bn33 Privacy Policy — How We Handle Your Personal Data

Introduction

bn33 ("we", "us", "our", "bn33") operates the online gaming and sports betting platform accessible at bn33.one ("Platform"). This Privacy Policy sets out in clear terms how bn33 collects, uses, stores, shares, and protects the personal data of individuals ("you", "Player", "User") who access or use the Platform, including all users based in Pakistan.

bn33 recognises that the privacy and security of your personal information is of the utmost importance. We are committed to processing your personal data only for lawful, specified, and transparent purposes. This Policy is intended to be read alongside the bn33 Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your use of the Platform.

Data Controller

For the purposes of this Privacy Policy, bn33 is the data controller responsible for determining the purposes and means of processing your personal data. bn33 operates the Platform under international gaming regulations and maintains its data processing activities in accordance with the data protection obligations imposed by its licensing jurisdiction.

All data protection enquiries, subject access requests, and complaints relating to bn33's processing of your personal data should be directed to the bn33 Data Team at [email protected] with the subject line "Privacy / Data Protection Enquiry."

Data We Collect

bn33 collects personal data that is necessary and proportionate to the purposes for which it is processed. The categories of personal data we collect are detailed below.

3.1 Registration & Identity Data

• Full legal name as it appears on your CNIC or other government-issued identification;
• Date of birth (used to verify the 21+ age requirement);
• Registered mobile number (Pakistani mobile number);
• City of residence within Pakistan;
• Account username and encrypted password.

3.2 Identity Verification (KYC) Data

• Copy of Pakistani CNIC (Computerised National Identity Card), passport, or other government-issued identity document;
• Selfie photograph or live identity verification image, where requested;
• Proof of address documentation, where required by our compliance team.

3.3 Financial & Transaction Data

• Payment method identifiers (JazzCash mobile number, EasyPaisa mobile number, bank account details for HBL, UBL, or Meezan Bank transfers);
• Transaction history including deposit amounts, withdrawal requests, and payment timestamps;
• Account balance records and bonus credit/debit logs.

3.4 Gaming & Betting Activity Data

• Game session logs, including games played, bets placed, outcomes, and session durations;
• Sports betting activity including markets wagered, odds accepted, and settlement records;
• Responsible gaming tool activations (deposit limits set, self-exclusion requests, cooling-off periods).

3.5 Technical & Device Data

• IP address at time of registration and each subsequent login;
• Device type, model, and operating system version;
• Browser type and version;
• Mobile network operator (e.g., Jazz, Telenor, Zong, Ufone, Warid);
• Session timestamps and geographic location derived from IP address.

3.6 Communications Data

• Records of all communications between you and the bn33 support team, including live chat transcripts, email correspondence, and any submitted forms;
• Feedback, survey responses, and voluntary information shared with our support or compliance teams.

How We Collect Your Data

bn33 collects personal data through the following channels:

Directly from You

The majority of personal data we hold is provided directly by you during the account registration process, during identity verification (KYC), when making deposits or requesting withdrawals, when setting responsible gaming limits, and when contacting our support team through any available channel.

Automatically During Platform Use

When you access and use the bn33 Platform, certain technical data is collected automatically through cookies, server logs, and similar tracking technologies. This includes your IP address, device information, browser type, and session activity data. Please refer to Section 7 of this Policy for detailed information on our use of cookies and tracking technologies.

From Third-Party Payment Providers

When you make a deposit or request a withdrawal, our payment processing partners — including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank — may share transaction confirmation data with bn33 for the purpose of crediting or debiting your Account. bn33 does not receive your full banking credentials through this process; only transaction confirmation details are shared.

From Identity Verification Services

Where bn33 uses third-party identity verification services to assist with KYC processing, those services may cross-reference the identity documents you submit against available databases to confirm their authenticity. bn33 receives only the verification outcome and necessary identity confirmation from such services.

How We Use Your Personal Data

bn33 uses your personal data for the following specified purposes:

• Account Management: Creating, maintaining, and administering your bn33 Account, including processing login requests, managing your balance, and recording your gaming and betting activity;
• Identity & Age Verification: Verifying that you meet the 21+ minimum age requirement and that the identity information you have provided is accurate and genuine;
• Payment Processing: Facilitating deposits and withdrawals through your chosen payment method (JazzCash, EasyPaisa, HBL, UBL, or Meezan Bank) and maintaining accurate transaction records;
• Regulatory Compliance: Fulfilling our obligations under the terms of our international gaming licence, including Anti-Money Laundering (AML) checks, Know Your Customer (KYC) requirements, and responsible gaming monitoring;
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, multi-accounting, bonus abuse, money laundering, and unauthorised access to the Platform;
• Responsible Gaming: Monitoring gaming behaviour to identify indicators of problem gambling, facilitating the use of responsible gaming tools, and applying self-exclusion or cooling-off restrictions when requested or required;
• Customer Support: Responding to your enquiries, resolving disputes, processing complaints, and providing account-related assistance;
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the performance, security, and user experience of the bn33 Platform;
• Marketing Communications: Where you have provided consent or where we have a legitimate interest, sending you promotional offers, bonus notifications, and relevant product updates by SMS or other permitted channels. You may opt out at any time as described in Section 14.

Legal Basis for Processing

bn33 relies on one or more of the following legal bases when processing your personal data:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and bn33, as set out in the Terms & Conditions. This covers account creation, payment processing, game provision, and customer support;
• Legal Obligation: Processing is necessary to comply with legal obligations, including AML regulations, KYC requirements under our gaming licence, and data retention obligations;
• Legitimate Interests: Processing is necessary for bn33's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and business analytics — provided those interests are not overridden by your data protection rights;
• Consent: Where required, processing is based on your freely given, specific, and informed consent. This applies primarily to direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Cookies & Tracking Technologies

The bn33 Platform uses cookies and similar technologies — including local storage and session storage — to deliver a functional and secure user experience. The categories of cookies used on the Platform are described below.

Strictly Necessary Cookies

These cookies are essential for the Platform to function correctly. They include session authentication tokens, security cookies that prevent cross-site request forgery, and cookies that maintain your login state during a session. These cookies cannot be disabled without breaking core Platform functionality.

Functional Cookies

These cookies remember your preferences and settings, such as your selected language, preferred game categories, and responsible gaming configurations. They improve your experience on returning visits.

Analytics Cookies

Analytics technologies allow bn33 to collect aggregated, anonymised data about how Players interact with the Platform — including which pages are visited most frequently, where users navigate to and from, and how long sessions typically last. This data is used exclusively to improve Platform performance and is not linked to your individual identity.

Data Sharing & Disclosure

bn33 does not sell your personal data to any third party. We share your personal data only in the following limited and controlled circumstances:

• Payment Service Providers: Transaction data is shared with JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank solely to facilitate the processing of deposits and withdrawals;
• Identity Verification Partners: KYC document data may be processed by contracted third-party identity verification services acting as data processors on bn33's behalf, under strict confidentiality obligations;
• Game Content Providers: Gaming session data — including your account identifier, bet amounts, and outcomes — is shared with the certified third-party game studios that supply our casino and sports betting products, for the purpose of service delivery and game integrity maintenance;
• Regulatory & Law Enforcement Authorities: bn33 will disclose personal data to competent regulatory authorities, law enforcement agencies, or other governmental bodies where required to do so by applicable law, court order, or the conditions of our gaming licence;
• Fraud Prevention Networks: In cases of suspected fraud, money laundering, or multi-accounting, bn33 may share relevant data with fraud prevention agencies or industry-shared databases to protect the integrity of the Platform and other players;
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of bn33's business, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

All third parties who receive personal data from bn33 are contractually bound to process that data only for the specified purpose and to maintain appropriate technical and organisational security measures.

International Data Transfers

The bn33 Platform serves Pakistani players, and while we endeavour to keep data processing as local as operationally practicable, certain data may be transferred to and processed in jurisdictions outside Pakistan. This may occur where our game providers, payment processors, or infrastructure partners operate servers in other countries.

Where international data transfers occur, bn33 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that described in this Policy. These safeguards may include contractual data protection clauses incorporated into agreements with our data processors.

Data Retention

bn33 retains personal data only for as long as is necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law or regulatory obligation. The primary retention periods applicable to each category of data are set out in the table in Section 3 of this Policy.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

Where your Account is closed at your request for responsible gaming reasons (self-exclusion), bn33 will retain sufficient data to ensure that the self-exclusion is respected if you attempt to re-register. This is a protective measure and not a processing of your data for any commercial purpose.

Your Rights

Subject to applicable law and the conditions of our gaming licence, you have the following rights in relation to your personal data held by bn33:

• Right of Access: You have the right to request a copy of the personal data we hold about you and information about how it is being processed;
• Right to Rectification: You have the right to request correction of any personal data that is inaccurate or incomplete. Certain data can be updated directly through your Account settings;
• Right to Erasure: In certain circumstances, you have the right to request deletion of your personal data. Note that this right may be limited where retention is required by regulatory obligation (such as AML and KYC record-keeping requirements);
• Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you have contested the accuracy of data pending verification;
• Right to Data Portability: Where processing is based on your consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Object: You have the right to object to processing based on legitimate interests, including direct marketing. Where you object to direct marketing, we will cease all such communications immediately;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Subject Rights Request." We will respond within 30 calendar days. We may need to verify your identity before processing your request to ensure we do not disclose personal data to an unauthorised party.

Data Security

bn33 implements and maintains comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the bn33 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols;
• Encrypted Data Storage: Sensitive personal data, including identity verification documents and financial records, is stored in encrypted databases with access restricted to authorised personnel only;
• Access Controls: Strict role-based access controls ensure that bn33 staff can only access personal data to the extent necessary for their specific job function;
• Regular Security Audits: The Platform undergoes regular third-party security assessments and penetration testing to identify and remediate vulnerabilities;
• Fraud Detection Systems: Automated monitoring systems operate continuously to detect and flag suspicious Account activity, including unusual login patterns and irregular transaction behaviour.

Minors & Age Verification

bn33 implements age verification at the point of registration and through the KYC verification process. Where we have reasonable grounds to suspect that an Account holder may be under the age of 21, we reserve the right to suspend the Account, freeze the balance, and request mandatory age verification documentation before permitting any further activity.

If you are a parent or guardian and believe that a person under your care has registered an Account with bn33, please contact us immediately at [email protected] and we will investigate and act promptly.

Marketing Communications

Where you have provided consent or where bn33 has a legitimate interest under applicable law, we may send you marketing communications about promotions, bonuses, new games, and platform features. These communications may be sent by SMS to your registered Pakistani mobile number.

You have the right to opt out of marketing communications at any time through any of the following methods:

• Updating your communication preferences directly within your Account settings;
• Contacting our support team at [email protected] with the subject line "Unsubscribe from Marketing";
• Replying STOP to any promotional SMS sent from a bn33 number.

Opting out of marketing communications does not affect your receipt of important transactional messages — such as deposit confirmations, withdrawal notifications, account security alerts, and KYC verification requests — which are sent as part of the core service.

Third-Party Links & Services

The bn33 Platform may contain references to third-party services, including payment providers and game studios. Where you interact directly with a third-party service, that party's own privacy policy will govern their collection and use of your data. bn33 is not responsible for the privacy practices of third-party services and encourages you to review their policies before providing personal information.

bn33 selects its third-party partners carefully and requires all data processors to adhere to data protection standards consistent with this Policy. However, bn33 cannot guarantee the security or privacy practices of external systems once data leaves the bn33 Platform environment.

Updates to This Privacy Policy

bn33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing activities, applicable law, or regulatory requirements. Where changes are material — meaning they significantly affect the way we process your personal data or your rights under this Policy — bn33 will notify you by displaying a prominent notice on the Platform and, where applicable, by sending an SMS notification to your registered mobile number.

The effective date shown at the top of this Policy indicates when the current version came into force. We encourage you to review this Policy periodically. Your continued use of the bn33 Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

Where you do not agree with an updated version of this Policy, you should cease using the Platform and may request Account closure as described in the bn33 Terms & Conditions.

Contact & Complaints

For all questions, requests, or concerns relating to this Privacy Policy or bn33's processing of your personal data, please contact our Data Protection Team:

If you believe that bn33 has processed your personal data in violation of this Policy or applicable data protection law and our response to your complaint is not satisfactory, you may have the right to lodge a complaint with the competent data protection authority in the jurisdiction of bn33's gaming licence. Details of the relevant supervisory authority are available upon written request.

This Privacy Policy was last reviewed and updated in January 2026. It supersedes all prior versions of the bn33 Privacy Policy. bn33 is committed to upholding the privacy rights of all players, including the hundreds of thousands of Pakistani players who trust the Platform with their personal data.