fly99 Privacy Policy

1. Data Controller

For the purposes of this Privacy Policy, fly99 (referred to throughout as "fly99", "we", "us", or "our") is the data controller responsible for your personal information. fly99 operates the online casino and sports betting platform accessible at fly99.games and is the entity that determines the purposes and means by which your personal data is processed.

If you have any questions about how fly99 handles your data, or wish to exercise any of the rights described in this Policy, you may contact our dedicated data protection support team at [email protected]. We aim to acknowledge all privacy-related enquiries within 5 business days.

2. Personal Data We Collect

fly99 collects personal data in the following categories. We collect only what is necessary for the purposes described in this Policy.

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, CNIC / passport number, photograph	Account registration, KYC verification, age confirmation
Contact Data	Email address, mobile number, residential address (city, province)	Account communications, support, regulatory correspondence
Financial Data	JazzCash / EasyPaisa account number, bank account details (HBL, UBL, Meezan Bank), transaction history, deposit and withdrawal records	Payment processing, fraud prevention, AML compliance
Technical Data	IP address, device type, browser type and version, operating system, session tokens	Platform security, fraud detection, session management
Usage Data	Games played, bets placed, session duration, pages visited, feature interactions	Platform improvement, personalisation, responsible gaming monitoring
Communications Data	Support chat transcripts, emails sent to fly99, feedback submissions	Customer support quality, dispute resolution, compliance records

3. How We Collect Your Data

3.1 Directly From You

The majority of the personal data fly99 holds about you is information that you provide to us directly, including:

• During the account registration process — name, date of birth, email, and mobile number.
• When completing KYC verification — identity documents and proof of address.
• When making a deposit or withdrawal — payment method details and transaction confirmations.
• When contacting our customer support team via live chat or email.
• When responding to surveys, promotions, or providing feedback about fly99.

3.2 Automatically Through Platform Use

When you access and use fly99, we automatically collect certain technical and usage data through cookies, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser configuration, pages visited, and the sequence of actions you take within the platform. This data is collected to ensure platform security, detect fraudulent behaviour, and improve service quality.

3.3 From Third-Party Sources

In certain circumstances, fly99 may receive personal data about you from third parties, including:

• Payment providers such as JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, who may confirm transaction status or flag suspicious activity.
• Identity verification services used to cross-check the documents you submit during KYC.
• Fraud prevention and AML screening services used to assess the risk profile of account activity.
• Publicly available sources such as government sanction lists or politically exposed persons (PEP) databases, where required for compliance.

4. How We Use Your Personal Data

fly99 uses the personal data it collects for the following purposes:

• Account management: Creating and maintaining your fly99 account, verifying your identity, and providing you access to the platform's full range of services.
• Payment processing: Facilitating deposits and withdrawals via your chosen payment method in PKR, confirming transaction completions, and resolving payment disputes.
• Regulatory compliance: Meeting our obligations under our international gaming license, including KYC, anti-money laundering (AML), and counter-terrorist financing (CTF) requirements.
• Fraud and security: Detecting, investigating, and preventing fraudulent account activity, unauthorised access, bonus abuse, and any other activity that may violate these Terms or applicable law.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling behaviour, enforcing self-exclusion requests, and managing deposit and session limits set by players.
• Customer support: Responding to your enquiries, resolving disputes, and maintaining records of support interactions for quality assurance.
• Platform improvement: Analysing aggregated usage data to understand how players interact with fly99, identify areas for improvement, and develop new features and games.
• Marketing communications: Sending you information about promotions, bonuses, and new games at fly99 — but only where you have opted in to receive such communications. You may opt out at any time.

5. Legal Basis for Processing

fly99 processes your personal data under the following legal bases:

• Performance of a contract: Processing your registration data, payment information, and gameplay records is necessary to fulfil our contractual obligations to you as a fly99 player.
• Legal obligation: KYC, AML, and CTF data processing is required to comply with the conditions of fly99's international gaming license and applicable financial regulations.
• Legitimate interests: Technical and usage data processing for fraud prevention, platform security, and service improvement is carried out under fly99's legitimate business interests, provided those interests are not overridden by your rights.
• Consent: Marketing communications and non-essential cookies are only used where you have given explicit, freely-given, and withdrawable consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

fly99 does not sell your personal data. We share your data only in the following limited circumstances, and only to the extent strictly necessary for the stated purpose:

6.1 Service Providers

fly99 engages trusted third-party service providers who process data on our behalf under strict contractual data processing agreements. These include payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank), identity verification providers, cloud infrastructure providers, and customer support software vendors. All service providers are prohibited from using your data for their own independent purposes.

6.2 Game Software Providers

Third-party game developers whose titles are hosted on fly99 may receive pseudonymised session and gameplay data necessary for game functionality, RNG certification, and payout calculation. These providers do not receive your name, contact details, or payment information.

6.3 Regulatory and Law Enforcement Authorities

fly99 may disclose your personal data to regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or in connection with our international gaming license obligations. We will notify you of such disclosures where legally permitted to do so.

6.4 Fraud Prevention and AML Screening

fly99 uses third-party fraud detection and AML screening services. Certain data points — such as transaction amounts, IP addresses, and device fingerprints — may be shared with these services to assess risk and detect suspicious activity.

7. Data Retention

fly99 retains your personal data only for as long as is necessary for the purposes for which it was collected, and in accordance with our legal and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account plus a minimum of 5 years following account closure, as required under gaming licensing and AML regulations.
• Transaction and financial records: Retained for a minimum of 5 years from the date of the transaction, in line with financial record-keeping requirements.
• Support communications: Retained for 3 years from the date of the interaction, or longer where relevant to an unresolved dispute or legal claim.
• Technical and usage data (logs): Typically retained for 12 months, after which they are aggregated and anonymised.
• Marketing consent records: Retained for the period of your consent, plus 2 years thereafter as evidence of compliance.

When your data is no longer required, it is securely deleted or irreversibly anonymised. Where deletion is not immediately possible due to technical backup constraints, the data is isolated and protected from further active processing until deletion is feasible.

8. Data Security

fly99 implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, loss, disclosure, alteration, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption on all data transmitted between your device and fly99 servers.
• Encrypted storage of all sensitive data including passwords (hashed using industry-standard algorithms), payment credentials, and identity documents.
• Role-based access controls ensuring that only authorised fly99 personnel with a legitimate operational need can access player data.
• Regular security audits and penetration testing conducted by independent third-party security specialists.
• Fraud detection systems monitoring account activity in real time for anomalous patterns.
• Secure data centres with physical access controls, redundant systems, and disaster recovery protocols.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that affects your rights and freedoms, fly99 will notify affected players without undue delay and take all reasonable steps to contain and remediate the incident.

You are also responsible for maintaining the security of your fly99 account. Use a strong, unique password, do not share your login credentials, and contact us immediately at [email protected] if you suspect unauthorised access.

9. Your Data Rights

As a fly99 player, you have the following rights regarding your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within 30 days of receiving a verified request.

• Right of Access: You may request a copy of all personal data fly99 holds about you, together with information about how it is being used.
• Right to Rectification: If any personal data fly99 holds about you is inaccurate or incomplete, you have the right to request that it be corrected.
• Right to Erasure: You may request that fly99 delete your personal data in certain circumstances — for example, where it is no longer necessary for the purpose it was collected. Note that this right is subject to fly99's legal data retention obligations, which may require us to retain certain records even after an account is closed.
• Right to Restrict Processing: In certain circumstances you may request that fly99 restrict the active processing of your data — for example, while a correction request is being assessed.
• Right to Data Portability: Where processing is based on your consent or a contract, and carried out by automated means, you may request that your data be provided to you in a structured, machine-readable format.
• Right to Object: You may object to processing carried out under fly99's legitimate interests, including direct marketing. Where you object to marketing communications, we will stop immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

10. Cookies & Tracking Technologies

fly99 uses cookies and similar tracking technologies to operate the platform effectively and to improve the experience for Pakistani players. The following types of cookies are in use:

• Strictly Necessary Cookies: Essential for platform functionality. These include session cookies that keep you logged in during your visit and security tokens that protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use fly99 — such as which pages are most visited and how long sessions last. This data helps us improve the platform. Analytics cookies require your consent.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming limit configurations. These improve your experience but are not strictly essential.

fly99 does not use advertising cookies, third-party tracking pixels, or any cookies that enable cross-site behavioural tracking for commercial purposes. When you first visit fly99, you will be presented with a cookie consent notice. You can manage or withdraw your cookie preferences at any time through the cookie settings panel accessible from the platform footer.

11. Minors & Age Restrictions

fly99 is strictly prohibited for individuals under the age of 21. We do not knowingly collect personal data from anyone under 21 years of age. If fly99 discovers or has reasonable grounds to suspect that personal data has been collected from a person under 21, that account will be immediately suspended, all associated data reviewed, and the account permanently closed in accordance with our age verification and responsible gaming policies.

fly99 employs age verification checks at the point of registration and during KYC. Players who cannot produce satisfactory proof of age will not be permitted to deposit, wager, or withdraw funds. This is a non-negotiable requirement that applies to all players regardless of location within Pakistan, including Karachi, Lahore, Islamabad, Faisalabad, and all other cities.

12. Amendments to This Policy

fly99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform services. When material changes are made, we will notify registered players via email and/or through a prominent notice on the fly99 platform prior to the changes taking effect.

The effective date of the current version of this Policy is stated at the top of this document. Your continued use of fly99 following the effective date of any amendment constitutes your acknowledgement of the updated Policy. We encourage you to review this page periodically to stay informed about how fly99 protects your data.

13. Contact & Privacy Enquiries

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact the fly99 data protection team through the following channel:

Email: [email protected]

Please include "Privacy Enquiry" or "Data Rights Request" in the subject line of your email so that our team can route your message to the correct department. We aim to acknowledge all privacy-related communications within 5 business days and to resolve substantive requests within 30 days.

Where you are not satisfied with fly99's response to a privacy concern, you may escalate the matter to the relevant supervisory authority under the jurisdiction of fly99's international gaming license. Details of the applicable authority are available upon request.