we9 Privacy Policy

1.1 This Privacy Policy is issued by we9, the operator of the online gaming and sports betting platform accessible at we9.bio (hereinafter referred to as "we9", "we", "us", or "our"). we9 operates under a licence issued by an international gaming regulatory authority and is committed to handling all personal data in accordance with applicable data protection laws and privacy standards.

1.2 For the purposes of this Privacy Policy, we9 acts as the Data Controller in relation to the personal information collected through the we9 platform. As Data Controller, we9 determines the purposes and means of processing your personal data and is accountable for doing so in a lawful, fair, and transparent manner.

1.3 This policy applies to all users of the we9 platform, with particular relevance to registered account holders located in Pakistan. If you access we9 from a jurisdiction that has specific local data protection requirements, those requirements apply to the extent that they are applicable and not in conflict with we9's regulatory obligations.

2.1 we9 collects personal data across several categories. The table below outlines the primary categories of personal data we collect, the specific data points within each category, and the primary purpose for which each category is collected:

2.2 we9 does not intentionally collect any special categories of sensitive personal data — such as health information, political opinions, religious beliefs, or biometric data — unless specifically required and disclosed for regulatory compliance purposes.

3.1 Directly from You. The majority of personal data we9 holds about you is provided directly by you in the course of using the platform. This includes data entered during account registration, information provided during the KYC verification process, data entered when making deposits or withdrawal requests, and information shared when contacting our customer support team.

3.2 Automatically During Platform Use. When you access the we9 platform — whether through a desktop browser or a mobile device — our systems automatically collect certain technical data. This includes your IP address, device type, operating system, browser version, session duration, pages visited, and the features you interact with. This data is collected through server logs, session management systems, and first-party analytics tools.

3.3 Cookies and Similar Technologies. we9 uses cookies and similar tracking technologies to maintain your login session, remember your preferences, detect fraudulent activity, and analyse aggregate usage patterns on the platform. Full details of we9's cookie usage are provided in Section 7 of this Policy.

3.4 From Third-Party Payment Providers. When you make a deposit or withdrawal through JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, or cryptocurrency channels, the relevant payment provider shares transaction confirmation data — including transaction reference numbers and amounts — with we9 to facilitate account crediting or withdrawal processing.

3.5 From Identity Verification Services. Where we9 engages third-party KYC and age verification services to confirm your identity, those services may share verification outcomes and relevant identity confirmation data with we9 as part of the compliance process.

4.1 we9 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is necessary to provide you with the we9 platform services you have requested — including account management, payment processing, game access, and withdrawal services — is carried out on the basis that it is necessary for the performance of our contract with you.
• Legal Obligation: Processing that we9 is required to carry out under applicable law — including anti-money laundering (AML) compliance, age verification, regulatory reporting, and tax obligations — is carried out on the basis of legal obligation.
• Legitimate Interests: Processing that serves we9's legitimate business interests — including fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring — where those interests do not override your fundamental privacy rights.
• Consent: Where we9 processes data for purposes that are not covered by the above legal bases, such as the use of optional marketing communications or certain non-essential cookies, we will obtain your explicit consent before such processing begins. You may withdraw consent at any time.

5.1 we9 uses the personal data we collect for the following primary purposes:

• Account Creation and Management: Creating and maintaining your we9 account, verifying your identity, managing your balance, processing deposits and withdrawals in PKR, and maintaining an accurate record of your gaming history;
• KYC and Age Verification: Confirming that you are 21 years of age or older and verifying your identity before processing withdrawal requests, as required by we9's gaming regulatory licence;
• Payment Processing: Facilitating deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and cryptocurrency channels, and processing withdrawal requests to your registered payment method;
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, bonus abuse, money laundering, and other security threats to the platform;
• Responsible Gaming: Monitoring gaming activity to identify patterns consistent with problem gambling behaviour and enforcing responsible gaming limits, cooling-off periods, and self-exclusion requests;
• Customer Support: Providing assistance to players who contact we9's support team via live chat or email, and maintaining records of interactions for quality assurance and dispute resolution;
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the we9 platform, optimise game loading performance on Pakistani mobile networks, and enhance the user experience;
• Regulatory Compliance: Fulfilling we9's reporting obligations to its licensing regulatory authority, including the provision of transaction records and player activity data as required;
• Communications: Sending you account-related notifications — including deposit confirmations, withdrawal updates, security alerts, and bonus communications — via your registered Pakistani mobile number.

6.1 We Do Not Sell Your Data. we9 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. This is an unconditional commitment.

6.2 Service Providers. we9 shares personal data with third-party service providers who process data on our behalf under strict contractual data processing agreements. These service providers include:

• Payment processing partners — JazzCash, EasyPaisa, and banking partners — for the purpose of executing your deposit and withdrawal transactions;
• KYC and identity verification service providers, who assist with age confirmation and CNIC verification;
• Cloud infrastructure and data hosting providers, whose servers store we9 platform data in secure, access-controlled environments;
• Fraud detection and anti-money laundering technology providers;
• Game content providers — including Pragmatic Play, NetEnt, PG Soft, and Spadegaming — who receive session data necessary for game delivery and technical support.

6.3 Regulatory Authorities. we9 may be required to disclose personal data to its licensing regulatory authority, financial intelligence units, or law enforcement authorities where required by law, a court order, or a regulatory demand. We9 will notify you of any such disclosure where legally permitted to do so.

6.4 Business Transfers. In the event that we9 undergoes a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity as part of that transaction. We9 will notify affected users of any such transfer and of any resulting changes to this Privacy Policy.

7.1 we9 uses cookies — small data files stored on your browser or device — and similar tracking technologies to enable core platform functionality and to understand how players interact with the we9 platform. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the we9 platform to function correctly. They maintain your login session, store your language preference, and protect the platform against cross-site request forgery (CSRF) attacks. These cookies cannot be disabled without breaking the platform. No consent is required for these cookies as they are technically essential.
• Functional Cookies: These cookies remember your platform preferences — such as your preferred game lobby view or last-visited section — to improve your experience across sessions. These are activated based on your use of the platform.
• Analytics Cookies: we9 uses first-party analytics cookies to collect aggregated, anonymised data about how users navigate the platform — including which game categories are most accessed, how long sessions last, and what devices are most common among Pakistani users. This data informs platform improvement decisions. These cookies do not identify you personally.
• Security and Fraud Detection Cookies: These cookies assist we9's security systems in detecting unusual or suspicious activity patterns — including login from unrecognised locations or devices — that may indicate account compromise or fraudulent access attempts.

7.2 We9 does not use third-party advertising cookies, social media tracking pixels, or cross-site behavioural tracking technologies. Cookies placed on the we9 platform are limited to those serving direct operational, security, or improvement purposes for the we9 platform itself.

8.1 we9 retains personal data for only as long as is necessary to fulfil the purposes for which it was collected, and to meet we9's applicable legal, regulatory, and licensing obligations.

8.2 The following indicative retention periods apply to key categories of personal data held by we9:

• Account and Identity Data: Retained for the lifetime of your active we9 account, plus a minimum of five (5) years following account closure — to meet AML and licensing regulatory retention requirements;
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, in compliance with financial record-keeping obligations;
• Gaming Activity Data: Retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes;
• Customer Support Communications: Retained for three (3) years from the date of the interaction;
• Technical and Security Logs: Retained for ninety (90) days under rolling deletion, unless retained for longer as part of an active security investigation;
• Self-Exclusion Records: Retained for the duration of the self-exclusion period plus five (5) years thereafter, to prevent inadvertent re-registration during a declared exclusion period.

8.3 Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised using cryptographic deletion methods that prevent recovery of the original data.

9.1 we9 implements a comprehensive suite of technical and organisational security measures to protect the personal data of our Pakistani players against unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• 256-bit Transport Layer Security (TLS/SSL) encryption applied to all data transmitted between your device and the we9 platform;
• Encryption of personal data and financial information at rest within we9's database infrastructure;
• Role-based access controls ensuring that only authorised we9 personnel with a legitimate need can access specific categories of personal data;
• Multi-factor authentication requirements for internal we9 team members accessing systems that hold personal data;
• Continuous security monitoring, intrusion detection systems, and regular penetration testing;
• Secure password hashing — we9 stores only cryptographic hashes of user passwords, not passwords in readable form;
• Incident response procedures that ensure rapid containment of any data security event and timely notification to affected users and relevant authorities where required.

9.2 While we9 implements industry-standard security practices, no online system can guarantee absolute security. You are responsible for maintaining the confidentiality of your own we9 account credentials and for notifying us immediately at [email protected] if you suspect unauthorised access to your account.

10.1 As a we9 user, you hold a number of rights in relation to the personal data we hold about you. These rights are outlined below:

10.2 To exercise any of the above rights, please contact the we9 privacy team at [email protected] with the subject line "Privacy Rights Request." We9 will verify your identity before processing any request and will respond within 30 days. No fee is charged for exercising your privacy rights under standard circumstances.

11.1 we9 processes certain personal and gaming activity data specifically in service of its responsible gaming obligations. This processing is carried out in the legitimate interests of player welfare and is a condition of we9's international gaming licence.

11.2 Specifically, we9 uses gaming activity data — including session durations, betting patterns, loss trajectories, and deposit frequency — to identify players who may be exhibiting behaviours consistent with problem gambling. Where such patterns are identified, we9's responsible gaming team may proactively reach out to the affected player to offer support information or to suggest the use of voluntary self-limitation tools.

11.3 Self-exclusion data — including the duration and scope of a player's self-exclusion election — is stored securely and actively enforced throughout the exclusion period. We9 retains this data for a minimum of five years after the exclusion period ends to prevent inadvertent re-registration.

11.4 For full information on responsible gaming tools available at we9, please visit our Responsible Gaming page. 21+ only.

12.1 The we9 platform is strictly intended for persons aged 21 and above. we9 does not knowingly collect, store, or process personal data relating to individuals under the age of 21, and the platform is not directed at minors in any way.

12.2 If we9 becomes aware that personal data has been submitted by or on behalf of an individual under 21 years of age — whether through account registration or any other means — we9 will immediately delete that data and close the associated account, without prejudice to any other action we may take in accordance with our Terms and Conditions.

12.3 If you are a parent or guardian and believe that a minor under your care has registered on or submitted data to the we9 platform, please contact us immediately at [email protected] and we9 will investigate and take appropriate action promptly.

13.1 we9 may update this Privacy Policy from time to time to reflect changes in our data practices, the introduction of new platform features, regulatory developments, or changes in applicable privacy law. Any updated version will be published on this page with a revised "Effective Date" at the top of the document.

13.2 Where changes are material — meaning they significantly affect the way we9 processes your personal data or your rights over it — we9 will notify registered users via their registered Pakistani mobile number or through a notification displayed upon the next login to the we9 platform.

13.3 Your continued use of the we9 platform following the publication of a revised Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree with the revised Policy, please discontinue your use of the platform and contact support to request account closure.

14.1 If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about the way we9 is handling your personal data, please contact the we9 Privacy Team using the following details:

• Email (plain text — not a link): [email protected] — please use the subject line "Privacy Enquiry" or "Privacy Rights Request" as appropriate;
• Live Chat: Available 24/7 from the we9 platform — select "Privacy / Data Request" from the support topic menu;
• Languages: Privacy enquiries are handled in English and Urdu by dedicated staff.

14.2 we9 will acknowledge all privacy enquiries within 5 business days and will aim to resolve them within 30 calendar days. For complex requests involving large volumes of data, the resolution period may be extended by a further 60 days with notification to you.

14.3 If you are not satisfied with we9's response to your privacy concern, you have the right to escalate your complaint to the data protection supervisory authority relevant to your jurisdiction, or to the dispute resolution mechanism designated by we9's licensing regulatory authority.