Privacy Policy — How se999 Handles Your Personal Data

Introduction

1.1 This Privacy Policy ("Policy") applies to all users of the se999 platform — including the website at se999.ws, any associated mobile interfaces, customer support channels, and promotional communications issued by se999.

1.2 By registering a se999 account or continuing to use the platform after this Policy has been published or updated, you acknowledge that you have read and understood how se999 collects and processes your personal data.

1.3 This Policy should be read alongside the se999 Terms & Conditions, which govern your use of the platform more broadly. Terms not otherwise defined here carry the same meaning as in the Terms & Conditions.

1.4 se999 is committed to handling all personal data with confidentiality, integrity, and care. The platform serves players predominantly in Pakistan — including users in Karachi, Lahore, Islamabad, Faisalabad, and other cities — and our data practices are designed with the practical realities of Pakistani digital financial services in mind.

Data Controller

2.1 For the purposes of this Policy, se999 is the data controller responsible for the personal data collected through the se999 platform.

2.2 All queries, requests, or complaints relating to your personal data under this Policy should be directed to the se999 Data Privacy team at: [email protected]. Please include "Privacy Request" in the subject line of your correspondence and your registered se999 username.

2.3 se999 has appointed a Data Privacy contact who oversees compliance with this Policy and handles data subject requests submitted by registered players. All requests are acknowledged within 5 business days and resolved within 30 days of receipt where technically and legally feasible.

Personal Data We Collect

3.1 se999 collects the following categories of personal data in the ordinary course of operating the platform:

3.2 se999 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or biometric data beyond what is strictly required for identity document verification as part of KYC procedures.

How We Collect Your Data

4.1 se999 collects personal data through the following channels:

• Direct submission: Information you provide when registering a se999 account, completing KYC verification, making deposits or withdrawals, or contacting customer support;
• Automated collection: Technical and usage data collected automatically when you access and interact with the se999 platform, including through cookies and server-side logging;
• Third-party verification partners: Identity and document verification data returned by KYC service providers engaged by se999 to confirm the authenticity of CNIC and other identity documents;
• Payment processors: Transaction confirmation and status data returned by JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Visa/Mastercard processing networks when you conduct deposits or withdrawals;
• Fraud prevention services: Risk signals and device fingerprinting data from anti-fraud tools used to protect the platform and its players.

4.2 se999 does not purchase personal data from data brokers or marketing list providers.

Purpose of Processing & Legal Basis

5.1 se999 processes your personal data only for specific, documented purposes. The following table sets out the primary purposes and the corresponding legal basis for each processing activity:

5.2 Where se999 relies on your consent as the legal basis for processing — in particular for marketing communications — you may withdraw that consent at any time by contacting support or using the unsubscribe link in any promotional email.

Data Sharing & Third Parties

6.1 se999 does not sell, rent, or trade your personal data to any third party for commercial purposes. Data is shared only in the specific circumstances set out below:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Visa/Mastercard networks receive the minimum personal and financial data necessary to process your deposit and withdrawal transactions;
• KYC and identity verification partners: Your identity documents and personal details are shared with authorised third-party KYC service providers solely for the purpose of verifying your identity and confirming you are aged 21 or above;
• Fraud prevention and security providers: Technical and behavioural data is shared with anti-fraud service providers to protect the platform against account takeovers, bonus abuse, and money laundering;
• Legal and regulatory authorities: se999 will disclose personal data to law enforcement agencies, regulatory bodies, or courts where required to do so by applicable law, court order, or other lawful demand;
• Professional advisers: se999 may share data with legal counsel, auditors, or accountants under professional confidentiality obligations where necessary for the operation of the business.

6.2 All third parties engaged by se999 to process personal data are required to handle that data in accordance with standards no less protective than those set out in this Policy. se999 maintains written data processing agreements with all material third-party processors.

Data Retention

7.1 se999 retains your personal data for as long as your account remains active and for a defined period after account closure, as set out below:

• Account and identity data: Retained for a minimum of 5 years following account closure, in line with anti-money-laundering record-keeping requirements;
• Transaction records: All PKR deposit and withdrawal records are retained for a minimum of 5 years from the date of the transaction;
• Responsible gaming records: Self-exclusion elections, deposit limit history, and cooling-off period records are retained for the duration of the exclusion and for at least 5 years thereafter, to prevent re-registration during active exclusion periods;
• Support communications: Customer support transcripts and email correspondence are retained for 3 years from the date of closure of the relevant support case;
• Technical and usage logs: Server-side access logs and device data are retained for up to 24 months for security and fraud investigation purposes.

7.2 After the applicable retention period has elapsed, personal data is securely deleted or anonymised in a manner that prevents re-identification.

Data Security

8.1 se999 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• TLS/SSL encryption for all data transmitted between your device and se999 servers;
• Encrypted storage of sensitive financial and identity data at rest;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of the se999 platform;
• Two-factor authentication (2FA) available to all players for account login security.

8.2 While se999 takes all reasonable precautions to secure your data, no online platform can guarantee absolute security. You are responsible for keeping your se999 login credentials — including your password and any 2FA codes — confidential. Do not share your password with anyone, including se999 support staff, who will never ask for it.

8.3 In the event of a data security incident that materially affects your personal data, se999 will notify affected players within a reasonable timeframe and take all necessary remedial steps.

Cookies & Tracking Technologies

9.1 se999 uses cookies and similar tracking technologies to operate and improve the platform experience. The following types of cookies are used:

• Essential cookies: Required for the platform to function — including session management, login state, and security tokens. These cannot be disabled without breaking platform functionality;
• Performance cookies: Collect anonymised data about how players interact with se999 — such as which pages are visited most and where errors occur — to help us improve the platform;
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and game lobby sorting options;
• Analytics cookies: Used to understand aggregate player behaviour on the platform. Data generated by analytics cookies is not linked to individual identities.

9.2 se999 does not use third-party advertising or retargeting cookies. No cookie data from the se999 platform is shared with advertising networks.

9.3 You may control cookie preferences through your browser settings. Please note that disabling essential cookies will affect your ability to log in and use the se999 platform normally.

Your Data Rights

10.1 As a se999 player, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Request" and your registered username:

• Right of access: You may request a copy of the personal data se999 holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data — for example, a misspelled name or an outdated contact number;
• Right to erasure: In certain circumstances you may request deletion of your personal data. Note that this right is subject to se999's legal obligation to retain records for anti-money-laundering and responsible gaming compliance purposes. Where a legal retention requirement applies, erasure requests may be declined or partially fulfilled;
• Right to restrict processing: You may request that se999 limits the way in which it uses your data while a dispute or review is in progress;
• Right to data portability: You may request a machine-readable copy of the personal data you provided to se999 directly;
• Right to withdraw consent: Where processing is based on consent — primarily for marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

10.2 se999 will not discriminate against you — for example by restricting account access or withholding bonuses — for exercising any of the rights described above.

Minors & Age Policy

11.1 se999 does not knowingly collect or process the personal data of individuals under the age of 21. The se999 platform is strictly intended for adults aged 21 and above.

11.2 Age verification is a mandatory step in the KYC process for all se999 accounts. Any account where the account holder is found to be under 21 years of age will be immediately closed and all personal data associated with that account will be handled in accordance with applicable legal requirements, which may include expedited deletion beyond standard retention periods.

11.3 If you are a parent or guardian and have reason to believe that a minor in your care has registered a se999 account, please contact our support team immediately at [email protected]. We will investigate and act promptly.

International Data Transfers

12.1 The se999 platform primarily serves Pakistani players and processes most data within systems serving the Pakistan region. However, some of our contracted third-party service providers — including KYC verification partners and cloud infrastructure providers — may process data in jurisdictions outside Pakistan.

12.2 Where personal data is transferred internationally, se999 ensures that appropriate safeguards are in place, including contractual protections requiring the receiving party to maintain data security and privacy standards equivalent to those described in this Policy.

12.3 se999 does not transfer personal data to countries where se999 has no reasonable basis to believe that adequate data protection standards exist, absent appropriate safeguard mechanisms.

Changes to This Privacy Policy

13.1 se999 reserves the right to update this Privacy Policy at any time. Where changes are material — for example, a new category of data being collected or a new third-party sharing arrangement — se999 will notify registered players via the email address on file or through an in-platform notification prior to the changes taking effect.

13.2 The current version of this Policy is always accessible at se999.ws/privacy-policy. The "Last Updated" date at the top of this page reflects the date of the most recent revision.

13.3 Your continued use of the se999 platform after any revised Policy takes effect constitutes your acceptance of the updated terms. If you do not agree with changes to this Policy, you should close your se999 account and cease using the platform.

Contact & Privacy Complaints

14.1 For all privacy-related queries, data subject requests, or complaints, please contact the se999 Data Privacy team:

• Email: [email protected]
• Subject line: "Privacy Request — [Your Registered Username]"
• Response time: Acknowledgement within 5 business days; resolution within 30 days

14.2 If you are not satisfied with se999's response to a privacy complaint, you may escalate the matter to se999's compliance team for a formal review. se999 will provide a final written response to escalated privacy complaints within 28 days of receiving full documentation.

14.3 All privacy correspondence must be conducted in English. se999 is not in a position to process privacy requests submitted in other languages.