, you're trusting us with something real. This policy is our commitment to be transparent about how that trust is honoured — what we do with your data, what we don't do, and what choices you have at every step.

This policy should be read alongside the 92stark Terms and Conditions and the Responsible Gaming page, both of which contain additional information relevant to your account and its management.

92stark collects personal data across several categories. The specific data collected depends on how you interact with the platform — a registered and verified account holder will have more data on file than someone who simply browses the website without logging in.

Identity & Contact Information

• Full legal name
• Date of birth
• Pakistani mobile number
• Email address (where provided)
• National Identity Card (CNIC) number and copy (for KYC verification)
• Residential address (for enhanced verification when required)

Financial Information

• Easypaisa, JazzCash, NayaPay, or SadaPay mobile wallet numbers
• Bank account details where IBFT is used
• Card details (card number and expiry are not stored by 92stark — these are handled directly by our PCI-compliant payment processor)
• Transaction history — all deposits, withdrawals, and bonuses associated with your account

Gameplay & Behavioural Data

• Betting history, game sessions, win/loss records
• Time and duration of platform sessions
• Games accessed, bet amounts, and markets wagered on
• Responsible gaming tool usage (deposit limits set, cooling-off periods activated)

Technical & Device Data

• IP address and approximate location derived from IP
• Device type, operating system, and browser version
• Unique device identifiers
• Platform interaction logs (pages visited, clicks, errors encountered)

92stark collects data through several channels, each of which is described below. We are transparent about collection methods because we believe Pakistani players have a right to know exactly how their information reaches us.

• Registration: When you create a 92stark account, you directly provide your name, mobile number, date of birth, and other requested details. This is the primary source of identity data.
• KYC verification: When 92stark requests identity verification, you provide copies of identity documents. This information is used solely for verification and fraud prevention purposes.
• Deposits and withdrawals: When you conduct a financial transaction, data about that transaction — including the payment method, amount, date, and outcome — is recorded as part of your account history.
• Platform usage: Your activity on the 92stark platform is logged automatically. This includes which games you play, how long you play, what bets you place, and how you navigate the interface.
• Cookies and tracking technologies: As described in section 9, cookies and similar technologies are used to maintain your session, remember your preferences, and analyse how the platform is used. See the dedicated cookies section for full details.
• Customer support interactions: When you contact the 92stark support team by live chat or email, the contents of that communication are retained as part of your account record.
• Third-party verification services: For enhanced identity verification, 92stark may use third-party KYC service providers. These providers verify your details against official records and report the outcome to 92stark.

Every piece of data that 92stark holds about you is used for a specific, defined purpose. We do not collect data speculatively or hold data that has no operational purpose. The table below summarises the primary uses of your personal data at 92stark:

92stark does not use your data to make automated decisions that have significant legal effects on you without human oversight. Fraud detection systems flag accounts for human review rather than taking automated enforcement action without staff involvement.

92stark processes personal data on the following legal bases, which are referenced in the table in section 4:

• Contract performance: Most data processing at 92stark is necessary to deliver the services you signed up for — managing your account, processing transactions, and resolving support requests. Without this processing, we cannot provide the platform.
• Legal obligation: Certain processing is required by law. This includes Know Your Customer (KYC) identity verification, anti-money laundering checks, and responsible gaming monitoring. We are legally obligated to carry out these checks and to retain records of them.
• Legitimate interests: Some processing is based on 92stark's legitimate interests as a business — fraud detection, platform security, and platform improvement analytics. In each case, we have assessed that these interests do not override your fundamental privacy rights.
• Consent: For marketing communications, 92stark relies on your consent. You can withdraw consent for marketing at any time without affecting the services you receive.

92stark does not sell your personal data to any third party, ever. Your data is not traded, rented, or provided to commercial data brokers. Full stop.

However, the operation of a gaming platform does require us to share certain data with specific categories of trusted service providers and regulatory bodies. Below is a transparent account of who receives your data and under what circumstances:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, bank transfer networks, and card payment processors receive transaction data necessary to complete your deposits and withdrawals. These providers operate under their own privacy policies and are bound by financial services regulations.
• Identity verification providers: Third-party KYC service providers receive the identity documents you submit for verification. They are contractually bound to use this data only for verification purposes and to maintain strict data security standards.
• Fraud prevention services: Fraud detection systems may cross-reference certain account data against known fraud databases. This is done to protect all players on the 92stark platform.
• Regulatory and legal authorities: Where required by applicable law or by a valid legal order, 92stark will disclose personal data to the relevant regulatory authority, law enforcement body, or court. 92stark will not disclose more data than is legally required in these circumstances.
• IT infrastructure and hosting providers: The technical infrastructure that runs the 92stark platform is operated by trusted hosting providers. These providers have access to data only to the extent necessary to maintain the infrastructure and are bound by strict data processing agreements.

92stark retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply:

• Active account data: Retained for the duration of the account's existence plus a period of five years after account closure, to meet anti-money laundering and gaming regulatory record-keeping requirements.
• Financial transaction records: Retained for a minimum of five years following the date of each transaction, as required under financial services regulations.
• KYC verification documents: Retained for five years following the closure of the associated account, unless a longer period is required by applicable law.
• Customer support communications: Retained for three years from the date of the communication, or longer where the communication relates to an unresolved dispute or legal matter.
• Marketing consent records: Retained until withdrawn plus one year, as evidence of consent history.
• Technical and behavioural logs: Aggregated analytics data is retained indefinitely but is anonymised. Individual session logs are retained for 12 months.

When data is no longer required for any applicable retention period, it is securely deleted or anonymised so that it can no longer be attributed to any individual.

92stark implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. The key measures in place include:

• Encryption in transit: All data transmitted between your device and 92stark is encrypted using TLS (Transport Layer Security), the same standard used by banking and financial institutions. The connection is secured with 256-bit SSL certificates.
• Encryption at rest: Sensitive personal and financial data stored in 92stark's databases is encrypted at rest, meaning it is protected even in the event of unauthorised database access.
• Access controls: Internal access to personal data is restricted on a need-to-know basis. Staff who do not require access to personal data as part of their role do not have it. Access is logged and regularly audited.
• Password security: Account passwords are stored using modern cryptographic hashing — plain-text passwords are never stored or accessible to any 92stark staff member.
• Two-factor authentication: 92stark supports two-factor authentication for player accounts and uses it internally for all staff access to production systems.
• Regular security testing: The 92stark platform undergoes regular security assessments to identify and remediate vulnerabilities before they can be exploited.
• Incident response: 92stark maintains a data breach response procedure. In the event of a breach that affects your personal data, you will be notified in accordance with applicable legal requirements.

92stark uses cookies and similar tracking technologies on its platform. A cookie is a small text file placed on your device when you visit a website. Cookies are used for the following purposes at 92stark:

• Essential cookies: Required for the platform to function. These maintain your login session so you stay logged in as you navigate between pages, and they store essential preferences. Essential cookies cannot be disabled without breaking core platform functionality.
• Analytics cookies: Used to understand how players interact with the 92stark platform in aggregate — which pages are most visited, where players encounter problems, and how the interface can be improved. Analytics data is anonymised and does not identify individual users.
• Preference cookies: Store your platform preferences, such as language settings or display choices, so they are remembered between sessions.
• Fraud prevention cookies: Used by fraud detection systems to maintain consistency between sessions and identify unusual patterns that may indicate fraudulent activity.

You can manage cookie settings through your browser. Most browsers allow you to block or delete cookies. Blocking essential cookies will affect your ability to use the 92stark platform — in particular, you will be unable to maintain a logged-in session.

As a player registered with 92stark, you have a number of rights in relation to your personal data. These rights are explained below, along with how to exercise them. All requests should be sent to support@92stark.app with the subject line including the relevant right (e.g., "Data Access Request").

92stark will respond to all privacy rights requests within 30 calendar days. Where a request is complex or high in volume, we may extend this by a further 30 days and will notify you of the extension. There is no charge for exercising your privacy rights.

92stark may send you promotional communications about bonuses, new games, PSL season offers, and other platform features. We do this only where you have given your consent during registration or at a later point.

You can opt out of marketing communications at any time by:

• Updating your communication preferences in your 92stark account settings.
• Clicking the unsubscribe link in any marketing email.
• Contacting support at support@92stark.app with the subject "Marketing Opt-Out".

Opting out of marketing does not affect transactional communications — you will still receive notifications about your account, deposits, withdrawals, and security alerts. These are part of the core platform service and cannot be disabled while your account is active.

92stark is strictly an adult platform. The services offered by 92stark are intended solely for individuals aged 18 years and above. We do not knowingly collect, store, or process personal data belonging to individuals under the age of 18.

During the registration process, 92stark requests date of birth information and will decline to complete registration for individuals who indicate they are under 18. Where age verification documents are requested, any account found to belong to a minor will be immediately closed, all balances forfeited, and the matter reported to the appropriate authorities where required by law.

If you believe that a person under the age of 18 has registered on 92stark — whether using their own details or someone else's — please contact us immediately at support@92stark.app.

The 92stark platform may contain links to third-party websites or services in certain contexts — for example, links to payment provider support pages or regulatory authority information pages. 92stark is not responsible for the privacy practices of any third-party site and this Privacy Policy does not extend to any website or service not operated by 92stark.

We encourage you to read the privacy policy of any third-party site before submitting personal information to it. If you access a payment provider's portal from within the 92stark platform, the data you submit to that portal is governed by the payment provider's own privacy policy.

92stark reviews and updates this Privacy Policy periodically to reflect changes in the platform, applicable law, or our data processing practices. When changes are made, the updated policy will be published at 92stark.app/privacy-policy with a revised "Last Updated" date.

For material changes that significantly affect how your data is used or your rights in relation to it, 92stark will provide advance notice through in-platform notifications or by email to your registered address at least 14 days before the changes take effect.

Your continued use of the 92stark platform after a policy update constitutes your acknowledgement of the revised policy. If you disagree with any update, you should close your account before the update takes effect and contact support to arrange return of any remaining balance.

For any questions about this Privacy Policy, how 92stark handles your personal data, or to exercise any of your privacy rights, please contact us through the following channels. All privacy-related requests are handled by a dedicated member of the 92stark team.

• Email: support@92stark.app
• Subject line for privacy requests: "Privacy Request — [Type]" (e.g., "Privacy Request — Data Access")
• Live Chat: Available 24/7 through the 92stark platform
• Language: Privacy requests are handled in both English and Urdu
• Response time: Privacy requests acknowledged within 48 hours; substantive response within 30 days

If you are not satisfied with our response to a privacy concern, you have the right to escalate the matter to the relevant data protection authority in the jurisdiction that governs 92stark's operations. Contact us for details of the applicable supervisory authority.