Privacy Policy — How 9kwin Handles Your Data

This Privacy Policy ("Policy") is issued by 9kwin ("we", "us", "our", "the Operator") and governs how we collect, use, store, disclose and protect the personal data of individuals ("User", "you", "your") who access or use the 9kwin website, mobile interface, applications and associated services (collectively, the "Platform").

We are committed to handling your personal data responsibly, in accordance with applicable data protection law and in a manner consistent with your reasonable expectations as a user of our Platform. This Policy is designed to be clear and readable — not buried in impenetrable legal language — while still meeting the formal obligations of a data protection notice.

By accessing the Platform, creating an account or continuing to use our services after this Policy has been published or updated, you confirm that you have read and understood its contents and that you consent to the data practices described herein to the extent such consent is required under applicable law.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

The Data Controller responsible for your personal data is 9kwin, operating the Platform at https://9kwin.cam. The Operator is responsible for determining the purposes for which personal data is collected and the manner in which it is processed.

Where the Operator engages third-party Data Processors — such as identity verification services, payment processing partners, fraud detection providers and analytics platforms — those processors act under written data processing agreements and are contractually prohibited from using your data for any purpose beyond what we have instructed.

9kwin collects the following categories of personal data, depending on how you interact with the Platform:

4.1 Identity & Registration Data

• Full legal name, date of birth and gender (where applicable);
• Residential address, city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar) and country;
• Email address and mobile phone number;
• Government-issued identity document details (CNIC, passport) and associated images submitted during KYC verification.

4.2 Financial Data

• Payment method details used for deposits (e.g., bank account reference, mobile wallet identifiers — note: we do not store full card numbers or bank passwords);
• Transaction history including deposits, withdrawals, and bonus activity;
• Currency denomination (PKR where applicable).

4.3 Gaming & Behavioural Data

• Betting and gameplay history across sports, live casino and slot categories;
• Game preferences, session durations and activity timestamps;
• Responsible gambling tool usage (deposit limits set, self-exclusion requests, session time alerts).

4.4 Technical & Device Data

• IP address, browser type and version, device model and operating system;
• Geolocation data (country/city level, derived from IP address);
• Session tokens, login timestamps and access logs;
• Cookies and similar tracking data (see Section 13).

4.5 Communications Data

• Records of correspondence with our support team via Live Chat, email or the Help Center;
• Complaints, dispute records and responsible gambling correspondence;
• Marketing preferences (where opt-in consent has been provided).

We collect personal data through the following means:

• Directly from you — when you register an account, submit KYC documents, make a deposit, contact support, or use responsible gambling tools;
• Automatically — through cookies, session logs and analytics tools when you browse or interact with the Platform;
• From third parties — including identity verification providers (for KYC), payment processors (for transaction confirmation), fraud detection services, and where required, publicly available registries or credit reference agencies;
• From responsible gambling databases — where a User has registered on a self-exclusion scheme and that information is accessible to the Operator in compliance with applicable regulatory requirements.

Under applicable data protection law, the Operator relies on the following lawful bases for processing personal data:

9kwin processes your personal data for the following specific purposes:

• Account Creation & Management — to register, maintain and administer your account;
• Identity & Age Verification (KYC) — to confirm you meet the 18+ minimum age requirement and to verify your identity for fraud and AML compliance purposes;
• Payment Processing — to facilitate deposits, process withdrawal requests and maintain accurate transaction records in PKR where applicable;
• Game Delivery — to deliver the gaming and sports betting services you access, including live casino streams and sports odds feeds;
• Responsible Gambling — to monitor gameplay patterns for problem gambling indicators, process deposit/loss/time limits and handle self-exclusion requests;
• Customer Support — to respond to enquiries, resolve disputes and provide account assistance in English and Urdu;
• Fraud Prevention & Security — to detect, investigate and prevent fraudulent transactions, bonus abuse, collusion and money laundering;
• Legal Compliance — to meet obligations under applicable law, regulations and licence conditions, including the retention of records for audit purposes;
• Platform Improvement — to analyse usage data and improve the performance, usability and security of the Platform;
• Marketing (consent-based only) — to send promotional offers, bonus notifications and product updates where you have opted in to receive such communications.

9kwin does not sell, rent or trade your personal data. We share personal data with third parties only in the following circumstances, and only to the extent necessary:

• KYC & Identity Verification Providers — third-party services that verify your identity and age documents. These providers operate under strict data processing agreements;
• Payment Service Providers — processors who handle deposit and withdrawal transactions. Payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah represent familiar Pakistani channels; any data shared with such processors is governed by their own privacy policies and data practices, not this Policy;
• Fraud Detection & AML Services — specialist providers that screen transactions for suspicious patterns, sanctions list matches and money laundering indicators;
• Game & Platform Technology Providers — software suppliers who deliver game content and platform infrastructure. These providers may receive limited technical data necessary for game delivery;
• Responsible Gambling Databases — where required by applicable regulation, information about self-excluded users may be shared with or verified against relevant responsible gambling registries;
• Regulatory & Law Enforcement Authorities — where we are required to do so by applicable law, a court order, a regulatory authority or a legitimate law enforcement request;
• Group Companies & Successors — in the event of a merger, acquisition or restructuring, personal data may be transferred to a successor entity, subject to the same data protection commitments.

9kwin operates internationally and some of the third parties with whom we share data (see Section 8) may be located in countries outside your country of residence. Where personal data is transferred to jurisdictions that may not provide equivalent levels of data protection to those applicable in the Operator's licensing jurisdiction, we implement appropriate safeguards, which may include:

• Standard Contractual Clauses (SCCs) or equivalent contractual mechanisms;
• Adequacy decisions or equivalent data transfer frameworks applicable in the relevant jurisdictions;
• Binding corporate rules where applicable within a group structure.

By using the Platform and submitting your personal data, you acknowledge that your data may be transferred to and processed in countries outside Pakistan. The Operator will take reasonable steps to ensure any such transfer is conducted lawfully and securely.

We retain personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law or regulation. The following general principles apply:

When retention periods expire, data is securely deleted or irreversibly anonymised so that it can no longer be attributed to an identifiable individual.

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

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encrypted storage for sensitive data fields including identity document images and financial records;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Multi-factor authentication options for User accounts;
• Monitoring systems to detect and respond to unusual access patterns or suspected data breaches.

In the event of a personal data breach that poses a risk to your rights and freedoms, the Operator will notify affected users and the relevant supervisory authority in accordance with applicable data protection law, within the required timeframes.

Subject to applicable data protection law and the Operator's legal obligations, you have the following rights in relation to your personal data held by 9kwin:

9kwin uses cookies and similar technologies (including local storage and session tokens) on the Platform. These help us deliver a functional and personalised experience and allow us to understand how the Platform is being used.

You can manage or delete cookies through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in and using core Platform features. For guidance on managing cookies, refer to your browser's help documentation.

The 9kwin Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the Operator's licence jurisdiction. We do not knowingly collect personal data from individuals under the age of 18.

If the Operator discovers that personal data has been submitted by a minor, that data will be deleted promptly and the associated account will be closed. Age verification (KYC) processes are in place precisely to prevent minors from accessing the Platform.

9kwin serves Pakistani users through an English-language platform and collects data from users located in Pakistan in the same manner as described throughout this Policy. The following additional points are relevant for Pakistani users:

• This Privacy Policy is governed by the laws of the Operator's registered licensing jurisdiction, not by the laws of Pakistan. Pakistani data protection legislation, to the extent applicable, is respected on a best-efforts basis where it does not conflict with the governing law of this Policy;
• References to familiar Pakistani payment methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are for user familiarity only. Any personal or financial data processed in connection with such payment channels is handled by the respective payment provider's own systems, subject to their own privacy policies. 9kwin is not responsible for the data practices of any third-party payment provider;
• Pakistani users who submit CNIC or passport documents for KYC purposes should note that these documents are processed through the Operator's secure verification portal and are not transmitted through unsecured channels. Document images are stored in encrypted form and are accessible only to authorised KYC personnel;
• The Operator does not share Pakistani user data with any Pakistani government body, financial regulator or law enforcement authority unless compelled to do so by a lawful order from a competent authority with jurisdiction over the Operator.

9kwin reserves the right to update or replace this Privacy Policy at any time. Where changes are material — for example, where we introduce a new purpose for processing or a new category of data sharing — we will notify registered users via the Platform's notification system or by email to the address associated with your account, where practicable.

The revised Policy will be effective immediately upon publication on the Platform. The "Last Updated" date at the top of this page reflects the date of the most recent revision. Continued use of the Platform following any posted update constitutes acceptance of the revised Policy. If you do not agree with a change, you should cease using the Platform and contact support to request account closure.

It is your responsibility to review this Policy periodically to stay informed of how 9kwin handles your personal data.

If you have any questions, concerns or requests relating to this Privacy Policy or the manner in which 9kwin processes your personal data, please contact us through the following channels: