Privacy Policy — don55

This Privacy Policy ("Policy") describes how don55 ("we", "us", "our", "the Platform") collects, processes, stores, shares and protects the personal data of individuals ("User", "you", "your") who access or use the don55 website, mobile interface, and associated services (collectively, "the Service").

don55 is an English-language online betting and casino platform designed with Pakistani users in mind. We are committed to processing personal data responsibly and transparently, in accordance with the privacy and data protection principles applicable in our operating jurisdiction and, where relevant, in the jurisdictions from which our users access the Service.

By accessing or using the Service, or by registering an account, you confirm that you have read and understood this Policy. If you do not agree with the practices described herein, you should discontinue use of the Service.

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, device identifiers and location data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For the Service, the Data Controller is the operator of don55.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller, under a contractual data-processing agreement.
• "Consent" means a freely given, specific, informed and unambiguous indication of agreement by a User to the processing of their Personal Data for a stated purpose.
• "KYC" means Know Your Customer — the process of verifying the identity of Users in compliance with applicable anti-money-laundering and age-verification requirements.
• "Cookies" means small data files placed on a User's device by the Service for purposes including session management, analytics and personalisation.

don55 collects the following categories of Personal Data, depending on the nature of your interaction with the Service:

We do not collect special-category personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data or biometric data) except where strictly necessary for responsible gambling assessments or where required by applicable law, in which case your explicit consent will be obtained prior to collection.

Personal Data is collected through the following means:

• Direct provision: Information you submit during account registration, KYC verification, deposit/withdrawal requests, support contacts and promotional opt-ins.
• Automated collection: Technical and usage data collected automatically as you interact with the Service via cookies, web beacons, log files and similar tracking technologies.
• Third-party sources: Identity verification providers, fraud-prevention agencies, payment processors, and data aggregators used to verify the accuracy of the information you provide and to comply with AML obligations.
• Public sources: Publicly available information used for fraud or sanctions screening purposes.

don55 processes Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to perform our contractual obligations to you as an account holder — including account management, bet settlement, deposit and withdrawal processing.
• Legal obligation: Processing required to comply with applicable law, including KYC/AML obligations, age verification requirements, regulatory reporting and law enforcement requests from competent authorities.
• Legitimate interests: Processing necessary for our legitimate interests in operating a secure, fair and commercially viable service — including fraud prevention, platform security, analytics and responsible gambling monitoring — where such interests are not overridden by your rights and interests.
• Consent: For non-essential marketing communications and non-essential cookies where applicable law requires consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Personal Data collected by don55 is used for the following purposes:

6.1 Account Management & Service Delivery

To create, maintain and administer your account; to process deposits and withdrawals; to settle bets; to provide access to games, live casino content, sports betting markets and other platform features; and to communicate with you regarding your account.

6.2 Legal & Regulatory Compliance

To verify your identity and age in compliance with KYC requirements; to conduct anti-money-laundering screening; to respond to lawful requests from regulatory, judicial or law enforcement authorities; and to fulfil record-keeping obligations under applicable licensing conditions.

6.3 Fraud Prevention & Security

To detect, investigate and prevent fraudulent activity, account takeover, money laundering, bonus abuse and other prohibited conduct; to monitor platform integrity; and to protect the rights and assets of don55 and its users.

6.4 Responsible Gambling

To monitor account activity for indicators of problem gambling behaviour; to enforce responsible gambling limits, cool-off periods and self-exclusion requests set by users; and to provide appropriate support or interventions where required by our responsible gambling obligations.

6.5 Platform Improvement & Analytics

To analyse usage patterns and improve the platform's design, performance and content offering; to conduct A/B testing; and to understand the needs of Pakistani users in cities including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar in order to deliver a more relevant experience.

6.6 Marketing Communications

Where you have opted in to marketing communications, to send you relevant promotional information about don55 offers, new features and sports events. You may opt out of marketing communications at any time by updating your account preferences or by contacting our support team.

don55 does not sell or rent Personal Data to third parties. We may share Personal Data with the following categories of recipients, strictly on a need-to-know basis and under appropriate contractual data-processing protections:

• Identity verification and KYC providers: Third-party services used to verify identity documents and age for compliance purposes.
• Payment processors: Entities processing deposit and withdrawal transactions on behalf of the platform.
• Fraud and risk management providers: Services used to detect and prevent fraudulent, abusive or prohibited activity.
• Technology and infrastructure providers: Cloud hosting, security and platform technology vendors processing data in accordance with our instructions under Data Processing Agreements.
• Game content providers: Game studios and sportsbook technology providers whose services are integrated into the platform, to the extent necessary for game session and bet data.
• Regulatory and law enforcement authorities: Competent authorities where disclosure is required by law, court order, or pursuant to our regulatory obligations.
• Professional advisors: Legal, audit and compliance advisors under strict professional confidentiality obligations.

don55 uses cookies and similar tracking technologies (web beacons, pixel tags, local storage) to operate the Service, remember user preferences, analyse platform performance, and — where applicable — support marketing measurement.

8.1 Types of Cookies Used

• Strictly necessary cookies: Required for the Service to function. These cannot be disabled without impairing core functionality such as login sessions, bet placement and account management.
• Functional cookies: Remember your preferences such as display settings, language and responsible gambling limit preferences across sessions.
• Analytics cookies: Collect anonymised or pseudonymised data about how users interact with the Service, used to improve platform design and performance.
• Marketing cookies: Used to measure the effectiveness of promotional campaigns and — where consent is given — to deliver relevant advertising. These are not deployed without appropriate consent.

8.2 Managing Cookies

You can control non-essential cookies through your browser settings or through the cookie preference centre provided on the platform where available. Please note that disabling strictly necessary cookies will affect the functionality of the Service.

don55 operates internationally and may process or transfer Personal Data to third-party service providers located outside the country from which you access the Service. Where such transfers occur, don55 takes appropriate steps to ensure that the transferred data receives an adequate level of protection, including:

• Standard Contractual Clauses or equivalent transfer mechanisms approved by the applicable data protection authority;
• Processor agreements requiring receiving entities to apply data security and privacy standards consistent with this Policy;
• Transfers only to jurisdictions recognised as providing adequate data protection where required by applicable law.

Pakistani users should be aware that data relating to their account may be processed in jurisdictions outside Pakistan. By using the Service, you acknowledge and consent to such international processing to the extent required.

Personal Data is retained for no longer than is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory or contractual obligations. The following general principles apply:

• Active accounts: Personal Data is retained throughout the period an account remains active on the platform.
• Closed accounts: Following account closure, identity, financial and transaction records are typically retained for a period of five (5) to seven (7) years in accordance with anti-money-laundering retention obligations, or longer where required by applicable law.
• Responsible gambling records: Self-exclusion, limit-setting and responsible gambling intervention records are retained for extended periods to prevent circumvention.
• Marketing data: Where consent for marketing communications has been withdrawn, personal data used solely for marketing purposes will be suppressed promptly, subject to suppression list retention for opt-out compliance.

Upon the expiry of applicable retention periods, Personal Data is securely deleted or anonymised in accordance with our internal data disposal procedures.

don55 implements appropriate technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols;
• Encryption of sensitive data at rest;
• Access controls restricting internal data access to authorised personnel on a need-to-know basis;
• Multi-factor authentication requirements for privileged system access;
• Regular security assessments, penetration testing and vulnerability management;
• Incident response procedures to detect, investigate and notify of personal data breaches within required timeframes.

While we employ industry-standard security measures, no data transmission over the internet or storage system can be guaranteed as entirely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorised account access.

Subject to applicable law and certain conditions, you have the following rights with respect to your Personal Data. You may exercise these rights by contacting us using the details in Section 15.

The Service is strictly intended for adults aged 18 or over, or the higher minimum age required by the applicable operator or license jurisdiction. don55 does not knowingly collect Personal Data from individuals below the applicable minimum age.

If we become aware that Personal Data has been collected from an individual below the applicable minimum age, we will take immediate steps to delete that data and close the associated account. Age verification is a mandatory part of the KYC process and all accounts are subject to verification prior to withdrawal and, in certain circumstances, prior to activation.

If you believe that a minor has registered on the platform, please notify us immediately at the contact address in Section 15.

don55 reserves the right to update or amend this Privacy Policy at any time. The most recent version of this Policy will always be available at don55.cam/privacy-policy, with the effective date displayed at the top of the page.

Where changes are material — meaning they significantly affect how we process your Personal Data or your rights in relation to it — we will notify registered users via email or in-platform notification prior to the changes taking effect, where practicable. Your continued use of the Service following the effective date of any amendment constitutes acknowledgement of the revised Policy.

We recommend reviewing this Policy periodically. Archived versions of previous iterations of this Policy may be requested by contacting our support team.

For any questions, concerns or requests relating to this Privacy Policy, including the exercise of your data protection rights, please contact our team using the following details: