Privacy Policy

1.1  ub999 ("we", "us", "our", "the Operator") operates the online casino and sports betting information platform accessible at https://ub999.cam ("the Platform"). We are committed to protecting and respecting the privacy of every individual who uses our Platform, including users located in Pakistan and elsewhere.

1.2  This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you — or that you provide to us — will be processed. "Personal data" means any information that identifies you or could reasonably be used to identify you as an individual.

1.3  This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy. By using the Platform, you acknowledge that you have read this Policy and understand how your data will be handled.

1.4  ub999 does not hold a Pakistan gambling license and does not claim authorisation or endorsement from the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan or any Pakistani regulatory authority. This Policy does not constitute legal advice under Pakistani law. Users are responsible for understanding all applicable local legal obligations.

2.1  The following terms carry the meanings set out below throughout this Policy:

3.1  ub999 acts as the Data Controller for all personal data collected through the Platform. As Data Controller, we are responsible for determining how your personal data is collected and for what purposes it is used.

3.2  Where we engage third-party service providers — such as payment processors, KYC verification providers, analytics services or fraud detection systems — those providers act as Data Processors under contractual obligations that require them to process your data only as instructed by us and to implement appropriate security measures.

3.3  Queries regarding our data controller status or processing activities may be directed to our support team using the contact information set out in Section 16.

4.1  We collect personal data in several ways depending on how you interact with the Platform. The categories of data we collect are summarised in the table below:

5.1  We use the personal data we collect for the following specific purposes:

• Account management: To create, verify, maintain and administer your ub999 account, including processing registrations and authentication.
• Transaction processing: To process deposits, withdrawals, bonus credits and any other financial transactions carried out through the Platform.
• Identity verification (KYC/AML): To verify your identity and age in compliance with applicable Know Your Customer and Anti-Money Laundering obligations.
• Customer support: To respond to your queries, complaints and requests submitted via live chat, email or any other support channel. Support is available in English and Urdu.
• Legal and regulatory compliance: To meet obligations imposed by applicable law, including record-keeping, regulatory reporting and fraud prevention.
• Security and fraud prevention: To detect, investigate and prevent unauthorised access, fraudulent transactions, bonus abuse and other prohibited activity.
• Platform improvement: To analyse usage patterns, identify technical issues, and improve the functionality and content of the Platform.
• Responsible gambling: To monitor play behaviour in support of responsible gambling obligations, including flagging potential at-risk patterns and applying player-imposed limits.
• Marketing communications: To send you promotional information about ub999 offers, bonuses and updates where you have consented to receive such communications. You may withdraw consent at any time.

5.2  We will not use your personal data for any purpose materially different from those listed above without providing prior notice and, where legally required, obtaining your consent.

6.1  Where applicable data protection law requires the Operator to identify a legal basis for processing personal data, we rely on one or more of the following:

• Contractual necessity: Processing required to fulfil the account agreement between you and ub999 — for example, processing deposits or verifying your identity before a withdrawal.
• Legal obligation: Processing required to comply with applicable law — for example, retaining KYC documents and transaction records to satisfy AML regulatory requirements.
• Legitimate interests: Processing that serves ub999's legitimate business interests where those interests are not overridden by your fundamental rights — for example, fraud detection, security monitoring and platform analytics.
• Consent: Processing that requires your explicit, freely given consent — primarily marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7.1  ub999 does not sell, rent or trade your personal data. We may share personal data with third parties only in the circumstances described below:

• KYC and identity verification providers: We engage licensed third-party identity verification services to process identity documents and perform liveness checks. These providers act as Data Processors under strict contractual controls.
• Payment processors: Transaction data is shared with payment service providers to the extent necessary to process your deposit or withdrawal request. Payment provider names referenced on the Platform (including those familiar to Pakistani users) are contextual and do not imply those providers endorse gambling.
• Fraud prevention and AML services: We may share data with fraud detection platforms, credit reference agencies or AML compliance services where required to meet our legal obligations.
• Analytics and performance services: Aggregated or pseudonymised usage data may be shared with analytics providers to help improve Platform performance. Such data does not identify you individually.
• Legal and regulatory authorities: We will disclose personal data to law enforcement, regulatory bodies or courts where required to do so by applicable law, court order or regulatory demand — including where our licensing authority requires disclosure.
• Business transfers: In the event of a merger, acquisition or sale of all or part of the Operator's business, personal data may be transferred to the acquiring entity as part of that transaction, subject to the same privacy protections.

7.2  All third-party Data Processors engaged by ub999 are required by contract to implement appropriate technical and organisational security measures and to process personal data only in accordance with our documented instructions.

8.1  As an international platform, ub999 may transfer personal data to and process it in countries outside your country of residence, including countries outside Pakistan. Where such transfers occur, we implement safeguards appropriate to the applicable data protection framework.

8.2  Such safeguards may include standard contractual clauses, binding corporate rules, adequacy decisions or other transfer mechanisms recognised under applicable data protection law.

8.3  Pakistani users should be aware that Pakistan's data protection regulatory framework may differ from those of other jurisdictions. Our practices are designed to meet international standards consistent with the Operator's licensing jurisdiction obligations.

9.1  ub999 uses cookies and similar tracking technologies to operate the Platform efficiently and to enhance user experience. The categories of cookies we use are as follows:

• Strictly necessary cookies: Required for the Platform to function. They enable session management, login authentication and security features. These cannot be disabled without impacting platform functionality.
• Functional cookies: Store your preferences such as language settings, interface options and responsible gambling limit configurations so you do not need to re-enter them on each visit.
• Analytical cookies: Collect pseudonymised usage data — such as pages visited, session duration and error logs — to help us understand how the Platform is used and where improvements can be made.
• Marketing cookies: Used where you have consented to receive personalised promotional content. Marketing cookies may track browsing behaviour across sessions.

9.2  On your first visit to the Platform, you will be presented with a cookie consent notice. You may accept or decline non-essential cookies. Strictly necessary cookies are deployed without consent as they are required for Platform operation. You may also manage cookie settings through your browser's privacy controls at any time.

10.1  We retain personal data only for as long as is necessary for the purposes described in this Policy or as required by applicable law. The following general retention principles apply:

• Active account data: Retained for the duration of your registered account and for a defined period following account closure, as required by our licensing and AML obligations.
• KYC and identity documents: Retained for the period required by applicable AML regulations following the closure or last activity of an account — typically a minimum of five years, though specific retention obligations depend on the applicable regulatory framework.
• Transaction records: Financial transaction data is retained as required by applicable anti-money laundering and financial record-keeping legislation.
• Support communications: Retained for a reasonable period following the resolution of a query or complaint, to allow for review and escalation where required.
• Marketing data: Retained until you withdraw consent for marketing communications or request deletion, subject to any overriding legal obligations.

10.2  Personal data that is no longer required and for which no legal retention obligation exists is securely deleted or anonymised so that it can no longer be linked to an individual Data Subject.

11.1  Subject to applicable data protection law and any overriding legal obligations, you have the following rights in respect of your personal data. You may exercise any of these rights by contacting our support team as described in Section 16.

12.1  The Platform is strictly intended for adults aged 18 or older — or the higher minimum age required under the Operator's license jurisdiction. We do not knowingly collect or process personal data from minors.

12.2  If we become aware that we have inadvertently collected personal data from an individual under the applicable minimum age, we will immediately take steps to delete that data and close any associated account.

12.3  If you believe a minor may have registered on the Platform, please contact us immediately using the details in Section 16.

13.1  ub999 implements technical and organisational security measures appropriate to the sensitivity of the personal data we process. These measures include, but are not limited to:

• Transport Layer Security (TLS): All data in transit between your device and ub999 servers is encrypted using current TLS protocols.
• Encryption at rest: Sensitive stored data — including identity documents and payment details — is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to personal data is restricted to authorised personnel on a need-to-know basis. All access is logged and subject to periodic review.
• Two-factor authentication (2FA): Available to all users for account login. We strongly encourage all registered users to enable 2FA to protect their account data.
• Regular security assessments: The Platform undergoes periodic security reviews and vulnerability assessments to identify and remediate potential weaknesses.

13.2  Notwithstanding these measures, no method of electronic transmission or storage is completely secure. We cannot guarantee the absolute security of data transmitted over the internet, and any transmission is at your own risk. You are responsible for maintaining the confidentiality of your login credentials.

14.1  ub999 is an English-language platform that serves users including those based in cities across Pakistan — Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We are aware that Pakistani users interact with our Platform in the context of a unique legal and regulatory environment.

14.2  Pakistan has gambling restrictions including the Prevention of Gambling Act, 1977. ub999 does not hold a Pakistani gambling license and is not approved, regulated or endorsed by the Government of Pakistan, the PTA, the State Bank of Pakistan, or any Pakistani provincial authority. This Privacy Policy is not a representation that use of the Platform is lawful in Pakistan. Users must independently assess their obligations under all applicable Pakistani law. This is not legal advice.

14.3  Payment references commonly known to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — may appear in transaction-related personal data fields as contextual identifiers. Their presence does not represent an endorsement of, affiliation with, or support for gambling by those providers.

14.4  Pakistani data protection regulation is subject to ongoing legislative development. We monitor changes to applicable Pakistani law and will update our practices where those changes affect how we handle Pakistani users' personal data.

15.1  We may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law or regulatory guidance. When we make material changes, we will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect.

15.2  The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how your personal data is protected.

15.3  Your continued use of the Platform following the publication of an updated Policy constitutes your acknowledgment of the revised terms. If you do not agree with any amendment, you should discontinue your use of the Platform and may request account closure.

16.1  To exercise any of your data subject rights, to raise a concern about our data processing practices, or to ask any question about this Privacy Policy, please contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the Platform interface. Support agents are available in English and Urdu.
• Email (plain text — not a link): [email protected]

16.2  When submitting a data subject rights request, please include: your full registered name, your registered email address, and a clear description of the right you wish to exercise (e.g., access, rectification, erasure). We may ask you to verify your identity before acting on any request.

16.3  We will endeavour to respond to all data subject rights requests within a reasonable timeframe in accordance with applicable law.