hh95 Privacy Policy

1. Introduction

This Privacy Policy (hereinafter "Policy") describes how hh95 (hereinafter "hh95", "we", "us" or "our") collects, uses, processes, stores and protects the personal data of individuals (hereinafter "User", "you" or "your") who access or use the hh95 online gaming platform and associated services, accessible at hh95.cam (hereinafter the "Platform").

hh95 is committed to protecting the privacy of all its users, including those accessing the Platform from cities across Pakistan — including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We recognise that the protection of personal data is a fundamental right and a responsibility we take seriously.

This Policy forms part of our broader legal framework and should be read alongside our Terms & Conditions and our Responsible Gambling Policy. In the event of any conflict between this Policy and the Terms & Conditions regarding data matters, this Policy shall take precedence.

We may process your personal data in connection with the provision of online gaming services, identity verification (KYC), payment processing, customer support, fraud prevention, anti-money laundering (AML) compliance, and the improvement of our Platform and Services.

2. Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" — any information that relates to an identified or identifiable natural person, including but not limited to name, email address, date of birth, residential address, payment information, device identifiers and account activity data.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, combination, restriction, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, hh95 acts as the Data Controller with respect to information collected from Users.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller under a data-processing agreement.
• "Cookies" — small data files placed on your device by a website to store preferences, session information and analytical data.
• "KYC" — Know Your Customer procedures requiring verification of a User's identity, age and residential details.
• "Services" — all gaming, betting, informational and support features available to registered Users via the Platform.
• "Sensitive Personal Data" — a subset of Personal Data warranting heightened protection, including financial account details, identity document numbers, and information that could facilitate fraud or identity theft.

3. Data We Collect

hh95 collects the minimum Personal Data necessary to provide its Services lawfully and effectively. The categories of data we may collect include:

We do not knowingly collect full payment card numbers. Where payment processing requires card data, it is handled by PCI-DSS compliant third-party payment processors and is not stored on hh95 infrastructure.

4. How We Collect Your Data

hh95 collects Personal Data through the following means:

• Direct submission: Information you provide when registering an Account, completing KYC, making deposits or withdrawals, contacting support, or responding to surveys.
• Automated collection: Technical and Usage Data collected automatically via cookies, server logs and analytics tools when you interact with the Platform.
• Third-party sources: Identity verification data returned by our KYC service providers; fraud-screening data from risk-management partners; payment confirmation data from payment processors including, where applicable, those facilitating transactions via references familiar to Pakistani users such as Easypaisa, JazzCash, Raast or bank transfers through institutions like HBL, UBL, Meezan Bank or Bank Alfalah.

5. Legal Basis for Processing

hh95 processes Personal Data only where a valid legal basis exists. The applicable legal bases include:

• Contractual necessity: Processing required to register your Account, verify your identity, process payments and deliver the Services you have requested.
• Legal obligation: Processing required to comply with applicable AML, KYC, fraud-prevention and other regulatory obligations imposed on hh95 by its licensing jurisdiction.
• Legitimate interests: Processing carried out for fraud prevention, platform security, abuse detection and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications, optional analytics participation or other purposes where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Data

hh95 uses your Personal Data for the following purposes:

• To create, manage and maintain your Account and provide access to the Platform's Services.
• To verify your identity and age in compliance with KYC and AML obligations.
• To process deposits and withdrawals and to reconcile financial transactions.
• To detect, investigate and prevent fraud, money laundering, bonus abuse and other Prohibited Conduct as defined in our Terms & Conditions.
• To provide customer support, respond to queries and resolve disputes.
• To monitor and enforce responsible-gambling obligations, including the administration of deposit limits, loss limits, cooling-off periods and self-exclusion.
• To send transactional communications — such as account confirmation emails, withdrawal notifications and security alerts — that are necessary for the operation of your Account.
• To send promotional communications regarding bonuses and offers, where you have consented to receive such communications. You may opt out at any time via your Account settings.
• To analyse Platform usage patterns in aggregate, in order to improve the functionality, content and user experience of hh95.
• To comply with applicable legal obligations and respond to lawful requests from regulatory or law enforcement authorities.

7. Data Sharing & Disclosure

hh95 does not sell, rent or trade your Personal Data to third parties for their own commercial or marketing purposes. We may share your data in the following limited circumstances:

• Service providers and Data Processors: Third-party vendors who assist in the operation of the Platform — including KYC verification providers, payment processors, cloud infrastructure providers, fraud-screening services, customer support software providers and analytics platforms. All such parties are bound by data-processing agreements requiring them to process your data only on our instructions and to maintain appropriate security standards.
• Regulatory and legal compliance: We may disclose Personal Data to regulatory authorities, law enforcement agencies, or courts where we are legally required to do so, or where we have reasonable grounds to believe disclosure is necessary to protect the rights, property or safety of hh95, its Users or the public.
• Corporate transactions: In the event of a merger, acquisition, sale of assets or other corporate restructuring, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.
• Consent-based sharing: We will share your data with third parties for any other purpose only with your explicit prior consent.

hh95 requires all third-party Data Processors to implement appropriate technical and organisational security measures and to handle your Personal Data solely in accordance with our instructions and applicable data protection law.

8. Cookies & Tracking Technologies

hh95 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies may be placed by hh95 directly (first-party cookies) or by our authorised analytics and advertising partners (third-party cookies).

The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly — for example, maintaining your session when you are logged in. These cannot be disabled.
• Functional cookies: Store your preferences, such as language settings and responsible-gambling tool configurations, to improve your experience.
• Analytics cookies: Help us understand how Users interact with the Platform, which pages are visited most frequently and where errors occur. Data collected is aggregated and anonymised where possible.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic and unauthorised access attempts.

You can manage cookie preferences through your browser settings. Disabling certain cookies may limit the functionality of the Platform. hh95 will seek your consent for non-essential cookies in accordance with applicable requirements.

9. Data Retention

hh95 retains Personal Data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable legal, regulatory, AML or tax obligations. General retention guidelines are as follows:

• Account and identity data: Retained for the duration of your Account relationship with hh95 and for a minimum period thereafter as required by AML and gaming regulatory obligations (typically five years following account closure, though specific requirements depend on the applicable licensing jurisdiction).
• Transaction data: Retained for a minimum of five years from the date of the transaction to satisfy AML record-keeping obligations.
• Customer support communications: Retained for a period sufficient to resolve disputes and for quality assurance, typically up to three years.
• Technical and usage data: Retained in aggregated or anonymised form for analytical purposes; identifiable technical data is typically retained for up to 12 months.

Where data is no longer required and retention is not mandated by law, hh95 will securely delete or anonymise it in a manner that prevents recovery.

10. Data Security

hh95 implements a range of technical and organisational measures designed to protect Personal Data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and our servers.
• Encryption of sensitive stored data, including identity document information.
• Role-based access controls limiting internal staff access to Personal Data on a need-to-know basis.
• Regular security assessments and vulnerability management processes.
• Multi-factor authentication requirements for administrative system access.
• Incident response procedures for detecting, containing and notifying affected parties of data breaches where required by law.

While hh95 takes reasonable and proportionate steps to protect your data, no online system can be guaranteed to be entirely secure. You are responsible for maintaining the confidentiality of your Account password and for ensuring that you access the Platform only via official, HTTPS-secured URLs. If you suspect unauthorised access to your Account, please contact hh95 support immediately.

11. International Data Transfers

hh95 operates internationally and may transfer Personal Data to, or process it in, countries outside your country of residence. Where such transfers occur, hh95 takes steps to ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that required under applicable data protection law, including:

• Transfers to countries recognised as providing an adequate level of data protection by the applicable regulatory framework.
• Use of contractual clauses or equivalent transfer mechanisms with recipients in countries that do not benefit from an adequacy determination.
• Processing by third-party service providers subject to binding data-processing agreements incorporating appropriate data protection requirements.

For users in Pakistan, please be aware that Pakistan does not currently have a comprehensive data protection law equivalent to international standards, though regulatory developments are ongoing. hh95 applies its own data protection standards regardless of the jurisdiction from which you access the Platform.

12. Your Data Rights

Depending on the applicable data protection law in your jurisdiction, you may have the following rights in relation to your Personal Data held by hh95. We will respond to valid requests within a reasonable timeframe.

To exercise any of these rights, please contact us using the details provided in Section 16. We may need to verify your identity before processing your request. Where requests are manifestly unfounded or excessive, we reserve the right to charge a reasonable administrative fee or decline the request.

If you believe your data rights have not been respected, you may have the right to lodge a complaint with the competent data protection supervisory authority in your jurisdiction.

13. Children's Privacy

The hh95 Platform is strictly intended for adults aged 18 years or over — or the higher minimum age required by the applicable operator or licensing jurisdiction. hh95 does not knowingly collect Personal Data from individuals under the applicable minimum age. If we become aware that a minor has registered an Account or provided Personal Data, we will take immediate steps to close the Account and delete all associated data.

If you believe that a minor has registered on the Platform, please contact our support team immediately so that we can investigate and take appropriate action.

14. Third-Party Links & Services

The Platform may contain references to, or integrate with, third-party services — such as payment gateways for transactions processed via familiar Pakistani payment references including Easypaisa, JazzCash, Raast and bank transfers through institutions such as HBL, UBL, Meezan Bank or Bank Alfalah. These third-party services operate under their own privacy policies, which are independent of this Policy.

hh95 is not responsible for the privacy practices or data handling of any third-party service. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of the Platform.

15. Changes to This Privacy Policy

hh95 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, we will provide reasonable notice via the Platform or by email to the address associated with your Account. The "Last Updated" date at the top of this page will be revised accordingly.

Your continued use of the Platform following the publication of a revised Policy constitutes your acceptance of those changes. If you do not agree to the revised Policy, you must cease using the Platform and may close your Account in accordance with the Terms & Conditions.

We encourage you to review this Policy periodically to remain informed of how hh95 protects your information.

16. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the processing of your Personal Data, please contact hh95 using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available on the Platform 24 hours a day, 7 days a week
• Subject line: Please include "Privacy Request" in your subject line to ensure your query is directed to the appropriate team
• Languages: English (primary); Urdu assistance may be available on request

We aim to acknowledge data-related requests within 5 business days and to resolve them fully within the timeframe required by applicable law.