sm99 game
Privacy Policy

This Privacy Policy ("Policy") describes how sm99 game ("we", "us", "our", "sm99 game", "Platform") collects, processes, stores, and protects the personal data of individuals ("you", "Player", "User") who access or use the sm99 game website at sm99game.com and all associated services, including the casino lobby, sports betting, payment services, account management, and customer support functions.

sm99 game is committed to protecting the privacy of all Pakistan players who use our platform. We process personal data in a lawful, fair, and transparent manner, and only for the specific purposes described in this Policy. This document is designed to help you understand exactly what we do with your information and what choices you have.

If you have questions about this Policy or your personal data at sm99 game, please contact our support team via 24/7 English live chat from your account dashboard. Our email for privacy-related enquiries is [email protected] (displayed as plain text — not a clickable link).

sm99 game collects personal data in several ways: directly from you when you register or interact with the platform, automatically as you use our services, and from third-party verification services where required for compliance purposes.

2.1 Registration Data

When you create an sm99 game account, we collect:

• Your Pakistan mobile number (used as your primary account identifier and for SMS communications);
• A username of your choosing (if different from your mobile number);
• Your date of birth (for age verification — you must be 18+);
• Your account currency selection (Pakistani Rupees — PKR).

2.2 Identity Verification (KYC) Data

Where required by our Know Your Customer (KYC) or Anti-Money Laundering (AML) obligations, we may collect:

• Full legal name as it appears on your CNIC (Computerised National Identity Card);
• CNIC number and a scanned or photographed copy of your CNIC;
• Proof of Pakistan residential address (utility bill, bank statement);
• Source of funds documentation (bank statement, employer letter, or equivalent).

2.3 Financial Transaction Data

To process your PKR deposits and withdrawals, we collect and retain:

• Easypaisa and/or JazzCash wallet numbers associated with your account;
• Pakistan bank account details (account number, IBAN, bank name — e.g., HBL, UBL, MCB) where bank transfer is used;
• USDT TRC20 wallet address (where cryptocurrency deposits are used);
• All transaction records: amounts in PKR, timestamps, transaction IDs, and payment method used.

2.4 Gaming Activity Data

We automatically record all gaming activity on your sm99 game account, including:

• Game sessions, bets placed, game outcomes, and PKR amounts wagered and won;
• Sports betting selections (Cockfighting, Horse Racing, cricket events);
• Bonus usage, wagering progress, and promotion participation records;
• Session duration, session start/end times, and responsible gaming tool usage.

2.5 Technical & Device Data

When you access sm99 game, we automatically collect:

• IP address and approximate geographic location (to verify Pakistan access and detect fraud);
• Device type, operating system, and browser type/version;
• Cookies and similar tracking technologies (see Section 6);
• Login timestamps, session activity logs, and access records.

2.6 Data Collection Summary

sm99 game uses personal data for the following specific and documented purposes:

• Account administration: Creating and managing your sm99 game account, processing your sm99 game Login sessions, maintaining your PKR wallet, and responding to your support requests.
• Payment processing: Processing PKR deposits from and withdrawals to your Easypaisa wallet, JazzCash account, Raast ID, or Pakistan bank account.
• Identity verification and KYC: Verifying your age (18+ requirement), confirming your identity before large withdrawals, and complying with anti-money-laundering regulations.
• Fraud prevention and security: Detecting and preventing unauthorised account access, fraudulent transactions, duplicate account creation, and other suspicious activity patterns.
• Responsible gaming monitoring: Identifying patterns of play that may indicate problem gambling and proactively engaging with affected Pakistan players, in line with our Responsible Gaming policy.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the sm99 game platform experience for Pakistan players.
• Legal and regulatory compliance: Maintaining records required under applicable AML, financial services, and anti-fraud legislation for the minimum retention periods prescribed by law.
• Marketing communications (where consent given): Sending promotional offers, bonus notifications, and platform updates to Pakistan players who have opted in to marketing communications from sm99 game.

sm99 game processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to perform our contract with you — including account registration, payment processing, game access, and customer support — is undertaken because it is necessary to provide the sm99 game service you have requested. Without this processing, sm99 game could not function as a platform for you.
• Legal obligation: KYC verification, AML transaction monitoring, financial record-keeping, and fraud reporting are undertaken because sm99 game is legally required to perform these activities under applicable regulations.
• Legitimate interests: Fraud detection, security monitoring, platform analytics (using anonymised data), and responsible gaming interventions are undertaken on the basis of sm99 game's legitimate interests in operating a safe, secure, and compliant platform for Pakistan players.
• Consent: Marketing communications (promotional emails, SMS bonus notifications) are only sent where you have expressly consented. You may withdraw marketing consent at any time from your sm99 game account settings or by contacting support.

sm99 game shares personal data with third parties only where necessary and only under appropriate data protection safeguards. We do not sell or rent your personal data. The categories of third parties with whom we share data are:

5.1 Payment Processors

To process your PKR deposits and withdrawals, sm99 game shares the minimum necessary payment data with: Easypaisa (Telenor Microfinance Bank), JazzCash (Mobilink Microfinance Bank), Raast (State Bank of Pakistan instant payment), and participating commercial banks (HBL, UBL, MCB Bank). These processors receive only the transaction data necessary to execute the specific payment instruction.

5.2 Game Technology Providers

To deliver certified fair games to Pakistan players, sm99 game's platform connects to servers operated by licensed game studios — including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, and Play'n GO. These providers may receive your player ID and session data for the purpose of game delivery, fairness certification, and dispute resolution. They do not receive your CNIC, full name, or payment method details.

5.3 KYC and AML Verification Services

To meet our identity verification and anti-money-laundering obligations, sm99 game may use certified third-party KYC verification service providers. These services receive identity documents (CNIC copies) solely for the purpose of identity confirmation and fraud screening.

5.4 Legal and Regulatory Authorities

sm99 game will disclose personal data to law enforcement agencies, regulatory authorities, or courts where required to do so by applicable law, valid legal process (such as a court order), or where disclosure is necessary to protect the safety of Pakistan players or the public.

sm99 game uses cookies and similar tracking technologies on our website to ensure the platform functions correctly, to maintain your login session, and to understand how Pakistan players use the site so we can improve it.

6.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the sm99 game platform to function — including maintaining your login session, remembering your PKR wallet state, and enabling the checkout flow for deposits. These cookies cannot be disabled without preventing the platform from working correctly.
• Functional Cookies: Remember your preferences — such as language (English), display settings, and recently visited game categories — to personalise your sm99 game experience on subsequent visits.
• Analytical Cookies: Collect anonymised data about how Pakistan players navigate the sm99 game platform — which game categories are most visited, how long sessions last, and where players encounter difficulties. This data is used only to improve the platform and is never shared with advertising networks.
• Security Cookies: Support fraud detection by helping sm99 game identify unusual session patterns that may indicate unauthorised account access or automated bot activity.

6.2 Managing Cookies

You can manage cookie preferences through your browser settings on your Pakistan mobile or desktop device. Disabling strictly necessary cookies will impair or prevent access to the sm99 game platform. Disabling analytical cookies will not affect your ability to use sm99 game but will mean we receive less information to improve the platform. Most modern browsers — Chrome on Android, Safari on iOS, Firefox — provide granular cookie controls in their settings menus.

sm99 game implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your Pakistan device (mobile, tablet, desktop) and sm99 game servers is encrypted using 256-bit SSL/TLS — the same encryption standard used by Pakistan's major banks for internet banking. Your personal data is never transmitted in plain text.
• Access Controls: Access to personal data within sm99 game's systems is restricted to employees and service providers who have a legitimate business need to access that data. Access rights are role-based, regularly reviewed, and immediately revoked when no longer required.
• Data Encryption at Rest: Sensitive personal data — including CNIC details and financial account numbers — is encrypted when stored on sm99 game's servers.
• Two-Factor Authentication: sm99 game supports and encourages two-factor authentication (2FA) for all Pakistan player accounts. When 2FA is enabled, your sm99 game Login requires both your password and a one-time code sent to your registered Pakistan mobile number.
• Penetration Testing: sm99 game's technical infrastructure undergoes regular security assessments and penetration testing by qualified cybersecurity professionals.
• Staff Training: All sm99 game staff who handle personal data receive regular data protection training and are bound by confidentiality obligations.

sm99 game retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, having regard to our legal and regulatory obligations. The following retention periods apply:

• Active account data: Retained for the lifetime of your sm99 game account plus 5 years following account closure or last transaction, to meet AML and financial record-keeping requirements.
• KYC documentation (CNIC copies, proof of address): Retained for a minimum of 5 years from the date of verification or account closure, whichever is later, in accordance with financial compliance obligations.
• Transaction records (PKR deposits, withdrawals, bets): Retained for a minimum of 5 years from the date of each transaction.
• Support communications and live chat logs: Retained for 3 years from the date of the communication, for quality assurance, dispute resolution, and compliance purposes.
• Technical and device data (IP logs, session logs): Retained for 12 months from the date of collection.
• Marketing consent records: Retained for the duration of your active marketing consent and for 3 years thereafter, for compliance documentation purposes.

After the applicable retention period expires, personal data is securely deleted or anonymised so that it can no longer be associated with any individual Pakistan player.

As a Pakistan player with a registered sm99 game account, you have the following rights in relation to your personal data held by sm99 game:

• Right of Access: You may request a copy of the personal data sm99 game holds about you. We will provide this within 30 days of your verified request.
• Right of Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You can update most account information directly from your sm99 game account settings, or contact support for data held in compliance records.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where sm99 game no longer has a lawful basis to retain it. Note that some data — particularly KYC and transaction records — must be retained for the minimum periods specified in Section 8 regardless of erasure requests, due to our legal obligations.
• Right to Restrict Processing: You may ask sm99 game to restrict the processing of your personal data in specific circumstances — for example, while a dispute about data accuracy is being resolved.
• Right to Data Portability: You may request your personal data in a structured, machine-readable format for transfer to another service provider where this is technically feasible.
• Right to Object: You may object to sm99 game processing your personal data on the basis of legitimate interests, or to processing for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

sm99 game may send marketing communications — including bonus notifications, promotional offers, new game announcements, and seasonal promotions (such as HBL Pakistan Super League cricket bonus campaigns) — to Pakistan players who have consented to receive such communications.

Marketing communications from sm99 game are sent via SMS to your registered Pakistan mobile number and/or displayed as notifications within your logged-in sm99 game account session. We do not send unsolicited marketing emails or third-party sponsored promotional messages.

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

• Visiting the Communication Preferences section of your sm99 game account settings and deselecting marketing communications;
• Contacting the sm99 game support team via live chat and requesting to be removed from marketing communications;
• Following the opt-out instructions included in any SMS marketing message from sm99 game.

Opting out of marketing communications will not affect your ability to use the sm99 game platform or receive transactional messages related to your account — such as deposit confirmations, withdrawal notifications, and security alerts, which are sent regardless of marketing preferences.

If you believe that a person under 18 has registered an sm99 game account using false information, please report this immediately to our 24/7 English support team via live chat. sm99 game takes underage gambling extremely seriously and will act promptly on any credible report of a minor accessing the platform.

sm99 game may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made — changes that significantly affect how we collect or use your personal data — sm99 game will:

• Post the updated Privacy Policy at sm99game.com/privacy-policy with a clearly updated effective date;
• Notify registered Pakistan players of material changes via SMS to their registered mobile number at least 14 days before the changes take effect;
• Display a prominent notification within the sm99 game platform for Pakistan players who log in during the notice period.

Minor, non-material updates — such as clarifications of existing practices or corrections of typographical errors — may be made without advance notice but will always be reflected in the version of the Policy at sm99game.com/privacy-policy. We recommend Pakistan players review this Policy periodically to stay informed.

Your continued use of the sm99 game platform after any Privacy Policy update takes effect constitutes your acknowledgement of the updated Policy. If you do not agree with any updated terms, please contact our support team to discuss your account options.

For all privacy-related enquiries, data rights requests, or concerns about how sm99 game handles your personal data, please contact us through the following channels:

• Live Chat (fastest): Available 24/7 in English directly from your sm99 game account dashboard. Select "Privacy / Data Request" as the subject when initiating the chat.
• Email (plain text — not a clickable link): [email protected] — use subject line "Privacy Policy Enquiry" for fastest routing. Responses within 48 hours for privacy matters.

All privacy and data-related communications with sm99 game are logged and handled with strict confidentiality. sm99 game will verify your identity before discussing the specifics of any personal data held on your account.