Privacy Policy – 92 Cocoa Pakistan Betting Platform

1. Who We Are and What This Policy Covers

This Privacy Policy applies to 92 Cocoa ("we", "us", "the Platform") and covers all personal data collected from users ("you", "members") who access or use the 92 Cocoa website at 92cocoa.net, including the sports betting, casino, Aviator, esports and referral features offered through the platform.

92 Cocoa is a betting and gaming platform built specifically for Pakistani users. The platform operates in Pakistani Rupees (PKR) and integrates with local payment providers including JazzCash, Easypaisa, NayaPay and SadaPay. Our user base consists entirely of registered members in Pakistan, and this Privacy Policy is written to reflect the Pakistani context in which we operate.

We take your privacy seriously. This policy was written to be genuinely understandable — not to confuse you with technical language. If you have any questions after reading it, please contact us at support@92cocoa.net at any time and a member of our team will respond in plain Urdu or English.

2. Personal Data We Collect

92 Cocoa collects personal data through three main channels: data you provide to us directly, data generated by your use of the platform and data we receive from third-party services connected to the platform.

2.1 Data You Provide Directly

• Registration data: Your full name, date of birth, mobile number and preferred username when you create a 92 Cocoa account.
• KYC documents: A copy of your National Identity Card (CNIC) or other government-issued identification, and proof of your registered payment method, when requested during verification.
• Payment information: Your JazzCash or Easypaisa mobile number, bank account details for IBFT transfers, or card details for Visa/Mastercard payments when you deposit or withdraw. Full card or account numbers are never stored on 92 Cocoa servers.
• Support communications: Messages, emails and live chat conversations you have with our customer support team.

2.2 Data Generated by Your Use of the Platform

• Betting and gaming activity: A full record of bets placed, markets selected, stakes, results and any bonuses used or earned on 92 Cocoa.
• Transaction history: All deposits, withdrawals and bonus transactions associated with your account.
• Device and access data: Your IP address, device type, operating system, browser type and the pages you visit on 92 Cocoa, collected automatically when you access the platform.
• Session data: Time spent on the platform, session start and end times, and feature usage patterns.

2.3 Data From Third Parties

• Payment verification: When you deposit via JazzCash or Easypaisa, we receive confirmation of your transaction from their systems, including transaction reference numbers and timestamps.
• Identity verification: If a third-party KYC provider is used, we receive a verification status (verified/not verified) from their system. The full document data may be processed by the provider under their own privacy policy.
• Fraud prevention: We may receive signals from fraud detection services about suspicious patterns associated with an IP address or device — without receiving any other personal information.

3. How We Use Your Personal Data

The table below sets out the purposes for which 92 Cocoa processes your personal data and the legal basis for each purpose.

4. Legal Basis for Processing

92 Cocoa processes your personal data on the following legal bases:

• Contract performance: Most of the data we process is necessary to deliver the services you signed up for — placing bets, processing your PKR deposits via JazzCash or Easypaisa and paying out your winnings. Without this data, we cannot fulfil our obligations to you.
• Legal obligation: KYC verification and responsible gaming monitoring are required by the obligations under which 92 Cocoa operates. We must verify member identity and monitor for problem gambling behaviours as part of operating responsibly.
• Legitimate interest: Fraud detection, platform security and analytics for improving the 92 Cocoa experience are processed under legitimate interest, provided that your privacy rights are not overridden by those interests.
• Consent: Marketing SMS messages and promotional emails from 92 Cocoa are sent only to members who have explicitly opted in. You can withdraw this consent at any time by contacting support or updating your account preferences.

5. Third-Party Data Sharing

92 Cocoa does not sell or trade your personal data to any third party. We share data only with the specific partners required to deliver the platform's services to you, and only to the extent necessary for each purpose.

• Payment processors: JazzCash, Easypaisa, NayaPay, SadaPay and banking partners receive only the transaction data needed to process your deposit or withdrawal. They do not receive your betting history or CNIC data.
• Game providers: Licensed game providers such as Evolution Gaming, Pragmatic Live and Spribe (Aviator developer) may receive your session token and stake data to deliver their games. They do not receive your full name, CNIC or payment account details.
• KYC verification services: If a third-party verification provider processes your CNIC for identity verification, that provider operates under a strict data processing agreement with 92 Cocoa and is prohibited from using your data for any purpose other than the verification requested.
• Analytics providers: Anonymised, aggregated session and behaviour data may be shared with analytics tools to help us understand how members use 92 Cocoa and where the platform can be improved. This data cannot be used to identify individual members.
• Law enforcement and regulatory bodies: We may be required by law to disclose certain member data to regulatory authorities or law enforcement agencies. We will only do this in response to a lawful request and will notify affected members where we are legally permitted to do so.

6. Payment Data Security

Your financial data receives the highest level of protection at 92 Cocoa. We understand that Pakistani members trust us with sensitive payment information when they deposit via JazzCash, Easypaisa or bank transfer, and we treat that trust seriously.

• Full card numbers, CVV codes and bank account passwords are never stored on 92 Cocoa servers. Payments are processed through encrypted connections directly with payment processors.
• Your JazzCash or Easypaisa mobile number is stored securely in encrypted form for the purpose of processing deposits and withdrawals to the correct account.
• Withdrawal requests can only be processed to accounts registered in your own name and matching your verified identity. This protects you from unauthorised withdrawals even if someone gains access to your 92 Cocoa account.
• All financial transactions on the platform are logged with timestamp, transaction type and reference number. If you ever believe a transaction is unauthorised, you can contact support with the reference number for investigation.

7. KYC and Identity Verification

Know Your Customer (KYC) verification may be required before processing your first withdrawal, when your cumulative withdrawals exceed set thresholds, or when there is a reason to verify your identity for security purposes.

• KYC documents submitted to 92 Cocoa are processed solely for the purpose of verifying your identity. They are not used for marketing or shared with third parties beyond the verification service provider if applicable.
• Submitted documents are stored in encrypted, access-controlled storage. Access to KYC documents within the 92 Cocoa team is restricted to the compliance and security teams on a need-to-know basis.
• If your KYC submission is declined, you will be notified and given the opportunity to resubmit. If verification cannot be completed, the account may be restricted to prevent financial transactions until the issue is resolved.
• KYC documents are retained for the legally required period after account closure (generally 5 years) before being permanently deleted.

8. Cookies and Tracking Technologies

92 Cocoa uses cookies — small data files stored in your browser — to make the platform work correctly, to keep you logged in securely and to understand how members use the site. We do not use advertising tracking cookies.

You can manage cookie settings through your browser. Disabling strictly necessary cookies will prevent you from logging in and using core platform features on 92 Cocoa. Disabling functional and analytics cookies has no effect on your ability to bet or play games.

9. Data Retention

92 Cocoa retains your personal data only for as long as is necessary for the purposes described in this policy or as required by applicable law.

• Active account data: Retained for the full duration of your membership on 92 Cocoa and for a period of 5 years after account closure.
• Transaction and betting records: Retained for 5 years after each transaction, in line with standard financial record-keeping requirements.
• KYC documents: Retained for 5 years after account closure before being permanently and securely deleted.
• Support communications: Retained for 2 years from the date of the conversation to support any follow-up enquiries or dispute resolution.
• Analytics data: Anonymised analytics data does not have a personal data retention limit as it cannot be used to identify you.

When your data is no longer required, it is deleted using secure deletion methods that prevent recovery. KYC documents are destroyed using industry-standard data destruction protocols.

10. Security Measures at 92 Cocoa

Protecting member data is a core operational responsibility at 92 Cocoa. The following measures are in place to secure your personal information:

• Transport encryption: All data between your browser or app and 92 Cocoa is encrypted using 256-bit SSL/TLS. Connections over HTTP are automatically redirected to HTTPS.
• Storage encryption: Sensitive data fields including CNIC numbers, payment account references and passwords are encrypted at rest using AES-256 encryption.
• Password security: Member passwords are stored as salted cryptographic hashes. 92 Cocoa staff cannot view your password in plain text.
• Two-factor authentication: 92 Cocoa supports SMS-based two-factor authentication for account login. We strongly encourage all members to enable 2FA for maximum account security.
• Access controls: Internal access to member data is restricted on a strict need-to-know basis. Support staff can access account status but not payment credentials or CNIC data.
• Regular security audits: 92 Cocoa undergoes periodic security reviews to identify and address potential vulnerabilities before they can be exploited.

11. Your Privacy Rights

As a 92 Cocoa member, you have the following rights over your personal data. To exercise any of these rights, email support@92cocoa.net with the subject line "Privacy Rights Request" and we will respond within 30 days.

12. Children's Privacy

92 Cocoa is strictly an 18+ platform. We do not knowingly collect personal data from anyone under the age of 18. If we discover that a registered account belongs to a minor, the account will be suspended immediately, any balance will be frozen pending investigation, and the matter will be handled in accordance with our Responsible Gaming policy.

If you are a parent or guardian and believe your child may have registered on 92 Cocoa, please contact us immediately at support@92cocoa.net with the subject "Underage Account". We will investigate and close the account within 24 hours of confirmed notification.

13. Marketing Communications

92 Cocoa may send you promotional SMS messages, WhatsApp updates and email communications about new features, bonuses, seasonal promotions and events on the platform. We only send marketing communications to members who have explicitly opted in during registration or through their account settings.

• You can opt out of marketing communications at any time by contacting support@92cocoa.net or by updating your notification preferences in your 92 Cocoa account settings.
• Opting out of marketing communications does not affect transactional messages — you will still receive SMS notifications for deposits, withdrawals and security events on your account.
• 92 Cocoa does not send cold marketing messages to non-members. If you receive a message claiming to be from 92 Cocoa and you do not have an account, please report it to support@92cocoa.net as it may indicate a phishing attempt.

14. Data Breach Notification

In the unlikely event of a data security breach that affects your personal information, 92 Cocoa will take the following steps:

• Contain the breach as quickly as possible and assess the scope of data affected.
• Notify affected members via their registered mobile number and email address within 72 hours of becoming aware of the breach, where the breach is likely to result in a risk to your rights.
• Provide clear information about what data was affected, what steps we have taken to address the breach and what actions you should take to protect yourself.
• Report the breach to relevant regulatory authorities as required by applicable law.

To minimise your own risk, we recommend that you enable two-factor authentication on your 92 Cocoa account and use a unique, strong password that is not shared with any other service.

15. Changes to This Privacy Policy

92 Cocoa may update this Privacy Policy from time to time to reflect changes in our data practices, platform features or applicable law. When we make material changes to this policy, we will notify you via SMS to your registered mobile number and display a notice within the platform when you next log in.

We encourage you to review this Privacy Policy periodically. The effective date at the top of the page indicates when the most recent update was made. If you continue using 92 Cocoa after a policy update, you are accepting the revised Privacy Policy. If you disagree with any update, you may close your account and request data deletion by contacting support.

16. Contact Us About Your Privacy

If you have any questions, concerns or requests regarding this Privacy Policy or the way 92 Cocoa handles your personal data, please contact us through any of the following channels:

• Email: support@92cocoa.net — use the subject line "Privacy Request" for the fastest routing to our data team. We respond within 2 business hours during standard hours and within 24 hours at all other times.
• Live Chat: Available 24/7 on the 92 Cocoa platform in both Urdu and English. Our support team can answer general privacy questions or escalate specific data requests to the appropriate team.

All privacy rights requests (access, correction, deletion, portability) are handled by our dedicated compliance team and will be acknowledged within 48 hours with an estimated completion timeline. Complex requests may take up to 30 days to fulfil.