Privacy Policy — ju55 Data Commitment

This Privacy Policy ("Policy") describes how ju55 ("we", "us", "our", or "the Platform") collects, uses, stores, shares, and protects the personal information of individuals ("you", "your", or "Player") who access or use the ju55 platform at ju55.org, including all related mobile interfaces, applications, live chat tools, and support channels.

ju55 is committed to handling your personal data with integrity, transparency, and full respect for your rights. We operate under internationally recognised data protection principles and maintain security standards appropriate to the sensitivity of the data we process, which includes financial information, identity documents, and gaming activity records.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference. Capitalised terms not defined here carry the meanings given to them in the ju55 Terms & Conditions.

ju55 collects the following categories of personal data from Players, either directly or through automated means during platform use:

ju55 collects personal data through the following primary methods:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting our support team, or participating in promotions.
• Automated collection: Technical and behavioural data collected automatically when you access the ju55 platform, including IP addresses, device identifiers, session metadata, and clickstream data captured through server logs and analytics tools.
• Payment processors: Transaction confirmation data received from payment intermediaries such as JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, and blockchain networks when processing your deposits and withdrawals.
• KYC verification partners: Identity verification results and risk scores returned by our third-party KYC service providers following document and liveness checks.
• Fraud and AML screening: Risk intelligence data received from anti-money-laundering and fraud detection systems that cross-reference your registration details against sanctions lists and known fraud databases.

ju55 processes your personal data only for specific, legitimate purposes. The following table sets out our primary processing purposes and the corresponding data categories used:

• Account creation and management: Setting up and maintaining your ju55 Player account, including authentication, password recovery, and account preference storage.
• Payment processing: Processing deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, and USDT blockchain transfers. Matching incoming payments to your account wallet.
• KYC and AML compliance: Verifying your identity and age (21+), screening against sanctions and politically exposed persons (PEP) lists, monitoring for suspicious transaction patterns, and fulfilling our anti-money-laundering obligations.
• Service delivery and improvement: Providing access to casino games, sports betting markets, live dealer tables, and PSL betting. Analysing aggregated platform usage data to improve game performance, user experience, and platform stability.
• Promotions and bonuses: Administering welcome bonuses, reload offers, cashback promotions, and PSL seasonal offers; verifying eligibility and tracking wagering requirement completion.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling indicators; applying deposit limits, session alerts, and self-exclusion settings at the Player's request; responding to third-party self-exclusion scheme notifications.
• Customer support: Responding to queries, resolving disputes, processing complaints, and maintaining records of support interactions for quality assurance.
• Security and fraud prevention: Detecting and preventing unauthorised account access, multi-accounting, bonus abuse, match-fixing, and other prohibited conduct.
• Legal compliance: Retaining records as required by applicable gaming regulations, financial regulations, and law enforcement requests from competent authorities.

ju55 processes your personal data on the following legal bases, which vary depending on the specific processing activity:

• Contractual necessity: Processing that is necessary to perform the contract between you and ju55 — including account creation, payment processing, game access, and customer support — is carried out on the basis that it is required to fulfil our contractual obligations to you as a Player.
• Legal obligation: Certain processing activities — particularly KYC identity verification, AML transaction monitoring, sanctions screening, and record retention — are carried out because ju55 is required to perform them under applicable gaming licensing conditions and financial crime prevention regulations.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform analytics, and responsible gaming pattern detection is carried out on the basis of ju55's legitimate interest in operating a secure, fair, and responsible platform, balanced against your privacy rights.
• Consent: Where ju55 sends you optional marketing communications about promotions, bonuses, or new games, we do so on the basis of your consent, which you may withdraw at any time by updating your communication preferences in your account settings or by contacting our support team.

ju55 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the following limited circumstances and only to the extent strictly necessary for the stated purpose:

• Payment service providers: We share transaction data with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, and blockchain network operators as required to process your deposits and withdrawals. These providers act as independent data controllers for their own transaction records.
• KYC and identity verification providers: We share identity document images and personal details with our KYC service provider(s) to complete mandatory age and identity verification. These providers are contractually bound to process data solely for this purpose.
• AML and fraud screening services: We share registration and transaction data with anti-money-laundering and fraud intelligence platforms to screen against sanctions lists and detect suspicious patterns. Results are used solely for compliance and security purposes.
• Gaming platform and software providers: Game providers whose products are offered on the ju55 platform may receive your Player ID and gaming session data for game integrity and dispute resolution purposes. Full personal identity data is not shared with game providers.
• Regulatory and law enforcement authorities: We will disclose your personal data to competent regulatory bodies, gaming licensing authorities, financial intelligence units, or law enforcement agencies where required to do so by applicable law, court order, or regulatory direction. Where permitted, we will notify you of such a disclosure.
• Professional advisers: Our legal counsel, auditors, and compliance consultants may access personal data on a strictly need-to-know basis and are bound by professional confidentiality obligations.

ju55 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the minimum retention periods required by applicable law and licensing conditions. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account plus a minimum of five (5) years following permanent account closure, in compliance with standard financial record-keeping obligations applicable to licensed gaming platforms.
• KYC documents (CNIC copies, selfies): Retained for a minimum of five (5) years following the date of submission, or longer if required by a specific regulatory or investigative obligation.
• Transaction records: All deposit and withdrawal records, including amounts, timestamps, payment methods, and associated wallet/account references, are retained for a minimum of five (5) years.
• Gaming activity logs: Bet history, game session records, and responsible gaming tool usage logs are retained for five (5) years from the date of the activity.
• Support and communications records: Live chat transcripts and email correspondence are retained for two (2) years from the date of the interaction, unless the interaction is related to a dispute or investigation, in which case records are retained for the duration of the matter plus two (2) years.
• Marketing consent records: Records of your marketing consent or opt-out are retained for the duration of your account relationship and two (2) years thereafter as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to any individual Player. Anonymised, aggregated data may be retained indefinitely for platform analytics and improvement purposes.

The ju55 platform uses cookies and similar tracking technologies to provide core functionality, maintain your session, and gather anonymised analytics. The following categories of cookies are used:

• Strictly necessary cookies: These cookies are essential for the platform to function. They include session authentication tokens, CSRF protection tokens, and load-balancing cookies. These cookies cannot be disabled without preventing you from using the platform.
• Functional cookies: These cookies remember your platform preferences, such as your preferred language, display settings, and responsible gaming limits. They improve your experience but are not essential to core functionality.
• Analytics cookies: ju55 uses privacy-respecting analytics tools to collect anonymised, aggregated data about how Players navigate the platform. This data is used to identify usability issues, improve page performance, and prioritise feature development. Individual Players are not identifiable from analytics data.

Most web browsers allow you to manage cookie settings through the browser's preferences menu. You may choose to block or delete cookies at any time; however, disabling strictly necessary cookies will prevent the ju55 platform from functioning correctly and you will not be able to access your account.

As a Player on the ju55 platform, you have the following rights in relation to your personal data, which you may exercise at any time by contacting our support team at support@ju55.org:

• Right of access: You have the right to request a copy of the personal data ju55 holds about you. We will respond to access requests within 30 calendar days of receipt and will provide data in a commonly used electronic format.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Where the inaccuracy affects KYC-verified data, you may be required to submit updated documentation.
• Right to erasure ("right to be forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been unlawfully processed. This right is subject to our legal retention obligations — we cannot delete data we are required to retain under gaming licensing or financial regulations.
• Right to restriction of processing: You may request that we restrict processing of your personal data in certain circumstances, for example while the accuracy of data is being contested or while an objection to processing is being assessed.
• Right to data portability: You have the right to receive personal data you have provided to ju55 in a structured, commonly used, machine-readable format, and to request that this data be transmitted to another service provider where technically feasible.
• Right to object: You have the right to object to processing of your personal data carried out on the basis of legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests or the processing is required for legal claims.
• Right to withdraw consent: Where processing is based on your consent — specifically for marketing communications — you may withdraw consent at any time without affecting the lawfulness of prior processing.

ju55 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes the following controls:

• Encryption in transit: All data transmitted between your browser or app and the ju55 platform is encrypted using TLS 1.3. We enforce HTTPS across all platform endpoints and reject connections using deprecated TLS versions.
• Encryption at rest: Sensitive data fields — including CNIC numbers, payment account references, and KYC document files — are encrypted at the database level using AES-256 encryption. Encryption keys are managed separately from the encrypted data.
• Access controls: Access to production systems and Player data is restricted to authorised personnel on a strict need-to-know basis. All administrative access requires multi-factor authentication and is logged for audit purposes.
• Password security: Player account passwords are stored as salted cryptographic hashes. ju55 employees cannot view your password in plain text. We enforce minimum password complexity requirements and recommend the use of unique passwords for your ju55 account.
• Vulnerability management: The ju55 platform undergoes regular penetration testing by independent security professionals. Critical and high-severity vulnerabilities are remediated on a priority basis within defined SLA timeframes.
• Incident response: ju55 maintains a documented data breach response plan. In the event of a confirmed breach affecting Player personal data, affected Players will be notified within 72 hours of our becoming aware of the breach, and relevant regulatory authorities will be informed as required.

The ju55 platform is strictly restricted to individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. This is a firm, non-negotiable policy that applies across all jurisdictions in which ju55 operates.

ju55 operates automated age-detection checks during the registration process, including date of birth validation and CNIC-based age verification during the KYC process. Accounts where there is reasonable suspicion of underage access are immediately suspended pending age verification review.

If ju55 becomes aware that personal data has been collected from an individual under 21 without appropriate age verification, we will take steps to delete that data as promptly as possible and close the associated account. Any funds held in an underage account will not be returned and will be handled in accordance with our Terms & Conditions.

ju55 operates as an internationally licensed gaming platform. In the course of providing our services, your personal data may be transferred to and processed in countries outside Pakistan, including the jurisdiction in which our licensing authority is based and the locations of our technology infrastructure providers.

When transferring personal data internationally, ju55 ensures that appropriate safeguards are in place to maintain the equivalent level of protection that would apply under applicable data protection standards. These safeguards may include:

• Standard contractual data protection clauses incorporated into our agreements with international data processors.
• Transfers to jurisdictions that are assessed to provide an adequate level of data protection comparable to internationally recognised standards.
• Binding corporate rules where applicable within our corporate group structure.

By using the ju55 platform and accepting this Privacy Policy, you acknowledge and consent to the transfer of your personal data to international locations as described in this section, subject to the safeguards outlined above.

The ju55 platform may, from time to time, contain references to third-party services, payment providers, and information resources. This Privacy Policy applies solely to personal data collected and processed by ju55 through the ju55.org platform and its associated channels.

ju55 is not responsible for the privacy practices or content of any third-party platforms, including the websites or applications of payment providers such as JazzCash and EasyPaisa, or any other external service. When you leave the ju55 platform to interact with a third-party service — for example, to complete a JazzCash payment — you do so subject to that third party's own privacy policy and terms of service.

We encourage you to review the privacy policies of any third-party services you use in connection with your ju55 account, particularly your mobile wallet and banking providers, to understand how they handle your personal and financial information.

ju55 may update this Privacy Policy from time to time to reflect changes in our data practices, service offerings, or applicable legal requirements. The effective date at the top of this page will be updated whenever a material revision is made.

Where changes to this Policy are material — meaning they significantly affect your rights or how we process your personal data — ju55 will make reasonable efforts to notify registered Players via email to the address registered on your account, or via a prominent notice on the platform, prior to the changes taking effect.

Your continued use of the ju55 platform following publication of a revised Privacy Policy constitutes your acceptance of the updated data practices. If you do not agree with any revised terms, you must cease using the platform and contact our support team to request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which ju55 processes your personal data, please contact our data protection and compliance team using the following channels:

• Email: support@ju55.org — Subject line: "Privacy Request — [Your Account ID]"
• Live Chat: Available 24/7 via the chat widget on the ju55 platform. Support is available in both Urdu and English. Average response time: 3–5 minutes.

For formal data access requests, erasure requests, or complaints regarding our data processing practices, please submit your request in writing via email. Include your full name, registered email address, and a clear description of your request. We will acknowledge your request within 5 business days.