hm99 Privacy Policy

01 Who We Are

hm99 is a crypto-first online casino and sports betting platform accessible at hm99.im. References to "hm99", "we", "us" or "our" throughout this Privacy Policy refer to the hm99 platform and its operating entity, which holds an international gaming licence authorising the provision of online gambling services.

hm99 acts as the data controller in respect of the personal data of registered players and site visitors. As data controller, hm99 determines the purposes and means by which personal data is processed, and is responsible for ensuring that processing is carried out lawfully, fairly and transparently.

If you have any questions about how hm99 handles your personal data, or wish to exercise any of your data rights, you may contact our dedicated support team at [email protected]. All data-related queries are handled within ten (10) business days of receipt.

02 Scope of This Policy

This Privacy Policy applies to all personal data collected by hm99 in connection with:

• The registration and maintenance of a player account on the hm99 platform.
• The use of any hm99 products or services, including casino games, live dealer tables, sports betting markets, slot games and promotional offers.
• All deposit and withdrawal transactions processed through hm99's supported payment methods, including USDT, BTC, JazzCash, EasyPaisa, HBL, UBL and Meezan Bank.
• Visits to the hm99 website at hm99.im, including pages accessed without a registered account.
• Any communications between you and hm99 via email, live chat or any other channel.

This policy does not apply to third-party websites, services or platforms that may be linked to or from hm99. hm99 is not responsible for the privacy practices of any third party, and players are encouraged to review the privacy policies of any external services they use.

03 Data We Collect

hm99 collects the following categories of personal data in the course of providing its services:

04 How We Collect Your Data

hm99 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing identity verification, making a deposit or withdrawal, contacting support, or responding to a promotional offer.
• Automated collection: Technical data collected automatically when you visit and interact with the hm99 website, including via cookies, web beacons, server logs and similar technologies. See Section 10 for full details of our cookie practices.
• Third-party sources: Data received from identity verification providers (e.g., document verification services), payment processors, fraud detection services and, where applicable, publicly available sources used for AML and sanctions screening purposes.
• Inferred data: Behavioural and preference data inferred from your platform activity, such as your preferred game categories, typical session times and betting patterns, used primarily for responsible gaming monitoring and platform improvement.

05 How We Use Your Data

hm99 uses the personal data it collects for the following purposes:

• Account management: Creating, maintaining and securing your hm99 account, verifying your identity and age, and managing your account settings and preferences.
• Service delivery: Processing your deposits and withdrawals, providing access to casino games, sports betting markets, live dealer tables and all other hm99 products.
• Regulatory compliance: Meeting our obligations under applicable anti-money laundering (AML), Know Your Customer (KYC) and gaming licence regulations, including maintaining mandatory transaction records and reporting to regulatory authorities where required by law.
• Fraud prevention and security: Detecting, investigating and preventing fraudulent activity, unauthorised account access, collusion, bonus abuse and other prohibited conduct on the hm99 platform.
• Responsible gaming: Monitoring player behaviour for indicators of problem gambling, enforcing deposit limits and self-exclusion requests, and providing support to players who may be experiencing gambling-related harm.
• Customer support: Responding to your queries, resolving complaints and maintaining records of communications for quality assurance purposes.
• Marketing communications: Sending you information about hm99 promotions, bonuses and new product features, where you have consented to receive such communications or where hm99 has a legitimate interest in doing so. You may opt out of marketing communications at any time.
• Platform improvement: Analysing aggregated and anonymised usage data to improve the performance, design and functionality of the hm99 platform.

06 Legal Bases for Processing

hm99 processes your personal data on the following legal bases:

• Contractual necessity: Processing that is necessary to enter into or perform the contract with you — including account creation, transaction processing and service delivery — is carried out on the basis that it is required to fulfil our contractual obligations to you as a registered player.
• Legal obligation: Processing necessary to comply with applicable laws and regulations, including AML obligations, KYC requirements, gaming licence conditions, and responses to lawful requests from regulatory or law enforcement authorities.
• Legitimate interests: Processing carried out in pursuit of hm99's legitimate business interests — such as fraud prevention, platform security, responsible gaming monitoring and service improvement — where those interests are not overridden by your rights and interests.
• Consent: Processing based on your explicit consent, such as marketing communications and the use of non-essential cookies. Where consent is the basis for processing, you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Sharing Your Data

hm99 does not sell, rent or trade your personal data. We may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Identity and age verification providers: Third-party KYC services used to verify the identity, age and address of players during account registration and ongoing due diligence reviews.
• Payment processors: Financial institutions and payment service providers — including JazzCash, EasyPaisa, HBL, UBL and Meezan Bank, as well as cryptocurrency processing partners — that process your deposits and withdrawals on hm99's behalf.
• Game studios and software providers: Licensed game development studios whose games are offered on the hm99 platform. These providers may receive limited session data necessary to deliver game functionality and verify game outcomes.
• Fraud prevention and security services: Specialist third-party providers that assist hm99 in detecting and preventing fraud, money laundering and other prohibited activity.
• Regulatory and law enforcement authorities: Where hm99 is required by applicable law, court order or regulatory instruction to disclose player data to governmental, regulatory or law enforcement bodies, we will do so in compliance with our legal obligations.
• Professional advisers: Legal, accounting and auditing professionals engaged by hm99, subject to professional confidentiality obligations.

All third-party service providers engaged by hm99 are required to enter into data processing agreements that bind them to process your personal data only on hm99's instructions and in compliance with applicable data protection law. hm99 does not permit its service providers to use your data for their own purposes.

08 International Data Transfers

As an internationally licensed platform serving players in Pakistan and other jurisdictions, hm99 may transfer your personal data to countries outside your country of residence in the course of operating the platform and engaging third-party service providers.

Where personal data is transferred to a country that does not provide an equivalent level of data protection to the jurisdiction in which hm99 is licensed, hm99 will implement appropriate safeguards to protect your data. These safeguards may include standard contractual clauses approved by the relevant regulatory authority, binding corporate rules, or other recognised transfer mechanisms.

By registering an hm99 account and accepting this Privacy Policy, you acknowledge and consent to the international transfer of your personal data as described in this section.

09 Data Retention

hm99 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable regulatory or legal obligations, whichever is the longer period.

The following indicative retention periods apply to the main categories of player data held by hm99:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in compliance with AML and gaming licence record-keeping obligations.
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AML regulations.
• Gaming history: Retained for a minimum of three (3) years from the date of the relevant wager or game session, for regulatory compliance and dispute resolution purposes.
• Support communications: Retained for three (3) years from the date of the final communication in a support thread, unless the communication relates to an ongoing dispute or legal matter, in which case it is retained until resolution.
• Marketing consent records: Retained for as long as you remain a registered hm99 player or until you withdraw your consent to marketing communications, whichever occurs first.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with hm99's data retention and disposal procedures.

10 Cookies & Tracking Technologies

hm99 uses cookies and similar tracking technologies on its website to provide platform functionality, improve user experience, and support security and fraud prevention operations. The following categories of cookies are used by hm99:

• Strictly necessary cookies: Essential for the operation of the hm99 website and platform, including session management, login authentication and security functions. These cookies cannot be disabled without impairing platform functionality.
• Performance and analytics cookies: Used to collect anonymised information about how players use the hm99 website, enabling hm99 to identify and fix performance issues and improve the overall platform experience.
• Functional cookies: Used to remember your preferences, such as language settings, preferred display options and responsible gaming tool configurations, so that you do not need to re-enter these settings on each visit.
• Security cookies: Used to support fraud detection systems, identify unusual login patterns and protect the integrity of account sessions.

11 Your Data Rights

As a data subject, you have the following rights in relation to the personal data that hm99 holds about you. These rights are subject to applicable legal exceptions and hm99's regulatory obligations.

To exercise any of these rights, please contact hm99 support in writing at [email protected] with the subject line "Data Rights Request", your registered username, and a clear description of the right you wish to exercise. hm99 will respond within ten (10) business days of receiving a valid request. In some cases, hm99 may need to verify your identity before processing a data rights request.

If you are not satisfied with hm99's response to a data rights request, you have the right to lodge a complaint with the data protection supervisory authority in the jurisdiction in which hm99 is licensed.

12 Children & Minors

The hm99 platform is strictly for users aged 21 years and above. hm99 does not knowingly collect, store or process personal data relating to any person under the age of 21. If hm99 becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed without delay.

If you are a parent or guardian and believe that your child has registered an account on hm99 or provided personal data to hm99 without your knowledge or consent, please contact hm99 support immediately at [email protected] so that we can investigate and take appropriate action.

hm99 employs age verification procedures at account registration and on an ongoing basis to prevent underage access to the platform. These procedures include document verification and cross-referencing against third-party identity databases where available.

13 Security Measures

hm99 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• Encryption: All data transmitted between your browser and the hm99 platform is encrypted using SSL/TLS protocols. Sensitive data stored in hm99's systems is encrypted at rest using AES-256 encryption.
• Access controls: Access to player personal data within hm99's internal systems is restricted to authorised personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication requirements for all staff.
• Intrusion detection: hm99 operates continuous monitoring systems to detect and respond to unauthorised access attempts, data breaches and other security incidents in real time.
• Penetration testing: The hm99 platform undergoes regular security assessments and penetration testing by qualified third-party security professionals to identify and remediate vulnerabilities before they can be exploited.
• Incident response: hm99 maintains a documented data breach response procedure. In the event of a breach that is likely to result in a risk to your rights and freedoms, hm99 will notify the relevant regulatory authority and affected players in accordance with applicable legal requirements.

While hm99 takes all reasonable steps to protect your personal data, no system is entirely immune to security threats. Players are encouraged to use strong, unique passwords for their hm99 accounts, to enable two-factor authentication, and to contact support immediately if they suspect any unauthorised access to their account.

14 Changes to This Privacy Policy

hm99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, hm99 will provide advance notice to registered players by email or via a prominent notice posted on the hm99 platform, prior to the changes taking effect.

The date of the most recent update to this Privacy Policy is displayed at the top of this page. It is your responsibility to review this policy periodically. Your continued use of the hm99 platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms.

If you do not accept the changes to this Privacy Policy, you must stop using the hm99 platform and may request account closure in accordance with the Terms and Conditions available at /terms-conditions.

15 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the way hm99 handles your personal data, please contact our support team using the following details:

hm99 does not provide telephone support. All privacy and data rights requests must be submitted in writing via the email address above to ensure a proper and auditable record is maintained.

This Privacy Policy was last reviewed and updated on 1 January 2026. The version published at hm99.im/privacy-policy is the current operative version and supersedes all prior versions.