btqq Privacy Policy —
How We Protect Your Data
as a Pakistani Player

1.1 Data Controller. btqq operates the online gaming and sports betting platform accessible at btqq.net. For the purposes of applicable data protection laws, btqq is the data controller responsible for the personal data collected through the Platform. As data controller, btqq determines the purposes and means of processing your personal data.

1.2 Contact Information. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by btqq, you may contact our dedicated data protection support team. The btqq support team is available via live chat 24 hours a day, seven days a week, from within your logged-in btqq account. You may also contact us by email using the address displayed in the footer of the Platform. We aim to acknowledge all data-related enquiries within two (2) business days and to provide a substantive response within twenty-eight (28) calendar days of receipt.

1.3 Data Protection Queries. For formal data subject rights requests — including access, rectification, erasure, portability, restriction of processing, or objection requests — please contact btqq support in writing by email, clearly identifying the nature of your request and including sufficient information to verify your identity. btqq will not process data subject rights requests from unverified individuals in order to protect the privacy of all account holders.

2.1 Registration Data. When you create a btqq account, we collect the information you provide during the registration process. This includes your full legal name, date of birth, email address, Pakistani mobile number, and any other information requested at the time of registration. This information is necessary to create and manage your account and to verify that you meet the minimum age requirement of 21 years.

2.2 Identity Verification (KYC) Data. To comply with our anti-money laundering obligations and to process withdrawals, btqq collects identity verification documents from players. These may include: (a) a copy of a valid, government-issued photo identification document such as a Pakistani National Identity Card (CNIC), Passport, or Driving Licence; and (b) documentation evidencing ownership of the payment method used for deposits. Additional documentation may be requested where required by our compliance obligations.

2.3 Financial and Transaction Data. btqq collects records of all financial transactions associated with your account, including deposits, withdrawals, bonus credits, bonus wagering activity, and game results. Transaction records include amounts in Pakistani Rupees, dates, times, payment methods used (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or Bank Transfer), and transaction reference numbers.

2.4 Gaming Activity Data. btqq maintains records of your gaming activity on the Platform, including the games played, bets placed, outcomes, session durations, and timestamps. This data is used to administer your account, resolve disputes, identify problem gambling behaviour, and improve the Platform's game offerings for Pakistani players.

2.5 Technical and Device Data. When you access the btqq Platform, we automatically collect certain technical data including your IP address, browser type and version, operating system, device type, screen resolution, and referring URL. This information is used for Platform security, fraud prevention, and to optimise the Platform's performance on the devices commonly used by Pakistani players.

2.6 Communications Data. btqq retains records of communications between you and our support team, including live chat transcripts and email correspondence. These records are used for quality assurance, dispute resolution, training purposes, and to maintain an accurate record of any commitments or representations made to you by btqq.

btqq uses the personal data collected from Pakistani players for the following specific purposes:

• Account Creation and Management: To register, maintain, and administer your btqq account, including processing deposits, crediting bonuses, and managing withdrawals to your preferred Pakistani payment method.
• Identity Verification and Compliance: To verify your identity, confirm your age (21+ requirement strictly enforced), and satisfy our anti-money laundering and regulatory compliance obligations under applicable laws.
• Provision of Gaming Services: To provide you with access to the full btqq Platform, including casino games, sports betting, crash games, and all other services available to registered players.
• Customer Support: To respond to your enquiries, resolve disputes, provide technical assistance, and communicate with you regarding your btqq account.
• Fraud Prevention and Security: To detect, investigate, and prevent fraud, money laundering, bonus abuse, and other prohibited activities on the Platform. This includes monitoring gaming activity patterns for signs of unauthorised access or suspicious behaviour.
• Responsible Gaming: To identify players who may be at risk of problem gambling, to enforce responsible gaming limits set by players, and to process self-exclusion requests promptly and effectively.
• Platform Improvement: To analyse aggregated and anonymised usage data to understand how Pakistani players interact with the Platform and to make evidence-based improvements to the gaming experience.
• Marketing Communications: Where you have given your explicit consent, to send you information about btqq promotions, bonuses, and new game launches relevant to your interests. You may withdraw your marketing consent at any time.
• Legal Compliance: To comply with applicable laws, regulations, court orders, and requests from regulatory or law enforcement authorities.

btqq processes personal data only where there is a recognised legal basis for doing so. The legal bases relied upon by btqq are as follows:

• Contractual Necessity: Processing necessary for the performance of the contract between you and btqq — specifically, the Terms and Conditions governing your use of the btqq Platform. This covers account management, game provision, payment processing, and withdrawal handling.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money laundering laws, age verification requirements, tax reporting obligations, and responses to lawful regulatory or law enforcement requests.
• Legitimate Interests: Processing necessary for btqq's legitimate interests, provided those interests are not overridden by your data protection rights. Legitimate interests pursued by btqq include fraud prevention, Platform security, responsible gaming monitoring, and improvement of gaming services for Pakistani players.
• Consent: Where btqq relies on your consent as the legal basis for processing — primarily for direct marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal.

5.1 Third-Party Service Providers. btqq shares personal data with carefully selected third-party service providers who assist in the operation of the Platform. These include: identity verification and KYC providers; payment processors (including those facilitating JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank transactions); game providers who supply casino and sports betting content; fraud detection and cybersecurity service providers; and customer support platform providers. All third-party service providers are contractually required to process personal data only on btqq's instructions and to maintain appropriate security standards.

5.2 Regulatory and Law Enforcement Authorities. btqq may disclose personal data to regulatory bodies, gaming commissions, financial intelligence units, law enforcement agencies, or courts where required to do so by applicable law, regulation, or valid legal process. btqq will notify affected players of such disclosures where legally permitted to do so.

5.3 Business Transfers. In the event that btqq undergoes a merger, acquisition, restructuring, or sale of all or part of its business assets, personal data held about registered players may be transferred to the acquiring or successor entity as part of that transaction. Affected players will be notified of any such transfer and any material change to the Privacy Policy that may result from it.

5.4 No Sale of Personal Data. btqq does not sell, rent, lease, or otherwise transfer personal data to third parties for their own commercial or marketing purposes. This commitment applies without exception to all personal data collected from Pakistani players using the btqq Platform.

6.1 Cross-Border Processing. As an internationally licensed online gaming platform serving players in Pakistan and other jurisdictions, btqq may transfer personal data to and process it in countries other than the country in which it was originally collected. This may include transfers to the jurisdiction in which btqq is licensed, and to the locations of our third-party service providers.

6.2 Safeguards. Wherever personal data is transferred outside of Pakistan to jurisdictions that may not provide a level of data protection equivalent to international standards, btqq ensures that appropriate safeguards are in place. These safeguards include: contractual clauses that impose data protection obligations on the recipient; technical measures including encryption in transit and at rest; and access controls that restrict who can access transferred data.

6.3 Player Rights in Transfers. If you would like further information about the specific safeguards applied to international transfers of your personal data, you may contact btqq's support team. We will respond with details of the applicable safeguards within a reasonable timeframe.

7.1 Use of Cookies. btqq uses cookies and similar tracking technologies on the Platform to ensure the proper functioning of your gaming session, to remember your preferences, to analyse Platform performance, and to support fraud detection systems. Cookies are small text files stored on your device by your browser when you visit the btqq Platform.

7.2 Types of Cookies Used. The following categories of cookies are deployed on the btqq Platform:

7.3 Cookie Management. You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from using the btqq Platform, as these cookies are essential for login session management and game functionality. Disabling analytical or functional cookies will not affect your ability to play but may reduce the personalisation of your btqq experience.

8.1 Retention Principle. btqq retains personal data for no longer than is necessary for the purpose for which it was originally collected, or for such longer period as is required to comply with applicable legal, regulatory, tax, and anti-money laundering obligations. The specific retention periods applied by btqq are as follows:

• Account and Registration Data: Retained for the duration of the account and for a minimum period of five (5) years following account closure, in accordance with applicable regulatory requirements.
• Identity Verification (KYC) Documents: Retained for a minimum of five (5) years from the date of verification, in accordance with anti-money laundering regulations applicable to internationally licensed gaming operators.
• Financial and Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with applicable financial record-keeping requirements.
• Gaming Activity Records: Retained for the duration of the account and for a period of three (3) years following account closure, unless extended retention is required for dispute resolution or regulatory compliance purposes.
• Customer Support Communications: Retained for a period of two (2) years from the date of the most recent communication in a particular matter.
• Marketing Consent Records: Retained for as long as the consent is active and for a period of two (2) years following consent withdrawal, as evidence of the consent having been obtained and subsequently withdrawn.

8.2 Secure Deletion. Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with btqq's data deletion procedures. Anonymised data — from which individual players cannot be identified — may be retained indefinitely for statistical and analytical purposes.

As a data subject, you hold a number of rights in relation to the personal data held about you by btqq. These rights are detailed below. To exercise any of these rights, please contact the btqq support team in writing by email from the address registered on your btqq account. btqq will verify your identity before processing any data subject rights request.

• Right of Access: You have the right to request a copy of the personal data btqq holds about you, along with information about how it is being used, where it came from, and who it has been shared with.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you by btqq. Many types of account information can be updated directly from your btqq account settings without contacting support.
• Right to Erasure ("Right to be Forgotten"): You have the right to request deletion of personal data that btqq holds about you, subject to btqq's legal obligations to retain certain categories of data for minimum statutory periods.
• Right to Restriction of Processing: You have the right to request that btqq restricts the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or where processing is unlawful but you prefer restriction over erasure.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to btqq's processing of your personal data where that processing is based on btqq's legitimate interests. You also have an unconditional right to object to the use of your personal data for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

10.1 Technical Safeguards. btqq implements comprehensive technical security measures to protect the personal data of Pakistani players against unauthorised access, accidental loss, destruction, or disclosure. These measures include: 256-bit SSL/TLS encryption for all data in transit between your device and btqq servers; AES-256 encryption for sensitive data stored at rest; multi-factor authentication options for player accounts; real-time intrusion detection and monitoring systems; regular penetration testing conducted by independent cybersecurity specialists; and strict access controls limiting data access to authorised btqq personnel on a need-to-know basis only.

10.2 Organisational Safeguards. In addition to technical measures, btqq maintains organisational safeguards including data protection training for all personnel with access to personal data, clear internal policies governing data handling and access, due diligence procedures for third-party service providers, and documented procedures for responding to personal data breaches.

10.3 Data Breach Response. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, btqq will notify the relevant supervisory authority as required by applicable law and will notify affected players without undue delay where the breach is likely to result in a high risk to their rights and freedoms. Notifications to affected Pakistani players will be sent to the email address registered on their btqq account.

10.4 Player Responsibility. While btqq implements robust security measures, players are also responsible for maintaining the security of their account credentials. You should use a strong, unique password for your btqq account, enable two-factor authentication where available, and never share your login details with any other person. btqq will never ask for your password through any channel.

11.1 Minimum Age Requirement. The btqq Platform is strictly for adults aged 21 years and above. btqq does not knowingly collect personal data from individuals under the age of 21. All players are required to confirm their age during registration and to provide satisfactory proof of age during identity verification.

11.2 Discovery of Minor's Data. If btqq discovers or is notified that personal data belonging to a person under the age of 21 has been collected — whether through a fraudulent registration or otherwise — btqq will immediately suspend the associated account, delete all personal data associated with the account (except where retention is required for legal compliance purposes), and permanently ban the associated identity from the Platform.

11.3 Parental Guidance. If you are a parent or guardian and you believe that a minor in your care has accessed or registered on the btqq Platform, please contact btqq support immediately. btqq will investigate the matter promptly, take all appropriate action to close the account and delete associated data, and cooperate fully with any parental or law enforcement inquiry.

12.1 Right to Amend. btqq reserves the right to amend, update, or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The current version of the Privacy Policy is always accessible on the btqq Platform and is dated with its effective date at the top of this document.

12.2 Material Changes. Where proposed changes to this Privacy Policy are material — meaning they significantly affect your rights or the way in which btqq processes your personal data — btqq will provide reasonable advance notice to registered Pakistani players via email to the address registered on their account, or via a prominent notice displayed on the Platform. Minor clarificatory changes that do not affect the substance of the policy may be made without advance notice.

12.3 Continued Use. Your continued use of the btqq Platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the updated Privacy Policy, you should cease using the Platform and, if you wish to exercise your right to erasure, contact btqq support to request deletion of your account and personal data subject to applicable legal retention obligations.

12.4 Version History. This is the Privacy Policy effective as of 1 January 2026. Previous versions of the btqq Privacy Policy are available upon request by contacting btqq support. btqq maintains an internal version history of all Privacy Policy documents.