ch999 Privacy Policy

01 About This Policy

This Privacy Policy applies to all personal data collected, processed, and stored by ch999 in connection with your use of the ch999 Platform at ch999.lat, including all associated mobile-optimised web interfaces, account management tools, gaming services, and customer support channels.

By registering a ch999 Account or continuing to use the ch999 Platform after this Policy has been made available to you, you acknowledge that you have read, understood, and agree to the collection and use of your personal data as described herein. If you do not agree with any part of this Privacy Policy, you should discontinue your use of the ch999 Platform immediately.

This Policy should be read together with the ch999 Terms & Conditions and the ch999 Responsible Gaming Policy, both of which contain additional provisions relevant to how your account data is managed.

02 Data Controller

For the purposes of applicable data protection law, ch999 — operating the Platform at ch999.lat — acts as the data controller in respect of all personal data collected from Members and Platform visitors. As data controller, ch999 determines the purposes for which, and the manner in which, your personal data is processed.

ch999 may engage third-party service providers to process personal data on our behalf in their capacity as data processors. Such processors are contractually bound to process data only on ch999's instructions and to apply appropriate security measures. A summary of the categories of third-party processors ch999 engages is set out in Section 7 of this Policy.

All data protection queries, subject access requests, and data correction or deletion requests should be directed to the ch999 data team via the contact details set out in Section 16.

03 Personal Data We Collect

ch999 collects the following categories of personal data, depending on how you interact with the Platform:

ch999 does not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, or health data, except where health-related information is voluntarily provided in the context of a responsible gaming request or self-exclusion application.

04 How We Collect Your Data

ch999 collects personal data through the following channels and mechanisms:

• Direct submission: Data you provide when completing the ch999 registration form, submitting KYC documentation, making deposits or withdrawal requests, completing responsible gaming forms, or contacting ch999 support.
• Automated technical collection: Data collected automatically when you visit or interact with the ch999 Platform, including IP address, device identifiers, browser type, session length, and page interaction data, collected via server logs and cookies.
• Payment provider data: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card payment processors, including transaction reference numbers, amounts, timestamps, and payment method identifiers, for the purpose of crediting and reconciling your PKR Wallet.
• Identity verification services: Where ch999 engages third-party KYC or identity verification providers, those providers may return verification status data and document authenticity assessments to ch999 as part of the verification process.
• Fraud prevention and AML screening: ch999 may receive flagging data from third-party fraud prevention and anti-money laundering screening services, which ch999 uses to assess account risk and comply with applicable regulatory obligations.
• Responsible gaming monitoring: ch999's platform systems automatically record gaming activity data — including session frequency, deposit velocity, and loss patterns — for the purpose of responsible gaming monitoring and early intervention where indicators of potential harm are detected.

05 Why We Use Your Personal Data

ch999 processes your personal data for the following specific purposes:

• Account administration: To create, manage, verify, and maintain your ch999 Account, including processing deposits and withdrawals, updating account preferences, and handling account-related communications.
• Identity verification (KYC): To verify your identity, age, and payment method ownership in accordance with our regulatory obligations, and to prevent the use of the Platform by ineligible individuals, including persons under 21 years of age.
• Anti-money laundering (AML) compliance: To monitor transactions for suspicious activity, screen Members against applicable sanctions lists, and fulfil our regulatory reporting obligations in connection with the operation of our gaming licence.
• Gaming service delivery: To operate and deliver the gaming and betting services you request, process your bets, calculate and credit winnings, apply bonus terms, and maintain accurate records of your gaming history.
• Responsible gaming: To monitor your gaming patterns for indicators of potential harm, apply responsible gaming tools and limits you have requested, and — where ch999 determines intervention is necessary — proactively restrict or limit gaming activity in your interest.
• Fraud prevention and security: To detect and prevent fraudulent account activity, multi-accounting, bonus abuse, collusion, and other prohibited conduct described in the ch999 Terms & Conditions.
• Customer support: To respond to your queries, complaints, and requests in a timely and effective manner, and to maintain records of support interactions for quality assurance and dispute resolution purposes.
• Platform improvement: To analyse aggregate usage patterns and technical performance data for the purpose of improving the ch999 Platform's functionality, reliability, and user experience.
• Marketing communications: Where you have provided your consent, to send you promotional communications about ch999 bonuses, new games, and platform features via email or SMS. You may withdraw marketing consent at any time — see Section 13.

06 Legal Basis for Processing

ch999 relies on the following legal bases to process your personal data, depending on the specific processing purpose:

• Contractual necessity: Processing required to perform the contract between you and ch999 — i.e., your ch999 Account and the Terms & Conditions governing it — including account creation, deposits, withdrawals, gaming service delivery, and KYC verification.
• Legal obligation: Processing required to comply with applicable laws and regulatory requirements, including AML obligations, regulatory reporting requirements, responsible gaming obligations imposed by our gaming licence, and responses to lawful requests from competent authorities.
• Legitimate interests: Processing carried out for ch999's legitimate business interests where those interests are not overridden by your data protection rights, including fraud prevention, platform security, responsible gaming monitoring beyond minimum regulatory requirements, and general platform improvement analytics.
• Consent: Processing of personal data for direct marketing communications, where ch999 has obtained your explicit prior consent. You may withdraw this consent at any time by updating your communication preferences in your Account settings or by contacting ch999 support.

07 Data Sharing & Third-Party Disclosure

ch999 does not sell, rent, or trade your personal data to third parties. We share personal data only in the following circumstances and with the following categories of recipients:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card payment processors receive transaction-related data necessary to process your deposits and withdrawals. These providers process data in accordance with their own privacy policies and applicable financial regulations.
• Identity verification and KYC providers: Third-party identity verification services that assist ch999 in confirming the authenticity of KYC documents submitted by Members. These providers act as data processors on ch999's behalf and are contractually prohibited from using your data for any purpose beyond the verification service.
• Fraud prevention and AML screening services: Third-party risk and compliance service providers that assist ch999 in detecting fraudulent activity and meeting AML obligations. Data shared with these providers is limited to what is strictly necessary for screening purposes.
• Game software providers: Third-party gaming software providers whose games are made available through the ch999 Platform may receive anonymised session data for the purpose of game performance monitoring and fair play verification. ch999 does not share identifiable Member data with game providers beyond what is strictly necessary for game delivery.
• Regulatory authorities and law enforcement: ch999 will disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by law, court order, or binding regulatory direction. ch999 will, where legally permissible, notify affected Members of such disclosures.
• Professional advisers: Legal, audit, and compliance advisers engaged by ch999 in connection with the operation of the Platform, subject to confidentiality obligations.

08 Data Retention

ch999 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following retention periods apply as a general guide:

• Active Account data: Personal data associated with an active ch999 Account is retained for the duration of your membership and for a minimum period of five (5) years following the closure or termination of your Account, in accordance with our AML and regulatory reporting obligations.
• KYC documents: Identity verification documents are retained for a minimum of five (5) years from the date of submission, or five (5) years from the closure of your Account, whichever is later, in accordance with applicable AML regulatory requirements.
• Transaction records: All deposit, withdrawal, and gaming transaction records are retained for a minimum of five (5) years following the date of the transaction for regulatory compliance and dispute resolution purposes.
• Support communications: Customer support correspondence is retained for a minimum of three (3) years from the date of the interaction for quality assurance and dispute resolution purposes.
• Marketing consent records: Records of your marketing communication consent or withdrawal thereof are retained for the duration of your membership and for three (3) years following membership closure, as evidence of compliance with consent obligations.
• Technical and log data: Server logs and technical access data are retained for up to twelve (12) months for security monitoring, fraud investigation, and platform performance analysis purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with ch999's internal data disposal procedures.

09 Cookies & Tracking Technologies

ch999 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: Session cookies required to maintain your logged-in state, protect against cross-site request forgery, and enable core Platform functionality. These cookies cannot be disabled without breaking Platform functionality.
• Performance and analytics cookies: Cookies used to collect anonymised data about how Members use the ch999 Platform — such as which pages are visited most frequently, session duration, and navigation paths — for the purpose of improving Platform performance and user experience.
• Preference cookies: Cookies that remember your language preference, responsible gaming tool settings, and other personalisation choices, so you do not need to re-configure them each time you visit the Platform.
• Security cookies: Cookies used to detect and prevent fraudulent activity, bot access, and account takeover attempts, including device fingerprinting tokens used to flag suspicious login patterns.

ch999 does not use third-party advertising or behavioural targeting cookies. You can manage non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the ch999 Platform.

10 Data Security

ch999 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ch999 servers.
• Encryption of sensitive data at rest, including KYC documents, financial data, and authentication credentials.
• Role-based access controls limiting access to personal data to ch999 personnel and authorised processors who have a genuine operational need for that access.
• Multi-factor authentication requirements for all ch999 internal system access.
• Regular security assessments, vulnerability scanning, and penetration testing of the ch999 Platform infrastructure.
• Incident response procedures for detecting, containing, and reporting data security incidents in a timely manner.

While ch999 applies rigorous security standards, no digital platform can guarantee absolute security against all possible threats. You are responsible for maintaining the security of your own Account login credentials and for notifying ch999 promptly if you suspect unauthorised access to your Account.

11 Your Data Rights

Subject to applicable law and our regulatory obligations, you have the following rights in respect of your personal data held by ch999:

• Right of access: You may request a copy of the personal data ch999 holds about you, together with information about how it is used. ch999 will provide this information within 30 days of receiving a verified request.
• Right to rectification: You may request that ch999 correct any inaccurate or incomplete personal data held about you. Where data can be corrected through your Account settings directly, you are encouraged to do so without the need to submit a formal request.
• Right to erasure: In certain circumstances, you may request that ch999 delete your personal data. This right is subject to important limitations: ch999 is legally required to retain certain data for AML, regulatory reporting, and dispute resolution purposes even after your Account is closed, and erasure requests cannot override those obligations.
• Right to restriction: You may request that ch999 restrict the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or have objected to processing pending the outcome of that objection.
• Right to object: You may object to ch999's processing of your personal data where that processing is based on legitimate interests. ch999 will consider your objection and cease processing unless ch999 can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where ch999 processes your data based on your consent (for example, for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, please contact the ch999 data team using the contact details in Section 16. ch999 may require you to verify your identity before processing a data rights request, to ensure that personal data is not disclosed to or amended by an unauthorised person.

12 Children & Minors

ch999 is strictly an adult platform. The ch999 Platform is not directed at, and must not be used by, any person under the age of 21 years. ch999 does not knowingly collect personal data from persons under 21 years of age.

ch999 applies age verification measures at the point of registration and through the KYC process to confirm that all Members meet the minimum age requirement. Where ch999 discovers or reasonably suspects that personal data has been collected from a person under 21 years of age, ch999 will immediately suspend the relevant Account, void any gaming activity conducted on that Account, and securely delete the personal data of the underage individual in accordance with applicable law.

If you are a parent or guardian and believe that a minor in your care has registered or attempted to register on the ch999 Platform, please contact the ch999 support team immediately so that we can investigate and take appropriate action.

13 Marketing Communications

ch999 may send you promotional and marketing communications — including bonus offers, new game announcements, and platform updates — via email and SMS, but only where you have given your explicit prior consent to receive such communications.

You may withdraw your marketing consent and opt out of promotional communications at any time by:

• Updating your communication preferences in the ch999 Account settings panel.
• Clicking the "unsubscribe" link included in any ch999 marketing email.
• Contacting ch999 support and requesting removal from all marketing lists.

Withdrawal of marketing consent will not affect the delivery of transactional communications that are necessary for the operation of your ch999 Account, such as deposit confirmations, withdrawal notifications, security alerts, KYC requests, and responsible gaming communications. These service communications will continue to be sent regardless of your marketing preference settings.

ch999 does not share your contact details with third-party marketers for the purpose of sending you unsolicited communications.

14 Third-Party Platform Links

The ch999 Platform may contain references to third-party game providers and payment service providers in the course of delivering gaming services and processing transactions. Where interaction with a third-party platform or service is involved, please note that:

• ch999 is not responsible for the data practices of third-party platforms or services that are not operated by ch999.
• Third-party payment providers — including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank — process payment data in accordance with their own privacy policies and applicable financial sector regulations. ch999 encourages you to review those policies.
• Third-party game software providers who supply games available on the ch999 Platform operate their own software platforms and may process limited technical data in connection with game delivery. ch999 contractually restricts the data that game providers may collect through ch999-hosted games.

ch999 is not responsible for the privacy practices of any third-party service provider beyond the contractual data processing obligations ch999 imposes on those providers as described in Section 7 of this Policy.

15 Changes to This Privacy Policy

ch999 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or Platform functionality.

When material changes are made to this Privacy Policy, ch999 will notify registered Members via email or in-Platform notification prior to the changes taking effect, where reasonably practicable. The "Last Updated" date at the top of this page will be updated to reflect the date of the most recent revision.

Your continued use of the ch999 Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must discontinue your use of the Platform and may request account closure in accordance with the ch999 Terms & Conditions.

ch999 recommends that you review this Privacy Policy periodically to stay informed about how we handle your personal data.

16 Contact & Data Requests

For all data protection queries, subject access requests, data correction or deletion requests, marketing opt-out requests, or privacy-related complaints, please contact the ch999 data team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Subject line: Please include "Privacy Request" or "Data Rights Request" in the subject line of your email to ensure your query is routed to the correct team.
• Live Chat: Available 24/7 on the ch999 Platform — avg. response time 3–5 minutes
• Response time: ch999 will acknowledge all data rights requests within 5 business days and provide a substantive response within 30 days of receipt.

When submitting a data rights request, please include your registered Account username and your registered mobile number (last four digits only) to enable the ch999 data team to locate your Account and process your request efficiently. ch999 may ask for additional identity verification before processing requests that involve the disclosure or deletion of personal data.