hm99 Privacy Policy — How We Handle Your Data

01 Introduction

This Privacy Policy ("Policy") is issued by hm99 ("hm99", "we", "us", "our") and governs the collection, use, storage, sharing and protection of personal data obtained from users ("User", "you", "your") of the hm99 website located at https://hm99.cam and all associated services (collectively, the "Platform").

hm99 is an English-language online casino and sports betting information platform serving users primarily in Pakistan. We are committed to handling personal data responsibly and transparently, in accordance with applicable data protection principles and the privacy expectations of our users.

By accessing the Platform, registering an Account or submitting any personal information, you acknowledge that you have read, understood and accepted this Policy. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

02 Definitions

For the purposes of this Policy, the following terms have the meanings set out below:

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, email address, date of birth, financial details and device identifiers.
• "Processing" — Any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" — The entity that determines the purposes and means of processing Personal Data. For users of this Platform, hm99 (or the Operator, as applicable) acts as Data Controller.
• "Data Processor" — A third party that processes Personal Data on behalf of hm99 under a data processing agreement.
• "KYC" — Know Your Customer verification procedures, including identity document submission and verification, required before processing withdrawals or complying with anti-money laundering obligations.
• "Cookies" — Small data files placed on your device by the Platform to enable functionality, personalisation and usage analysis.
• "Platform" — The hm99 website at https://hm99.cam and all associated subdomains, mobile-optimised interfaces and services.
• "Account" — A registered user profile created on the Platform.

03 Data We Collect

hm99 collects personal data through various means during your interaction with the Platform. The categories of data collected are described below.

3.1 Registration & Account Data

When you create an Account, we collect:

• Full legal name
• Date of birth (for age verification)
• Email address
• Residential address (including city and country — e.g., Karachi, Lahore, Islamabad, Rawalpindi or elsewhere in Pakistan)
• Username and encrypted password
• Phone number (where provided)

3.2 Identity Verification (KYC) Data

For withdrawal processing and compliance with anti-money laundering obligations, we may collect:

• Government-issued identification documents (e.g., Pakistani CNIC, passport)
• Proof of address documentation
• Proof of payment method ownership (e.g., screenshot of wallet or bank account in your name)
• Selfie or liveness check data where required by the KYC provider

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts in PKR or other supported currencies
• Payment method identifiers (e.g., last four digits of a card, or wallet ID for services such as Easypaisa or JazzCash — referenced as context only)
• Transaction timestamps and reference numbers
• Bonus redemption history and wagering records

3.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system and browser version
• Session duration, pages visited and features used
• Referring URL and search terms used to reach the Platform
• Error logs and performance diagnostics

3.5 Communications Data

• Content of support chat transcripts and emails you send to our team
• Survey responses and feedback submitted voluntarily
• Records of marketing preference selections (opt-in / opt-out)

04 Legal Basis for Processing

hm99 processes personal data on the following legal bases, applied as appropriate to each specific processing activity:

05 How We Use Your Data

hm99 uses the personal data collected for the following purposes:

• Account Services: Creating, managing and securing your registered Account, including authentication, password recovery and session management.
• Transaction Processing: Facilitating PKR deposits and withdrawals through available payment channels. Payment method names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are used here as context for Pakistani users only — their mention does not imply these providers endorse or process gambling transactions.
• Identity Verification: Conducting KYC and AML checks as required by applicable law and operator licensing conditions prior to processing withdrawals.
• Customer Support: Responding to queries, resolving disputes and managing complaints submitted via live chat or email.
• Responsible Gambling: Monitoring usage patterns to identify potential problem gambling behaviour and applying self-exclusion, limit-setting or account restriction tools where appropriate.
• Legal Compliance: Meeting obligations under applicable anti-money laundering, counter-terrorism financing, data protection and gambling regulation requirements.
• Platform Improvement: Analysing aggregated usage data to improve navigation, feature design and overall user experience.
• Marketing (with consent only): Sending promotional offers, bonus notifications and relevant updates to users who have opted in to marketing communications.
• Fraud & Security: Detecting, investigating and preventing fraudulent activity, multi-accounting, bonus abuse and other prohibited conduct.

06 Data Sharing & Third Parties

hm99 does not sell, rent or trade personal data to third parties for commercial purposes. We may share data only in the following circumstances:

• Payment Processors: Transaction data is shared with payment service providers to facilitate deposits and withdrawals. These providers operate under their own privacy and security standards.
• KYC & AML Providers: Identity verification data is shared with regulated KYC service providers to fulfil legal obligations. These providers are contractually bound to process data only for verification purposes.
• Technology Partners: Technical service providers (hosting, analytics, platform infrastructure) may access data as Data Processors under contractual data processing agreements with hm99.
• Regulatory & Legal Authorities: Data may be disclosed to competent authorities, regulators or law enforcement agencies where required by applicable law, court order or regulatory obligation — without requiring your prior consent.
• Business Transfers: In the event of a merger, acquisition or sale of hm99's business or assets, personal data may be transferred to the successor entity, subject to equivalent privacy protections.

All third-party processors engaged by hm99 are required to maintain appropriate data security standards and are prohibited from using personal data for purposes beyond those specified in their processing agreement with hm99.

07 Data Retention

hm99 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Active Accounts: Personal data is retained for the duration of your active Account relationship with hm99.
• Closed Accounts: Following Account closure, data is typically retained for a minimum of five (5) years for AML, legal compliance and dispute resolution purposes, or longer if required by applicable law.
• KYC Documents: Identity verification documents are retained for the period required by applicable AML regulations, which may extend beyond Account closure.
• Transaction Records: Financial transaction data is retained for a minimum of five (5) years to meet accounting, tax and regulatory requirements.
• Marketing Data: Marketing preference records are retained until you withdraw consent or close your Account, after which they are deleted promptly.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

08 Security Measures

hm99 implements a range of technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration or destruction:

• SSL/TLS Encryption: All data transmitted between your device and hm99 servers is encrypted using industry-standard TLS protocols.
• Access Controls: Access to personal data within hm99's systems is restricted to authorised personnel on a need-to-know basis, with role-based permissions enforced.
• Password Security: Account passwords are stored in a hashed and salted format. hm99 does not store plaintext passwords and cannot retrieve your password — only reset it through verified procedures.
• Monitoring: Platform systems are subject to ongoing security monitoring to detect anomalous activity, intrusion attempts and data integrity issues.
• Vendor Security: Third-party data processors are required to demonstrate appropriate security standards before being engaged by hm99.

09 Cookies & Tracking Technologies

hm99 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the site. We use the following categories of cookies:

You can manage or delete cookies through your browser settings at any time. Disabling non-essential cookies may affect certain Platform features. Continued use of the Platform following acknowledgement of this Policy constitutes acceptance of essential cookie usage.

10 International Data Transfers

hm99 operates internationally, and your personal data may be transferred to, stored in and processed in countries other than your country of residence, including countries outside Pakistan. Where personal data is transferred internationally, hm99 takes steps to ensure that appropriate safeguards are in place, such as contractual data protection agreements with receiving parties.

Pakistan does not currently have a comprehensive data protection law equivalent to international standards such as the GDPR; however, hm99 applies data processing principles aligned with internationally recognised privacy standards for the benefit of all users, including Pakistani players in cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.

11 Your Rights as a Data Subject

Subject to applicable law and any overriding legal obligations (such as AML retention requirements), you hold the following rights with respect to your personal data held by hm99:

To exercise any of the above rights, please contact hm99 at the email address listed in Section 14. We will respond to valid requests within a reasonable timeframe and in any event within 30 days, unless an extension is required and communicated to you.

hm99 may be required to verify your identity before processing a data subject request to prevent unauthorised disclosure.

12 Minors & Age Restrictions

hm99 is strictly for adults aged 18 or older — or the higher minimum age required by the applicable Operator or license jurisdiction. The Platform does not knowingly collect personal data from persons under the applicable minimum age. If hm99 becomes aware that personal data has been collected from a minor, that data will be deleted immediately and the associated Account will be closed.

Parents and guardians who believe that a minor in their care has registered on hm99 should contact support immediately at the address in Section 14.

13 Amendments to This Policy

hm99 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, data processing practices or Platform functionality. Material amendments will be communicated to registered users via email or a prominent notice on the Platform before taking effect, where reasonably practicable.

The Effective Date at the top of this document indicates when the current version was last updated. Continued use of the Platform following the effective date of any amended Policy constitutes your acceptance of those changes.

The most current version of this Privacy Policy is always available at https://hm99.cam/privacy-policy.

14 Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or hm99's data processing practices, please contact our support team using the details below. When contacting us about a data subject request, please include your registered username and a clear description of your request.

Support Email: [email protected]

Live Chat: Available via the Platform during operational hours. Response times for data-related requests may be longer than standard support queries — we will acknowledge your request within 5 business days.

hm99 does not have a designated Data Protection Officer (DPO) listed publicly at this time. All privacy-related correspondence should be directed to the support email address above, clearly marked as a data privacy enquiry.