bh99 Privacy Policy

1. Overview

This Privacy Policy ("Policy") describes how bh99 ("we", "us", "our") collects, processes, stores, and protects personal data submitted by users ("you", "your") of the bh99 platform, accessible at bh99.im and all associated mobile interfaces and applications.

bh99 operates under an international gaming licence and is committed to handling personal data in accordance with applicable data protection laws and the standards set by its licensing authority. By registering an account or using any bh99 service, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read alongside the bh99 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Personal Data We Collect

bh99 collects the following categories of personal data from registered users and platform visitors:

2.1 Identity Data

• Full legal name as it appears on your CNIC or passport
• Date of birth (used for 21+ age verification)
• Gender (optional, for personalisation purposes)
• CNIC number or passport number (for KYC verification)
• Photograph of government-issued identification document

2.2 Contact Data

• Email address (primary communication channel)
• Mobile phone number (used for OTP verification and support)
• Residential address (required for enhanced KYC and withdrawal verification)
• City of residence (e.g., Karachi, Lahore, Islamabad, Faisalabad)

2.3 Financial Data

• JazzCash or EasyPaisa mobile wallet number
• Bank account details for IBFT or HBL/UBL/Meezan Bank transfers
• Deposit and withdrawal transaction history
• Source-of-funds documentation where required by AML compliance

2.4 Gaming & Behavioural Data

• Betting history, game logs, and wagering records
• Bonus claims and promotional participation
• Session duration, frequency, and timing patterns
• Responsible gaming tool usage (deposit limits, self-exclusion requests)

2.5 Technical Data

• IP address and geolocation data (city/region level)
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform interaction logs and error reports

3. How We Collect Your Data

bh99 collects personal data through the following channels:

• Direct submission: Information you provide during registration, KYC verification, deposit/withdrawal forms, and support tickets submitted to [email protected].
• Automated collection: Technical data collected automatically when you access the bh99 platform, including via cookies, session tracking, and server logs.
• Third-party verification: Identity verification data received from licensed KYC/AML service providers engaged by bh99 for regulatory compliance purposes.
• Payment processors: Transaction confirmation data received from JazzCash, EasyPaisa, Raast, and banking partners when you make deposits or request withdrawals.
• Game providers: Gaming session data received from bh99's licensed game content providers, including RNG certification bodies and live dealer studio operators.

4. Why We Use Your Data

bh99 processes your personal data for the following purposes:

• Account creation and management: To register your bh99 account, verify your identity, and maintain accurate account records.
• Age and identity verification: To confirm that you are aged 21 or above and are who you say you are, as required by our licensing authority.
• Payment processing: To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, IBFT, and other supported PKR payment channels.
• Regulatory compliance: To fulfil our anti-money laundering (AML), Know Your Customer (KYC), and responsible gaming obligations as imposed by our international gaming licence.
• Platform security: To detect and prevent fraud, bonus abuse, account takeovers, and other prohibited conduct described in our Terms & Conditions.
• Customer support: To respond to your queries, complaints, and support requests in a timely and effective manner.
• Responsible gaming: To monitor gaming patterns, identify potential problem gambling indicators, and administer self-exclusion or cooling-off periods upon request.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided explicit consent. You may withdraw this consent at any time via your account settings.
• Platform improvement: To analyse aggregated, anonymised usage data to improve platform performance, game selection, and user experience.

5. Legal Basis for Processing

bh99 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to fulfil the bh99 user agreement, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with AML, KYC, and responsible gaming regulations imposed by our licensing authority.
• Legitimate interests: Processing carried out in bh99's legitimate interest to prevent fraud, maintain platform security, and improve service quality — provided that such interests do not override your fundamental privacy rights.
• Consent: Processing of data for direct marketing and optional personalisation features, where you have given explicit prior consent. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing & Disclosure

bh99 does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties strictly on a need-to-know basis:

• KYC/AML service providers: Licensed identity verification partners engaged to confirm your CNIC or passport details and conduct source-of-funds checks.
• Payment processors: JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, 1LINK, and other PKR payment partners, solely to process your transactions.
• Game content providers: Licensed casino and sportsbook software providers who require session data to deliver and audit game outcomes.
• Licensing authority: Our international gaming licence regulator, which may require access to player records for audit, compliance inspection, or dispute resolution purposes.
• Law enforcement: Where bh99 is legally compelled to disclose data by a court order, regulatory directive, or law enforcement request, we will comply with applicable legal obligations. Where permitted by law, bh99 will notify you of such requests.
• Fraud prevention networks: Industry-wide fraud and problem gambling databases where bh99 participates to protect players and the integrity of the platform.

All third parties engaged by bh99 are contractually bound to process your data only for the specified purpose and to maintain equivalent data security standards. bh99 remains responsible for the data processing activities of its sub-processors.

7. Data Retention

bh99 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by our licensing obligations:

• Account and identity data: Retained for a minimum of five (5) years from the date of account closure, as required by AML regulations applicable to licensed gaming operators.
• Financial transaction records: Retained for a minimum of five (5) years from the transaction date for audit and regulatory compliance purposes.
• Betting and gaming history: Retained for a minimum of three (3) years from the date of the relevant gaming session.
• Support correspondence: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained for three (3) years from the date of last consent or withdrawal of consent.
• Technical and log data: Retained for twelve (12) months, after which it is aggregated and anonymised.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with bh99's data destruction procedure.

8. Data Security

bh99 implements a multi-layered security architecture to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption on all data transmitted between your device and bh99 servers.
• AES-256 encryption at rest for all stored personal and financial data.
• Two-factor authentication (2FA) available on all bh99 accounts and mandatory for staff with access to player data.
• Role-based access controls ensuring that only personnel with a specific operational need can access personal data.
• Regular third-party penetration testing of the bh99 platform infrastructure.
• Automated fraud detection systems that flag unusual account activity in real time.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights, bh99 will notify affected users and the relevant regulatory authority within the timeframe prescribed by applicable law.

9. Cookies & Tracking Technologies

bh99 uses cookies and similar tracking technologies to operate the platform and improve your experience. The following cookie categories are used:

• Strictly necessary cookies: Required for platform functionality — session management, login state, and security tokens. These cannot be disabled without affecting core platform features.
• Performance cookies: Anonymised analytics data used to understand how players navigate the platform, which pages are visited most frequently, and where technical errors occur.
• Functional cookies: Used to remember your preferences such as language settings, preferred payment method, and responsible gaming limit configurations.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and to measure the effectiveness of bh99 marketing campaigns.

You may manage your cookie preferences at any time through your browser settings. Blocking strictly necessary cookies will impair your ability to use the bh99 platform. Blocking other cookie categories will not affect core functionality but may reduce personalisation features.

10. Your Data Rights

Subject to applicable data protection law and our regulatory retention obligations, you have the following rights regarding your personal data held by bh99:

• Right of access: You may request a copy of all personal data bh99 holds about you (a "Subject Access Request"). bh99 will respond within thirty (30) days.
• Right to rectification: You may request correction of inaccurate or incomplete personal data. Minor corrections (e.g., contact details) can be made directly through your account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected — subject to our legal retention obligations (see Section 7).
• Right to restrict processing: You may request that bh99 limit how your data is used in certain circumstances, for example while a correction request 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.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing emails), you may withdraw consent at any time via your account settings or by emailing [email protected].
• Right to object: You may object to processing based on legitimate interests, including profiling for marketing purposes.

To exercise any of the above rights, contact bh99 at [email protected] with the subject line "Data Rights Request". We may require identity verification before processing your request.

11. Minors & Age Restriction

The bh99 platform is strictly restricted to individuals aged 21 years and above. bh99 does not knowingly collect personal data from anyone under the age of 21. If you believe a minor has registered a bh99 account, please contact us immediately at [email protected].

Any account found to be operated by a person under 21 years of age will be permanently closed without notice. All funds associated with such an account will be returned to the originating payment method following identity verification, and all gaming history will be voided. bh99 takes its responsibility to protect minors extremely seriously and cooperates fully with any regulatory investigation related to underage access.

12. International Data Transfers

As bh99 operates under an international gaming licence, your personal data may be processed in countries other than Pakistan. Where data is transferred internationally, bh99 ensures that appropriate safeguards are in place, including:

• Contractual data processing agreements with all sub-processors requiring equivalent data protection standards.
• Transfer only to jurisdictions that provide an adequate level of data protection as assessed by bh99's compliance team.
• Use of standard contractual clauses or equivalent mechanisms where transfers occur outside adequacy-recognised jurisdictions.

bh99's primary server infrastructure is hosted in a jurisdiction recognised for strong data protection standards. Data transferred to payment processors (JazzCash, EasyPaisa, etc.) remains subject to those providers' own regulatory obligations within Pakistan.

13. Changes to This Policy

bh99 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Material changes will be communicated to registered users by email or in-platform notification at least seven (7) days before taking effect.

The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the bh99 platform after the effective date of any amendment constitutes acceptance of the revised Policy. Archived versions are available on request by emailing [email protected].

14. Contact & Data Enquiries

For any privacy-related questions, data rights requests, or concerns regarding bh99's handling of your personal information, please contact our data protection team:

• Email: [email protected] (subject line: "Privacy Enquiry" or "Data Rights Request")
• Live Chat: Available 24/7 via the bh99 platform after login — ask to speak to the Data Protection team
• Response Time: We aim to acknowledge all privacy requests within 48 hours and resolve them within 30 days

If you are not satisfied with bh99's response to a data rights request, you have the right to escalate your complaint to the supervisory authority under our licensing jurisdiction.