Privacy Policy — How bn33 Collects, Uses & Protects Your Personal Data

This Privacy Policy ("Policy") applies to all personal data collected by, processed by, or on behalf of bn33 ("we," "us," or "our") in connection with the operation of the bn33 online gaming platform, accessible at bn33.bid ("the Platform"). This Policy covers data collected from all individuals who interact with the Platform, including registered players, prospective players who browse without registering, and individuals who contact our support team.

bn33 is committed to handling personal data responsibly and transparently, in accordance with the privacy obligations imposed by our international gaming license and applicable data protection principles. This Policy is designed to be read and understood by a general audience — we have written it in clear, plain English without unnecessary legal complexity, while still satisfying our formal disclosure obligations.

By registering an account, accessing the Platform, or submitting any personal information to bn33, you acknowledge that you have read and understood this Policy and that you consent to the data practices described herein. If you do not agree to these practices, please do not use the bn33 Platform.

For the purposes of this Policy, bn33 acts as the data controller in respect of all personal data collected through the Platform. As data controller, bn33 determines the purposes for which personal data is collected and the manner in which it is processed.

Where bn33 engages third-party processors — such as KYC verification providers, payment processors, or analytics platforms — to process personal data on our behalf, we require those processors to handle data only in accordance with our instructions, this Policy, and applicable data protection requirements. bn33 remains responsible for ensuring that such processors provide appropriate data protection guarantees.

All data-related enquiries, access requests, correction requests, and deletion requests should be directed to the bn33 support team via live chat or by email as specified in Section 16.

bn33 collects the following categories of personal data in the course of providing our services to Pakistani players and other users of the Platform:

3.1 Registration & Account Data

3.2 KYC & Identity Verification Data

Before processing any withdrawal, bn33 is required by its licensing obligations to carry out Know Your Customer (KYC) verification. This may involve collecting:

• CNIC (Computerised National Identity Card) number and copy
• Proof of address (such as a utility bill or bank statement issued within the last three months)
• Selfie photograph or live facial recognition data where required by our verification provider
• Source-of-funds documentation where transactions exceed regulatory thresholds

3.3 Financial & Transaction Data

We collect records of all deposits, withdrawals, and gaming transactions associated with your account, including payment method identifiers (such as JazzCash account number or bank account ending digits), transaction amounts in PKR, timestamps, and transaction status. Full payment credentials — such as complete bank account numbers or wallet PINs — are never stored by bn33 directly; payment processing is handled by regulated third-party payment processors.

3.4 Technical & Usage Data

When you access the bn33 Platform, we automatically collect certain technical data, including: IP address, device type and operating system, browser type and version, session duration and timestamps, pages and games accessed, and error or crash logs. This data is used for security monitoring, fraud prevention, and platform optimisation.

3.5 Communications Data

We retain records of all communications you initiate with the bn33 support team, including live chat transcripts, email correspondence, and any documentation you submit in connection with a complaint or account query. These records are retained to ensure continuity of support and for dispute resolution purposes.

bn33 collects personal data through the following mechanisms:

• Directly from you — when you complete the registration form, submit KYC documents, initiate a deposit or withdrawal, or contact our support team.
• Automatically during Platform use — through server logs, session management cookies, and analytics tools that record your interaction with the Platform.
• From third-party KYC providers — when we commission identity and age verification checks, our licensed verification provider may return enriched identity data (such as a confirmed date of birth or name match score) to us based on the CNIC information you have submitted.
• From payment processors — payment processors such as JazzCash and EasyPaisa may confirm transaction status and basic account holder details to facilitate payment reconciliation.
• From fraud prevention services — we may receive risk signals from fraud prevention and anti-money laundering screening services based on transaction patterns or device fingerprinting results.

bn33 processes personal data on the following legal bases:

• Contractual necessity: Processing required to create and manage your account, process deposits and withdrawals, settle bets, and provide the gaming services you have requested. Without this processing, we cannot deliver the Platform services.
• Legal obligation: Processing required to fulfil our obligations under our international gaming license, including KYC verification, anti-money laundering checks, age verification, and record-keeping mandated by the licensing authority.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and technical analytics, where such processing does not override your fundamental privacy rights.
• Consent: Where we send promotional communications, we rely on your consent. You may withdraw consent for marketing communications at any time by contacting support or updating your Account notification preferences.

The personal data collected by bn33 is used exclusively for the following purposes:

• Account creation and management: Setting up and maintaining your bn33 Account, authenticating your identity at login, and enabling account self-service functions including password reset and contact detail updates.
• Service delivery: Processing bets, settling gaming outcomes, crediting winnings, processing deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other supported PKR methods, and delivering bonus promotions where applicable.
• Identity and age verification: Confirming that you are at least 21 years of age and that your identity documents are genuine, as required by our licensing obligations.
• Fraud prevention and anti-money laundering compliance: Monitoring transactions and account behaviour for indicators of fraud, money laundering, or other prohibited activities, and reporting suspicious activity to relevant authorities where legally required.
• Customer support: Responding to your queries, resolving disputes, and maintaining a record of communications for quality assurance and continuity purposes.
• Platform security: Detecting and preventing unauthorised access to accounts, identifying duplicate accounts, and maintaining the integrity of the Platform.
• Responsible gaming: Monitoring gaming patterns where self-imposed limits or responsible gaming alerts have been activated, and identifying accounts that may exhibit signs of problem gambling requiring intervention.
• Legal and regulatory compliance: Maintaining records as required by our gaming license and responding to lawful requests from regulatory authorities or law enforcement agencies.
• Marketing communications (consent-based): Sending promotional offers, bonus notifications, and Platform updates where you have consented to receive such communications via SMS or email.

bn33 does not sell, rent, or trade personal data to third parties for commercial purposes. We share personal data with third parties only in the following defined circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers receive the minimum personal data necessary to process your deposit or withdrawal request. These providers operate under their own privacy policies and are regulated by applicable financial authorities.
• KYC and identity verification providers: Regulated third-party verification services receive your identity document data for the purpose of confirming your age, identity, and the authenticity of submitted documents. These providers are bound by contractual confidentiality obligations and applicable data protection requirements.
• Fraud prevention services: Anonymised or pseudonymised transaction and device data may be shared with licensed fraud detection services to identify risk patterns. These services do not receive your full identity data without specific justification.
• Game software providers: Where games are provided by third-party studios such as Pragmatic Play, Evolution Gaming, or Ezugi, minimal session data (such as a pseudonymised player identifier and stake amount) is shared with the relevant studio solely for the purpose of delivering and settling the game.
• Regulatory authorities and law enforcement: Where required by law, court order, or formal request from a competent regulatory authority, bn33 will disclose personal data without prior notice to the player concerned. We will notify you of such disclosures where permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of bn33's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the acquiring entity's privacy practices before your data is transferred.

As an internationally licensed gaming platform, bn33's infrastructure — including servers, data centres, and third-party processing systems — may be located in jurisdictions outside Pakistan. This means that personal data relating to Pakistani players may be transferred to and processed in countries that have different data protection frameworks from those currently applicable in Pakistan.

Where personal data is transferred internationally, bn33 ensures that appropriate safeguards are in place to protect such data to a standard consistent with this Policy. These safeguards may include contractual clauses with data recipients, ensuring the recipient jurisdiction maintains adequate data protection standards, or relying on specific exemptions applicable to cross-border data transfers in the context of international gaming operations.

By using the bn33 Platform, you acknowledge and consent to the transfer of your personal data to processing locations outside Pakistan as described in this Policy. If you would like further information about the specific safeguards in place for any such transfer, please contact the support team at the email address specified in Section 16.

bn33 retains personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law and licensing obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is either securely deleted or irreversibly anonymised so that it can no longer be associated with any identifiable individual. Anonymised data may be retained for statistical and analytical purposes without limitation.

bn33 uses cookies and similar tracking technologies on the Platform for the purposes described below. A cookie is a small text file that the Platform places on your device. Some cookies are essential for the Platform to function; others help us improve your experience or monitor security. bn33 does not use advertising cookies or allow third-party advertisers to place cookies through the Platform.

Most browsers allow you to control cookie settings through the browser preferences menu. Blocking essential cookies will impair your ability to use the bn33 Platform. Blocking analytics or preference cookies will not prevent you from gaming but may affect your experience.

bn33 implements a comprehensive set of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your device and the bn33 servers is encrypted using TLS 1.3 with 256-bit AES encryption — equivalent to the standard used by major Pakistani banks.
• Encryption at rest: Sensitive personal data stored in bn33's databases — including identity documents, CNIC information, and financial records — is encrypted at rest using industry-standard encryption protocols.
• Password security: Passwords are never stored in plain text. bn33 uses industry-standard cryptographic hashing with salting for all stored password data, meaning that even bn33 staff cannot view your password.
• Access controls: Access to personal data within bn33's internal systems is restricted to personnel whose role requires it, governed by a least-privilege access control policy. Access logs are maintained and audited regularly.
• Two-factor authentication: SMS OTP-based two-factor authentication is available for all player accounts and is required for high-risk actions such as withdrawal processing and mobile number changes.
• Penetration testing: The Platform undergoes periodic independent security assessments including penetration testing and vulnerability scanning to identify and remediate weaknesses before they can be exploited.
• Data breach response: bn33 maintains an incident response procedure for data breaches. In the event of a breach that is likely to result in high risk to affected players, bn33 will notify affected players as soon as reasonably practicable and will take immediate steps to contain and remediate the breach.

Subject to applicable law and our obligations under our gaming license, you have the following rights in relation to the personal data that bn33 holds about you:

To exercise any of these rights, contact the bn33 support team via live chat or at the email address specified in Section 16. We will respond within a reasonable period (and in any event within 30 days) and at no charge to you. We may need to verify your identity before processing any request.

The bn33 Platform is strictly restricted to individuals who are at least 21 years of age. bn33 does not knowingly collect personal data from individuals under the age of 21. Age verification is performed at registration and confirmed as part of the KYC process before any withdrawal is authorised.

If bn33 becomes aware that personal data has been collected from an individual who is under 21 years of age, we will immediately close the associated account, delete all personal data collected from that individual to the maximum extent permitted by law, and return any deposited funds to the originating payment method. We will also take reasonable steps to prevent re-registration by the same individual.

As part of our responsible gaming obligations, bn33 uses certain personal data — specifically gaming behaviour data including session duration, bet frequency, stake levels, and deposit patterns — for the purpose of identifying accounts that may exhibit signs of problem gambling. This processing is carried out as a legitimate interest of bn33 and as a requirement of our gaming license, and is designed to protect players rather than to disadvantage them.

Where responsible gaming tools are activated by a player (including deposit limits, session alerts, cool-off periods, or self-exclusion), the associated processing records are retained for the duration specified in Section 9 to ensure the effectiveness of those tools and to prevent circumvention. Self-exclusion data is particularly sensitive and is handled with strict access controls.

If you voluntarily share information about a gambling problem when contacting the bn33 support team, that information may be used internally to ensure appropriate care is provided. It will not be disclosed to third parties without your explicit consent, except where required by law. For further information about responsible gaming tools available at bn33, please visit our Responsible Gaming page.

bn33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or our gaming license requirements. The "Last Reviewed" date at the top of this document will be updated each time the Policy is revised.

Where changes are material — meaning they significantly affect your rights, the categories of data we collect, or the purposes for which we use your data — we will provide advance notice via SMS to your registered Pakistani mobile number and by posting a prominent notice on the Platform prior to the effective date of the change. For non-material amendments such as typographical corrections or minor clarifications, changes take effect upon publication without prior notice.

Continued use of the bn33 Platform following the effective date of any policy amendment constitutes your acceptance of the revised Policy. If you do not agree to a revised Policy, you should close your Account in accordance with the process described in the bn33 Terms & Conditions.

All privacy-related queries, data subject rights requests, and concerns regarding this Privacy Policy should be directed to the bn33 support team. We are committed to responding to all data-related enquiries promptly and professionally.

Preferred contact method: Live chat available 24/7 from within your bn33 account. Live chat is the fastest route to a response for all privacy queries.

Email: [email protected] — please include "Privacy Request" in your subject line, along with your registered mobile number, so that we can verify your identity and respond to your specific request efficiently.