Privacy Policy — doen55

This Privacy Policy ("Policy") is issued by doen55 ("doen55", "we", "us", "our") and governs the collection, processing, storage, use and disclosure of personal data obtained through your access to and use of the doen55 website at https://doen55.cam and all related services, features and content (collectively, the "Platform").

doen55 is an English-language online betting and casino information platform designed specifically for users in Pakistan. We are committed to handling your personal data responsibly, transparently and in accordance with internationally recognised data protection principles.

By registering an Account, using the Platform or providing us with your personal information in any way, you confirm that you have read and understood this Privacy Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you must cease using the Platform immediately.

The following terms, as used in this Policy, have the meanings set out below:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly, including but not limited to name, email address, phone number, IP address, device identifier and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, doen55 acts as Data Controller in respect of data collected through the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a written agreement.
• "User" / "you" means any individual who accesses or uses the Platform.
• "Account" means the registered user profile created by a User upon successful completion of the registration process.
• "KYC" means Know Your Customer — the identity and document verification process required for anti-money laundering compliance.
• "Cookies" means small text files placed on your device by the Platform to store preferences, session data and analytics information.
• "Third Party" means any entity other than doen55 and the User.

doen55 collects Personal Data through multiple channels. The categories of data we collect, and the specific data points within each category, are set out in the table below.

We collect your Personal Data through the following means:

• Direct collection: When you register an Account, complete KYC verification, make a deposit or withdrawal, contact our support team, respond to a survey or participate in a promotion, you provide data to us directly.
• Automated collection: When you use the Platform, our servers and analytics tools automatically record technical and usage data, including IP address, device identifiers, browser data, session timestamps and in-Platform behaviour.
• Cookies and similar technologies: The Platform uses cookies, web beacons and similar tracking technologies to collect session data, remember preferences, prevent fraud and analyse usage patterns. See Section 8 for details.
• Third-party sources: We may receive information about you from third-party payment processors (e.g. to confirm a transaction), identity verification providers (for KYC purposes), fraud-prevention services and, where permitted, publicly available sources.
• Referral data: If you were referred to doen55 through a promotional or affiliate link, we may receive data from the referring party to track the referral origin.

We do not knowingly collect data from persons under 18 years of age. If we become aware that a minor has provided Personal Data to us, we will delete that data promptly and close the associated Account.

doen55 processes your Personal Data on one or more of the following legal bases, depending on the nature of the data and the purpose for which it is processed:

• Contractual necessity: Processing required to perform the contract with you — for example, creating your Account, processing deposits and withdrawals, and delivering the Services described in the Terms & Conditions.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, KYC obligations and responsible gambling regulations imposed by the Operator's license jurisdiction.
• Legitimate interests: Processing necessary for doen55's legitimate business interests where those interests are not overridden by your rights and freedoms — including fraud prevention, Platform security, analytics and business improvement.
• Consent: Processing based on your freely given, specific and informed consent — for example, sending you promotional and marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Vital interests: In exceptional circumstances, processing may be necessary to protect the vital interests of a data subject — for example, sharing data with emergency services if there is an imminent risk to life.

doen55 uses the Personal Data we collect for the following purposes. We will not use your data for any purpose incompatible with the original collection purpose without your prior consent or a legitimate legal basis.

• Account management: To create, maintain, authenticate and manage your doen55 Account, including password resets, session management and Account settings updates.
• Service delivery: To provide access to betting markets, casino games, live dealer tables, and all other features of the Platform.
• Payment processing: To facilitate deposits and withdrawals in PKR through available payment methods, and to maintain accurate financial records.
• Identity verification (KYC): To verify your identity and age in compliance with the Operator's AML obligations and responsible gambling requirements.
• Fraud prevention and security: To detect, investigate and prevent fraudulent transactions, unauthorised Account access, bonus abuse and other prohibited activities.
• Responsible gambling: To monitor betting and gaming patterns that may indicate problematic behaviour, to enforce deposit/loss/time limits you have set, and to support self-exclusion requests.
• Customer support: To respond to your queries, resolve disputes, process complaints and provide technical assistance.
• Legal compliance: To meet our obligations under applicable laws, including data retention requirements, regulatory reporting and responding to lawful requests from authorities.
• Platform improvement: To analyse usage data and feedback to improve the Platform's features, content, performance and user experience.
• Marketing and promotions: To send you personalised promotional offers, bonus notifications and Platform updates — but only where you have given your consent or where we have a legitimate interest and you have not opted out.

doen55 does not sell your Personal Data to third parties. We may share your data with the following categories of recipients, strictly to the extent necessary for the purposes described in this Policy:

• Game and platform technology providers: Third-party suppliers of casino games, sports data feeds, live dealer studios and platform infrastructure who process data as Data Processors on our behalf under written agreements.
• Payment processors: Entities facilitating deposit and withdrawal transactions, including technical processors for familiar Pakistani payment methods such as Easypaisa, JazzCash, Raast and bank transfers (HBL, UBL, Meezan Bank, Bank Alfalah). Sharing is limited to what is necessary to complete the transaction. None of these providers are implied to endorse gambling.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and document authenticity in compliance with regulatory requirements.
• Fraud prevention and security services: Specialist providers engaged to protect the Platform and its users from fraud, collusion and cyber threats.
• Regulatory authorities: Applicable gambling regulators, law enforcement agencies and government authorities, where we are legally required to disclose data — for example, in response to a court order or AML reporting obligation.
• Professional advisers: Legal counsel, auditors and compliance consultants engaged in the course of our business, subject to confidentiality obligations.
• Business transfer: In the event of a merger, acquisition, restructuring or sale of all or part of doen55's business, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

doen55 uses cookies and similar technologies to enhance your experience on the Platform, maintain session state, prevent fraud and collect analytics data. By using the Platform, you consent to our use of cookies in accordance with this section.

You can control cookie settings through your browser's privacy settings. Note that disabling essential cookies will impair Platform functionality. For analytics and marketing cookies, you may opt out at any time through the cookie preference centre accessible in the Platform footer.

doen55 retains your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any applicable legal, regulatory, accounting or reporting obligations. The following general retention periods apply:

• Account and registration data: Retained for the duration of your Account's active life, plus a minimum of five (5) years after Account closure, to comply with AML record-keeping requirements.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of last transaction or Account closure, as required by applicable AML regulations.
• Financial transaction records: Retained for a minimum of seven (7) years from the date of each transaction, as required by financial regulations and tax law.
• Customer support communications: Retained for three (3) years from the date of closure of the relevant support ticket.
• Technical and usage logs: Retained for up to twelve (12) months for platform security and analytics purposes, after which they are anonymised or deleted.
• Marketing consent records: Retained for the period of the marketing relationship and for three (3) years thereafter to evidence consent and opt-out history.

When data is no longer required, we will securely delete or anonymise it in accordance with our data destruction procedures. Where anonymisation is applied, the resulting data no longer constitutes Personal Data and may be retained indefinitely for statistical purposes.

doen55 implements appropriate technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your browser and our servers is encrypted using industry-standard TLS/SSL encryption. Always verify the padlock symbol in your browser's address bar before entering credentials.
• Password security: User passwords are stored using strong one-way hashing algorithms. We never store or transmit passwords in plain text.
• Access controls: Access to Personal Data is restricted to doen55 staff and authorised Data Processors on a strict need-to-know basis. All access is logged and audited.
• Encrypted data storage: Sensitive data, including KYC documents and financial records, is stored in encrypted databases with restricted access permissions.
• Penetration testing and security audits: The Platform undergoes periodic security assessments by qualified information security professionals to identify and remediate vulnerabilities.
• Incident response procedures: We maintain documented data breach response procedures. In the event of a material security breach affecting your data, we will notify you and the applicable regulatory authority within the timeframes required by law.

doen55 operates globally and may transfer your Personal Data to, and store it on, servers located in countries outside Pakistan. These countries may have data protection laws that differ from those in Pakistan.

When we transfer Personal Data outside Pakistan to countries not deemed to provide an equivalent level of data protection, we implement appropriate safeguards to ensure that your data remains protected to a standard consistent with this Policy. These safeguards may include:

• Standard contractual clauses agreed between doen55 and its Data Processors, requiring the Data Processor to protect data to an equivalent standard.
• Binding corporate rules where applicable within a corporate group.
• Transfers to jurisdictions that are recognised as providing adequate data protection by relevant regulatory authorities.

By using the Platform and providing your Personal Data, you acknowledge and consent to the transfer, storage and processing of your data as described in this Section.

Subject to applicable law, you have the following rights in respect of your Personal Data held by doen55. You may exercise these rights by contacting us using the details in Section 16. We will respond to all valid requests within a reasonable period — typically within 30 calendar days, though complex requests may take longer, in which case we will notify you.

• Right of Access: You have the right to request a copy of the Personal Data we hold about you, together with information about how we use it. This is commonly known as a Subject Access Request (SAR).
• Right to Rectification: You have the right to request correction of inaccurate or incomplete Personal Data. You may update most Account details directly through your Account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other lawful basis for processing. Note that this right is subject to our legal obligations to retain certain data (e.g. AML records).
• Right to Restrict Processing: You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while a rectification request is under review.
• Right to Data Portability: Where processing is based on your consent or a contract, 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, and to transmit it to another data controller.
• Right to Object: You have the right to object to Processing carried out on the basis of our legitimate interests, including profiling and direct marketing. You may unsubscribe from marketing communications at any time via the unsubscribe link in our emails or by contacting support.
• Right to Withdraw Consent: Where Processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.

The Platform is strictly intended for adults aged 18 and above, or the higher minimum age required by the Operator's license jurisdiction. doen55 does not knowingly collect, process or retain Personal Data from persons under the applicable minimum age.

If you are a parent or guardian and you believe that a minor has registered an Account on the Platform or provided Personal Data to us without your knowledge, please contact us immediately at [email protected]. Upon verification of such a report, we will:

• Immediately suspend and permanently close the minor's Account.
• Void and reverse any transactions processed through that Account to the extent practicable.
• Delete all Personal Data associated with the Account from our systems, subject to any mandatory legal retention obligations.

The Platform may reference or interact with third-party services, including payment providers, game technology partners and analytics tools. doen55's Policy applies only to data collected through the Platform itself. We are not responsible for the privacy practices of third-party services.

When you use third-party payment services — for example, completing a transaction through a payment provider familiar to Pakistani users such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — that provider's own privacy policy and data practices apply to the data you share with them directly. doen55 is not responsible for how those providers handle your data beyond what is specified in our agreements with them as Data Processors.

We encourage you to review the privacy policies of any third-party service you use in connection with the Platform. References to these payment providers are for user context only and do not imply their endorsement of gambling or any partnership beyond payment processing.

doen55 reserves the right to update, modify or replace this Privacy Policy at any time. Changes may be made to reflect updates in applicable data protection law, changes to our data processing practices, new product features or improvements to our security measures.

When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page. Where the changes significantly affect your rights or how we use your data, we may also notify you by email or through a Platform notification prior to the changes taking effect.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any change, you must stop using the Platform and may request Account closure by contacting our support team.

If you have any questions, concerns or complaints about this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 12, please contact the doen55 Data Protection team using the details below. We aim to respond to all privacy-related enquiries within 30 calendar days.

When submitting a data rights request, please include your registered Account username, the email address associated with your Account, and a clear description of your request. This will allow us to verify your identity and process your request as efficiently as possible.