At p399 we take your privacy seriously. This Privacy Policy explains exactly what personal data we collect from users — including players across Pakistan — why we collect it, how it is stored, who may access it, and what rights you hold over your own information. Please read it in full before using the Platform.
p399 ("p399", "we", "us", "our") operates the online betting and casino platform accessible at https://p399.cam (the "Platform"). In providing the Platform, we collect, process and store personal data relating to registered users and visitors ("you", "your", "User").
This Privacy Policy sets out in full: what personal data we collect, the purposes for which it is processed, the legal bases on which that processing rests, who we may share it with, how long we retain it, and the rights you hold as a data subject. It should be read alongside our Terms & Conditions and Responsible Gambling Policy.
p399 is committed to handling personal data responsibly and in compliance with applicable data protection law. Where we act as data controller — determining the purposes and means of processing — we accept the obligations that status entails. Where we act as data processor on behalf of a third-party operator, we process data only in accordance with documented instructions from that controller.
This policy is published in English. All communications regarding data rights and queries will be handled in English; Urdu-language assistance may be available via Live Chat during select hours.
The following terms carry specific meanings throughout this Privacy Policy:
| Term | Meaning |
|---|---|
| Personal Data | Any information that identifies or could reasonably be used to identify a living natural person, directly or indirectly. |
| Processing | Any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure or deletion. |
| Data Controller | The entity that determines the purposes and means of processing personal data. p399 acts as data controller for the personal data it collects from Platform users. |
| Data Processor | An entity that processes personal data on behalf of a data controller, under documented instructions. |
| KYC Data | Identity and verification documents submitted as part of the Know Your Customer process, including government-issued ID (e.g., CNIC, passport) and proof of address. |
| Cookies | Small text files placed on your device by the Platform to enable functionality, remember preferences and collect analytics data. |
| Third-Party Processor | A service provider engaged by p399 to perform specific data-processing functions, including payment processors, KYC verification providers and analytics platforms. |
The categories of personal data we collect depend on how you interact with the Platform. The following table sets out the principal data categories and the circumstances in which they arise:
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full name, date of birth, gender, nationality | Account registration; KYC verification |
| Contact Data | Email address, residential address, city (e.g., Karachi, Lahore, Islamabad) | Account registration; support interactions |
| Identity Documents | CNIC scan, passport copy, proof of address document | KYC verification prior to first withdrawal |
| Financial Data | Payment method reference (e.g., last four digits of account), transaction history, deposit/withdrawal amounts in PKR | Deposits; withdrawals; cashier activity |
| Account & Gaming Data | Username, betting history, casino play history, balance records, bonus usage, session timestamps | Ongoing platform use |
| Technical Data | IP address, browser type and version, device type, operating system, screen resolution | Automatic collection on each session |
| Usage Data | Pages visited, features used, click-paths, session duration, referral source | Automatic collection via analytics |
| Communications Data | Content of support tickets, Live Chat transcripts, email correspondence | When you contact support |
| Responsible Gambling Data | Self-exclusion status, limit settings, problem gambling disclosures | When limits or exclusions are set or updated |
p399 collects personal data through the following channels and mechanisms:
Data you provide directly when you: complete the account registration form; submit KYC documents; use the cashier to deposit or withdraw funds; contact our support team via Live Chat, email or Help Centre; set responsible gambling limits or self-exclusion; or complete any other form on the Platform.
Technical and usage data collected automatically through cookies, web beacons, log files and similar tracking technologies each time you interact with the Platform. This includes your IP address, session data and browser characteristics. See Section 8 for full cookie details.
We may receive data from: KYC verification providers who cross-reference your identity documents against official databases; fraud prevention and anti-money-laundering (AML) screening services; payment processors involved in processing your PKR deposits or withdrawals; and, where applicable, responsible gambling databases maintained under licensing requirements.
Where data protection law requires a legal basis for processing personal data, p399 relies on one or more of the following grounds depending on the purpose of the processing:
p399 uses personal data only for the purposes described below. We do not repurpose data for uses that are incompatible with the original collection purpose without first obtaining your consent.
| Purpose | Data Categories Used |
|---|---|
| Account registration and management | Identity Data, Contact Data, Account Data |
| Age and identity verification (KYC) | Identity Data, Identity Documents, Financial Data |
| Processing deposits and withdrawals in PKR | Financial Data, Identity Data, KYC Data |
| Sports betting and casino game settlement | Account & Gaming Data, Financial Data |
| Fraud detection and AML compliance | Identity Data, Financial Data, Technical Data, Communications Data |
| Responsible gambling monitoring and interventions | Account & Gaming Data, Responsible Gambling Data |
| Customer support | Identity Data, Contact Data, Communications Data, Account Data |
| Platform security and integrity | Technical Data, Usage Data, Account Data |
| Analytics and platform improvement | Usage Data, Technical Data (aggregated / pseudonymised where possible) |
| Marketing communications (with consent only) | Contact Data, Account & Gaming Data (preferences) |
p399 does not sell personal data. We share personal data externally only in the following circumstances and only to the extent strictly necessary:
We engage carefully selected third-party processors who perform services on our behalf under binding data processing agreements. These include: KYC and identity verification providers; payment processing partners; fraud and AML screening services; cloud hosting and infrastructure providers; and customer support platform providers. Each processor is contractually prohibited from using your data for any purpose beyond the specific service they provide to p399.
We may disclose personal data to regulatory authorities, law enforcement agencies, courts or other government bodies where we are legally required to do so, or where disclosure is necessary to protect the rights, property or safety of p399, our users or the public. This includes mandatory reporting obligations under anti-money-laundering regulations.
Where required by our operating licence, we may share self-exclusion status or problem gambling flags with responsible gambling database operators or cross-operator exclusion schemes. This is done to protect vulnerable users and fulfil our regulatory obligations.
In the event of a merger, acquisition, restructuring or sale of all or part of p399's business, personal data held by p399 may be transferred to the relevant acquiring or successor entity, subject to equivalent data protection obligations. We will notify affected users of any such transfer in advance where reasonably practicable.
p399 uses cookies and similar technologies (including web beacons and local storage) to make the Platform function correctly, to improve your experience and to analyse how the Platform is used.
| Cookie Type | Purpose | Required? |
|---|---|---|
| Strictly Necessary | Maintain your login session, remember your language and display preferences, enable cashier security tokens | Yes — cannot be disabled |
| Functional | Remember odds format preference, live-betting layout settings, previously viewed games | Optional |
| Analytics | Understand how users navigate the Platform, identify performance issues, measure feature usage | Optional |
| Security / Fraud Prevention | Detect suspicious login patterns, bot activity and multi-account abuse | Yes — required for platform integrity |
You can control optional cookie categories through your browser settings. Most browsers allow you to block or delete cookies. Blocking strictly necessary cookies will impair or prevent your ability to log in and use the Platform. Blocking analytics cookies will not affect your ability to bet or play.
p399 retains personal data for no longer than is necessary for the purposes for which it was collected, taking into account our legal and regulatory obligations. The following retention periods apply as a general guide:
At the end of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identified individual.
p399 operates an international platform. Your personal data may be transferred to, and processed in, countries outside your country of residence — including countries outside Pakistan. Some of these countries may not have data protection laws equivalent to those in your home jurisdiction.
Where we transfer personal data internationally, we take appropriate safeguards to ensure that the data receives an adequate level of protection. Safeguards may include: standard contractual clauses approved by the relevant data protection authority; binding corporate rules; adequacy decisions; or other legally recognised transfer mechanisms.
By using the Platform, you acknowledge that your data may be transferred internationally in connection with the provision of our services.
The p399 Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the operator or the licensing jurisdiction. We do not knowingly collect personal data from individuals under this minimum age.
If we become aware that personal data has been collected from an individual who does not meet the minimum age requirement, we will take immediate steps to delete that data and close the relevant account. Any winnings associated with an underage account will be forfeited in accordance with our Terms & Conditions.
If you believe that a minor has registered an account on p399 or has accessed the Platform using your credentials, please contact our support team immediately via the Help Centre or Live Chat.
p399 implements a range of technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:
While we take all reasonable precautions, no internet transmission or electronic storage system is completely secure. We cannot guarantee absolute security, and users accept a residual risk inherent in digital communication when using the Platform. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by applicable law.
Subject to applicable data protection law and certain exceptions, you hold the following rights in relation to your personal data held by p399. Your rights are described in detail in the section below and in the illustrated grid that follows this clause.
To exercise any of these rights, please contact us via the Help Centre or Live Chat, or email us at the address set out in Section 15. We will respond to verified requests within the timeframe required by applicable law. We may ask you to verify your identity before processing a request.
You also have the right to lodge a complaint with the relevant data protection supervisory authority in the jurisdiction in which you reside if you believe that your data has been processed unlawfully. This right is without prejudice to any other legal remedies available to you.
p399 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or business operations. The date of the most recent revision is displayed at the top of this page.
Where amendments are material — for example, if we change the categories of data we collect, the purposes for which we process it, or the third parties with whom we share it — we will provide advance notice by email to your registered address or by a prominent notice on the Platform before the change takes effect. Your continued use of the Platform following the effective date of any amendment will be taken as acceptance of the revised policy.
We encourage you to review this Privacy Policy periodically to stay informed about how p399 handles your personal data. The current published version supersedes all prior versions.
For any queries, concerns or requests relating to this Privacy Policy or the personal data p399 holds about you, please contact us through the following channels:
When contacting us about a data rights request or privacy concern, please include your registered email address and, where relevant, your account username. This helps us locate your records and respond accurately.
Response times may vary depending on query volume. We aim to acknowledge all privacy-related requests promptly and to respond in full within the timeframe required by applicable data protection law.
Under applicable data protection law, you have the following rights regarding the personal data p399 holds about you. These rights are subject to certain legal exceptions and identity verification requirements.
You have the right to request a copy of the personal data p399 holds about you, along with information about how and why it is processed. Contact our support team to submit a Subject Access Request.
If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or completed without undue delay. Account information can also be updated directly in your account settings.
You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose it was collected. Note that legal retention obligations (e.g., AML record-keeping) may prevent full erasure.
You may request that processing of your personal data be restricted — for instance, while the accuracy of data is being contested, or while an objection to processing is being considered — rather than deleted outright.
You have the right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease that processing immediately. Other objections will be assessed against our lawful basis for processing.
Where processing is based on consent or contract and carried out by automated means, you may request that we provide your personal data in a structured, commonly used and machine-readable format, or transfer it directly to another service provider where technically feasible.
If you have questions about how p399 uses your personal data, or want to exercise any of your data rights, visit our FAQ or contact our support team directly.