Privacy Policy – How 92 Starr Handles Your Personal Data

1Introduction — Our Privacy Commitment

92 Starr ("we", "us", "our", "the Platform") takes the privacy of every registered user seriously. This Privacy Policy describes how 92 Starr collects, processes, stores and protects personal information provided by or generated through the use of the 92 Starr platform at https://92starr.app, including all associated mobile and web interfaces.

This policy applies to all users who visit, register with, or place any bet or game on 92 Starr, regardless of the device used. By registering for a 92 Starr account or by continuing to use the platform, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read alongside the 92 Starr Terms and Conditions and Responsible Gaming Policy, both of which complement the protections described here. Together, they form the full framework governing your relationship with 92 Starr.

2What Personal Information We Collect

92 Starr collects personal information from you in several ways — directly when you register or use the platform, automatically as you navigate the site, and from third-party service providers where necessary for verification and payment processing.

2.1 Information You Provide Directly

• Registration data: Your full name, Pakistani mobile number, email address and date of birth when you create a 92 Starr account.
• Identity verification documents: A copy of your CNIC (Computerised National Identity Card) and, where required, a selfie or proof of address when you complete the KYC (Know Your Customer) process.
• Payment information: Your JazzCash or Easypaisa mobile number, NayaPay or SadaPay account details, bank account name and IBAN for IBFT transfers, or partial card details (last four digits) for Visa/Mastercard transactions. 92 Starr does not store full card numbers.
• Support communications: The content of any messages, chat transcripts or emails you send to the 92 Starr support team.
• Responsible gaming information: Deposit limits, self-exclusion requests and any other information you provide when using our responsible gaming tools.

2.2 Information Collected Automatically

• Device and browser data: IP address, device type, operating system, browser type and version, screen resolution and connection type.
• Usage data: Pages visited, features accessed, bets placed, games played, session duration, click paths and navigation patterns within the 92 Starr interface.
• Transaction records: All deposit and withdrawal transactions, bet placements, game results and account balance changes — maintained as a complete account history.
• Location data: General geographic location derived from your IP address (city and country level only). 92 Starr does not access your device's GPS location.
• Cookies and similar tracking technologies: Session identifiers, authentication tokens and platform preference settings stored in your browser. Full details are in Section 6 of this policy.

3How 92 Starr Uses Your Personal Data

Every piece of personal data collected by 92 Starr is used for a specific, documented purpose. We do not process your data for reasons beyond those set out in this section without your prior consent or a legal obligation requiring us to do so.

3.1 Account Management and Platform Operation

Your registration information is used to create and maintain your 92 Starr account, authenticate your identity on login, process bets and game participation, and display your account balance, history and preferences. This is the core operational use of your data — without it, you cannot have an account on 92 Starr.

3.2 Payment Processing

Your payment method details are used solely to process deposits and withdrawals. 92 Starr passes only the minimum necessary data to its payment processors (JazzCash, Easypaisa, NayaPay, SadaPay, bank partners) to complete each transaction. Payment processor partners have their own privacy policies governing data handling on their platforms.

3.3 Identity Verification and Fraud Prevention

CNIC data and other verification documents are used to confirm your identity, verify your age (18+), prevent the use of stolen or fraudulent identities, and comply with anti-money laundering (AML) obligations. This data is compared against third-party identity verification databases only to the extent required for compliance.

3.4 Customer Support

Support communications are retained to maintain a record of your interactions with 92 Starr, to ensure continuity of assistance across multiple contacts, and to improve support quality through periodic review. Your support history is accessible to 92 Starr support agents only — not to the general team.

3.5 Responsible Gaming Monitoring

Usage data including session duration, deposit frequency, betting patterns and loss thresholds are monitored as part of 92 Starr's responsible gaming obligations. This monitoring allows 92 Starr to identify accounts that may be exhibiting signs of problem gambling behaviour and to proactively reach out or apply protective measures.

3.6 Platform Improvement and Analytics

Aggregated, anonymised usage data is used to understand how players use 92 Starr, identify features that are confusing or underused, and prioritise product improvements. This analytics processing does not identify individual users — it operates on statistical patterns across the player base as a whole.

3.7 Marketing Communications

If you have opted in to receiving promotional communications, 92 Starr may send you information about offers, bonuses and new features by SMS or email. You can opt out of marketing communications at any time by contacting support@92starr.app or by using the unsubscribe link in any marketing email. Opting out of marketing does not affect your ability to receive transactional communications (such as deposit confirmations or withdrawal notifications), which are essential to account operation.

4Legal Basis for Data Processing

92 Starr processes your personal data on the following legal grounds, depending on the purpose of processing:

• Contractual necessity: Processing required to fulfil the agreement between you and 92 Starr — including account registration, payment processing and bet settlement. Without this processing, we cannot provide the service.
• Legitimate interests: Processing carried out for fraud prevention, security monitoring, platform analytics and responsible gaming — where these interests are proportionate and do not override your privacy rights.
• Legal obligation: Processing required to comply with applicable regulations, including AML (anti-money laundering) record-keeping requirements, KYC obligations and cooperation with lawful authority requests.
• Consent: Processing for marketing communications — only where you have explicitly opted in and only until you withdraw your consent.

5Who We Share Your Data With

92 Starr does not sell, rent or trade your personal data. We share data with third parties only in the limited circumstances described below, and only to the minimum extent necessary for each specific purpose.

5.1 Payment Service Providers

To process your deposits and withdrawals, 92 Starr shares the necessary payment information with your chosen payment provider — JazzCash, Easypaisa, NayaPay, SadaPay, your bank (for IBFT) or your card scheme provider. These providers are contractually required to handle your data securely and to use it only for the transaction being processed.

5.2 Identity Verification Services

To fulfil KYC requirements, 92 Starr uses third-party identity verification services to validate CNIC documents and confirm age. These services receive only the data necessary for the verification check and are prohibited from retaining or using your data beyond the scope of the check.

5.3 Technology and Hosting Partners

92 Starr's platform is hosted on secure cloud infrastructure. Hosting and technology partners may have technical access to data stored on servers in the course of maintaining infrastructure, but are bound by strict data processing agreements that prohibit any independent use of your data.

5.4 Legal and Regulatory Authorities

92 Starr may be required to disclose your personal data to law enforcement, regulatory bodies or courts in response to a lawful order. 92 Starr will always seek to verify the legitimacy of such requests before complying and will not voluntarily disclose your data to any authority beyond what is legally required.

6Cookies and Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files that a website stores in your browser when you visit. They allow the website to remember information about your visit — such as your login status and preferences — the next time you return. 92 Starr uses cookies and similar technologies including local storage and session tokens.

6.2 Cookies 92 Starr Uses

• Essential cookies: Required for the platform to function — your login session, security tokens and account preferences. These cannot be disabled without breaking core platform functionality.
• Performance cookies: Collect anonymised data about how you use the 92 Starr platform to help us improve the experience. No personally identifiable information is included in this data.
• Functional cookies: Remember your language, display preferences and recent activity to personalise your experience within the platform.

6.3 Managing Cookies

You can control and delete cookies through your browser settings. Note that disabling essential cookies will affect your ability to log in and use the 92 Starr platform. Performance and functional cookies can generally be disabled without impacting core functionality. Most modern mobile browsers (Chrome, Safari, Firefox on Android and iOS) include cookie management in their settings menus.

7How Long We Keep Your Data

92 Starr does not keep your personal data for longer than is necessary for the purpose for which it was collected, subject to any legal or regulatory obligations that require longer retention.

When data reaches the end of its retention period, 92 Starr securely deletes or irreversibly anonymises it so that it can no longer be associated with any individual.

8How We Keep Your Data Secure

Data security is one of the highest operational priorities at 92 Starr. We implement and maintain technical and organisational measures that are appropriate for the sensitivity of the data we handle.

8.1 Encryption

All data transmitted between your device and 92 Starr is encrypted using TLS 1.3 with 256-bit encryption — the same standard used by Pakistani banks for online banking. Data at rest on 92 Starr's servers is encrypted using AES-256 encryption. This means that even if a storage medium were physically compromised, the data on it would be unreadable without the encryption keys.

8.2 Access Controls

Access to personal data within 92 Starr is controlled on a strict need-to-know basis. Individual staff members can only access the data categories they require for their specific role. Support agents can view account and transaction information but cannot access CNIC documents directly. Access logs are maintained and reviewed regularly.

8.3 Account Security Features

92 Starr offers two-step OTP (one-time password) verification for all account logins, which we strongly encourage every registered player to activate. This means that even if your password is compromised, your account cannot be accessed without the OTP sent to your registered mobile number.

8.4 Fraud Detection

92 Starr operates continuous automated fraud detection systems that monitor for unusual login patterns, suspicious payment activity and account access anomalies. Where a potential security incident is detected, the affected account may be temporarily restricted while our team investigates. You will be notified by SMS or email if any protective action is taken on your account.

9Your Privacy Rights as a 92 Starr User

As a registered user of 92 Starr, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at support@92starr.app with the subject line "Privacy Rights Request" and include your registered mobile number to help us locate your account promptly.

92 Starr will respond to all verified privacy rights requests within 30 calendar days. Where a request is complex or where we receive multiple simultaneous requests, we may extend this period to 60 days with prior notice. There is no charge for exercising your privacy rights unless requests are clearly unfounded or excessive.

10Children's Privacy

92 Starr is strictly for users who are 18 years of age or older. We do not knowingly collect, store or process personal data from anyone under the age of 18. If you believe that a person under 18 has registered on 92 Starr, please notify us immediately at support@92starr.app. Upon confirmation, we will close the account, void any transactions and securely delete all associated personal data.

Parents and guardians are encouraged to use device-level parental controls and content restrictions to prevent underage access to online betting platforms including 92 Starr. Please visit our Responsible Gaming page for additional guidance on protecting younger family members from gambling-related content.

11Third-Party Links Within the Platform

The 92 Starr platform is a closed environment and does not contain links to external third-party websites in its main interface. Any third-party service providers referenced in these policies — such as payment processors — operate their own privacy policies that govern data handling on their respective platforms. 92 Starr is not responsible for the privacy practices of any third-party service you access independently in connection with your use of 92 Starr.

If you have questions about how a payment provider (such as JazzCash or Easypaisa) handles your data in connection with transactions on 92 Starr, we recommend reviewing their respective privacy policies directly on their official websites.

12Changes to This Privacy Policy

92 Starr reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations or platform features. When material changes are made, registered users will be notified via SMS to their registered mobile number or by email at least 14 days before the changes take effect.

The "Effective date" displayed at the top of this page reflects the date of the most recent revision. Continued use of 92 Starr after a policy update takes effect constitutes your acceptance of the revised terms. If you do not agree with any update, you should stop using the platform and may request account closure by contacting support@92starr.app.

We recommend bookmarking this page and reviewing it periodically, particularly if you use 92 Starr frequently. The changes section will always be updated to reflect what was modified and when.

13Contact Us — Privacy Queries and Complaints

If you have any question, concern or complaint related to this Privacy Policy or to how 92 Starr handles your personal data, please get in touch with our team. We take all privacy-related communications seriously and aim to respond within one business day.

• Email: support@92starr.app
• Subject line for privacy requests: "Privacy Rights Request" or "Privacy Complaint"
• Support hours: 24 hours a day, 7 days a week, including Pakistani public holidays
• Response time: Most privacy queries resolved within one business hour; formal rights requests within 30 days

Please include your registered mobile number in any privacy-related communication so our team can locate your account quickly. For formal data access or erasure requests, we may ask you to verify your identity before processing to ensure we do not disclose or delete another person's data in error.