Privacy Policy — td99

This Privacy Policy ("Policy") describes how td99 ("td99", "Platform", "we", "us", "our") collects, uses, processes, stores, discloses and protects personal data belonging to individuals ("Users", "Players", "you") who visit or use the td99 online gambling and sports betting platform at https://td99.cam and any associated services ("Service").

td99 is committed to handling personal data responsibly and in accordance with applicable data protection legislation. By accessing or using the Service, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you must discontinue using the Service.

This Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the td99 Service. Where applicable laws impose additional requirements regarding the processing of personal data belonging to users in specific jurisdictions, those requirements shall supplement this Policy.

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, location data, online identifier or factors specific to that person.
• "Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this case, td99.
• "Data Processor" means an entity that processes personal data on behalf of the Data Controller.
• "Consent" means a freely given, specific, informed and unambiguous indication of agreement to the processing of personal data.
• "KYC Data" means identity verification documents and information collected during the Know Your Customer process, including identification documents, proof of address and payment method verification.
• "Cookies" means small text files stored on your device by a website to remember preferences, session data and analytical information.
• "Third Party" means any natural or legal person other than you and td99.

td99 acts as the Data Controller in respect of personal data collected through the Service. As Data Controller, td99 determines the purposes for which and the means by which personal data is processed.

In circumstances where td99 engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, cloud hosting services and analytics providers — those parties act as Data Processors under instructions from td99. td99 maintains data processing agreements with such processors to ensure appropriate safeguards are in place.

Where regulatory or law enforcement authorities lawfully request access to personal data, td99 may act as a disclosing party. In such cases, td99 will disclose only the minimum data required to fulfil its legal obligations.

4.1 Registration Data

When you create a td99 account, we collect information including your full legal name, date of birth, email address, contact telephone number, country of residence, username and account password (stored in hashed form).

4.2 KYC Verification Data

To comply with anti-money laundering requirements and age verification obligations, we may collect copies of government-issued identification (e.g., CNIC, passport, driving licence), proof of address documents (e.g., utility bill, bank statement) and documentation to verify ownership of payment methods used.

4.3 Financial and Transaction Data

We record all deposits, withdrawals, bets, wins and account transactions. We store payment method reference data necessary to process transactions — we do not store full card numbers or bank account credentials on our systems.

4.4 Technical and Usage Data

We automatically collect technical data when you use the Service, including your IP address, browser type and version, device type and operating system, pages visited, session duration, clickstream data and referring URL. This data is used for platform security, fraud prevention, performance analysis and service improvement.

4.5 Communications Data

If you contact our customer support team, we retain records of those communications, including the content of messages, timestamps and any resolution actions taken. This includes live chat transcripts, email correspondence and any support tickets raised.

4.6 Responsible Gambling Data

Where you use responsible gambling tools — such as deposit limits, self-exclusion or cooling-off requests — we retain records of these instructions to ensure they are properly applied and maintained throughout their active period and beyond.

td99 processes personal data only where a recognised lawful basis exists. The applicable bases are as follows:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under the Terms & Conditions, including account management, payment processing, bet settlement and customer support.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) regulations, age verification requirements and responses to lawful regulatory or law enforcement requests.
• Legitimate Interests: Processing conducted for td99's legitimate business interests — such as fraud prevention, platform security, service improvement and responsible gambling monitoring — where those interests are not overridden by your privacy rights.
• Consent: Where we rely on consent as a lawful basis (e.g., for certain marketing communications), we will obtain your explicit consent and you may withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

td99 uses the personal data it collects for the following purposes:

• Account creation and management: To register your account, authenticate your identity and manage your account settings and preferences.
• Service delivery: To process deposits, withdrawals and bets, deliver game content and provide access to all platform features.
• Identity and age verification: To comply with applicable KYC requirements and confirm that users meet the minimum age requirements for gambling.
• Fraud prevention and security: To detect and prevent fraudulent activity, money laundering, account takeover and other prohibited conduct.
• Responsible gambling: To monitor gambling behaviour for indicators of problem gambling and to administer tools such as deposit limits, loss limits, session timers and self-exclusion requests.
• Customer support: To respond to enquiries, resolve complaints and provide technical assistance.
• Legal and regulatory compliance: To meet our obligations under applicable laws, respond to regulatory requests and maintain required records.
• Platform improvement: To analyse usage patterns, identify technical issues and improve the functionality, design and performance of the Service.
• Marketing communications: Where you have provided consent, to send promotional emails, offers and platform updates. You may opt out at any time.

7.1 Service Providers

We share personal data with carefully selected third-party service providers who process data on our behalf and under our instructions. These include payment processing providers, identity verification services, cloud hosting and infrastructure providers, fraud detection platforms, customer support software providers and analytics services. All such providers are bound by data processing agreements requiring appropriate security and confidentiality measures.

7.2 Regulatory and Law Enforcement Bodies

td99 may disclose personal data to regulators, law enforcement agencies, financial intelligence units or other competent authorities where required or permitted by applicable law. Disclosures are made on a minimum necessary basis and, where lawful to do so, we will notify affected users.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or substantially all of td99's assets, personal data held by td99 may be transferred to the acquiring entity. Users will be notified of any such transfer that materially affects the terms of this Policy.

7.4 No Sale of Data

td99 does not sell, rent or trade your personal data to any third party for their own marketing or commercial purposes. Payment provider names referenced on this site (including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) are mentioned as familiar Pakistani payment context only — they do not receive your personal data from td99 as a result of being listed here.

td99 operates internationally. As a result, your personal data may be transferred to, stored in and processed in countries other than Pakistan. Some of these countries may have data protection laws that differ from those applicable in your jurisdiction.

Where personal data is transferred outside of the jurisdiction in which td99 holds its licence, td99 takes appropriate steps to ensure that such transfers are subject to adequate safeguards — including the use of contractual clauses, adequacy decisions or other recognised transfer mechanisms. By using the td99 Service, you acknowledge and consent to cross-border transfers of your personal data as described in this Policy.

td99 retains personal data for as long as necessary to fulfil the purposes set out in this Policy, unless a longer retention period is required or permitted by applicable law. The following general retention principles apply:

• Active Account Data: Retained for the duration of the account relationship plus a minimum post-closure period as required by anti-money laundering regulations (typically five to seven years after account closure, depending on applicable jurisdiction).
• KYC Documents: Retained for the period required under applicable AML/CTF legislation, typically five years from the end of the business relationship.
• Transaction Records: Retained for the period required by applicable financial regulations, typically five years.
• Support Communications: Retained for a period of up to three years from the date of the last communication, unless a longer period is required by dispute resolution or legal processes.
• Self-Exclusion Records: Retained indefinitely to prevent re-registration during an active exclusion period and to maintain a record of the Player's request.
• Marketing Consent Records: Retained for as long as marketing communications are sent and for a period thereafter to demonstrate compliance.

When personal data is no longer required for any lawful purpose, it is securely deleted or anonymised in accordance with td99's internal data lifecycle procedures.

td99 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the td99 platform;
• Encryption of sensitive personal data stored on td99 systems, including passwords (stored as salted hashes) and identification documents;
• Role-based access controls limiting staff access to personal data based on operational necessity;
• Regular security assessments, penetration testing and vulnerability management;
• Monitoring for suspicious access patterns, anomalous activity and potential data breaches;
• Incident response procedures designed to detect, contain and remediate data security incidents promptly.

While td99 applies industry-standard security practices, no system can guarantee absolute security. You are responsible for maintaining the confidentiality of your account login credentials. If you suspect unauthorised access to your account, please contact our support team immediately.

Depending on the data protection laws applicable in your jurisdiction, you may have the following rights in relation to your personal data held by td99. To exercise any of these rights, please contact our support team using the details in Section 16.

12.1 What Cookies We Use

td99 uses cookies and similar tracking technologies (such as web beacons, pixel tags and local storage) to operate and improve the Service. The categories of cookies used include:

• Strictly Necessary Cookies: Essential for platform operation — including session management, authentication and security. These cannot be disabled without impacting core functionality.
• Functional Cookies: Remember your preferences such as language settings, display options and account configuration.
• Analytical Cookies: Collect aggregated, anonymised data about how users navigate the platform, helping us identify issues and improve user experience. Data from these cookies does not identify you personally.
• Security Cookies: Used for fraud detection, bot mitigation and session integrity verification.

12.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling strictly necessary cookies may impair your ability to use certain features of the td99 platform, including logging in. Please consult your browser's help documentation for guidance on managing cookies.

The td99 Service is strictly for adults aged 18 years and above, or the higher minimum age required by the operator/licence jurisdiction. td99 does not knowingly collect or process personal data from individuals under the applicable minimum age.

If td99 becomes aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered or is using the td99 platform, please contact us immediately at [email protected] so we can take appropriate action.

td99 uses age verification procedures as part of the KYC process to minimise the risk of underage access. Parental control software may also be used by parents and guardians to restrict access to gambling websites.

td99 targets Pakistani users and acknowledges the specific context of operating within or in relation to Pakistan. The following disclosures are specific to Pakistani users:

• No Pakistani Regulatory Endorsement: td99 does not hold a licence issued by any Pakistani governmental body, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan or any provincial authority. This Privacy Policy is not regulated under Pakistani law and td99 does not represent that it satisfies any specific Pakistani data protection standard.
• Cross-Border Transfer Acknowledgement: By using td99, Pakistani users acknowledge that their personal data may be transferred to and processed in countries outside Pakistan, including countries with different data protection standards.
• Payment Data: References to payment methods familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are provided as contextual references only. Data related to payment transactions is processed by the relevant payment service providers under their own privacy policies. These brands do not receive personal data from td99 as a result of being mentioned on this site.
• Evolving Pakistani Law: Pakistan's data protection framework is developing. Users are encouraged to monitor legislative developments and seek independent legal advice regarding their rights.

td99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable legislation or platform functionality. When material changes are made, we will notify active users via the registered email address or by a prominent notice on the platform at the time of login.

The effective date displayed at the top of this page reflects when the current version came into force. Your continued use of the td99 Service after a revised Policy has been published constitutes acceptance of the updated terms. If you do not agree to the revised Policy, you should cease using the Service and may request account closure.

We recommend reviewing this Policy periodically, particularly if you are providing new personal data or using new platform features. The current version is always available at https://td99.cam/privacy-policy.

If you have any questions about this Privacy Policy, wish to exercise a data right or have a concern about how your personal data is being processed by td99, please contact our support team:

Email: [email protected] (plain text — not a clickable link)

For general platform questions, visit our FAQ page. For information about responsible gambling tools and player protection, visit our Responsible Gambling page.