hn55 Privacy Policy —
Your Data, Your Rights

1 Introduction & Scope

This Privacy Policy ("Policy") is published by hn55 ("hn55," "we," "us," or "our") and describes how hn55 collects, uses, stores, discloses, and otherwise processes personal data relating to individuals ("you," "User," or "Player") who access or interact with the hn55 online gaming and sports betting platform, available at hn55.app (the "Platform").

This Policy applies to all personal data collected through any channel operated by hn55, including the Platform website, mobile browser access, customer support communications, and any promotional or marketing communications hn55 may send to registered players. By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Policy.

hn55 is committed to processing personal data in a fair, transparent, and lawful manner in compliance with its international licensing obligations and applicable data protection frameworks. We apply the principle of data minimisation — collecting only what is genuinely necessary for each stated purpose.

2 Data Controller

For the purposes of applicable data protection law, hn55 is the data controller in respect of personal data collected from users of the Platform. As data controller, hn55 determines the purposes for which and the means by which personal data is processed.

All data processing carried out by hn55 is subject to the supervision of our designated Data Protection function. Any queries relating to this Policy, requests to exercise your privacy rights, or complaints about our data handling practices should be directed to our support team using the contact details set out in Section 14 of this Policy.

3 Data We Collect

hn55 collects personal data in three main ways: directly from you when you register or interact with the Platform, automatically when you use the Platform, and from third-party sources in connection with KYC and fraud prevention. The categories of data we collect are described below.

3.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, Pakistani mobile number, email address (where provided), and account credentials.
• KYC and Identity Verification Data: CNIC number, passport number (where applicable), date of issue, scanned copies of government-issued ID documents, and proof of address documents such as utility bills or bank statements.
• Payment Data: JazzCash mobile wallet number, EasyPaisa account details, bank account information (HBL, UBL, Meezan Bank, or other supported banks), and transaction reference numbers. hn55 does not store full payment card numbers where card processing is applicable.
• Support Communications: The content of any messages, complaints, or queries you submit to hn55 customer support via live chat or email.
• Responsible Gaming Preferences: Any deposit limits, session reminders, cooling-off periods, or self-exclusion requests you submit through the Account Settings section.

3.2 Data Collected Automatically

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and time zone.
• Usage Data: Pages visited, games played, bet amounts, session duration, login timestamps, and navigation patterns within the Platform.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, and similar technologies as described in Section 10 of this Policy.
• Geolocation Data: Approximate geographic location derived from IP address, used for regulatory compliance and fraud prevention. hn55 does not use GPS-level precision location tracking.

3.3 Data From Third Parties

• Identity verification results and risk scores from third-party KYC and age verification providers.
• Fraud risk signals from third-party fraud prevention and anti-money laundering screening services.
• Publicly available data used to verify the accuracy of information you have provided during registration or KYC.

4 How We Use Your Data

hn55 uses personal data for the following specific purposes. Where a legal basis applies to each purpose, it is identified in Section 5 of this Policy.

hn55 does not use your personal data to make fully automated decisions that produce significant legal effects without human review. Where automated fraud or risk scoring is used, decisions that result in account suspension or withdrawal restriction are reviewed by a member of the hn55 compliance team before being finalised.

5 Legal Basis for Processing

hn55 processes personal data only where a valid legal basis exists. The primary legal bases on which hn55 relies are as follows:

• Contractual Necessity: Processing required to perform the contract between hn55 and the player — including account management, game operation, deposits, and withdrawals.
• Legal Obligation: Processing required to comply with applicable law — including anti-money laundering obligations, KYC/age verification requirements under international gaming licence conditions, and regulatory reporting.
• Legitimate Interests: Processing carried out for hn55's legitimate business interests where those interests are not overridden by your fundamental rights — including fraud prevention, platform security, responsible gaming monitoring, and service improvement.
• Consent: Where hn55 relies on consent as a legal basis — specifically for optional marketing communications — that consent is freely given, specific, informed, and unambiguous. You may withdraw consent at any time by contacting hn55 support or adjusting your account notification preferences.

6 Sharing Your Data

hn55 does not sell personal data to third parties. We share personal data only in the following specific, disclosed circumstances:

• KYC & Identity Verification Providers: Third-party services engaged to verify your identity, age, and CNIC details as part of the KYC process. These providers are contractually bound to process data only for the stated verification purpose.
• Payment Processors: JazzCash, EasyPaisa, and banking partners (HBL, UBL, Meezan Bank) receive transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and applicable financial regulations.
• Fraud Prevention & AML Services: Specialist third-party platforms that screen transactions and account activity for fraud indicators and money laundering risk. Sharing with these services constitutes a legal obligation under hn55's licensing conditions.
• Regulatory Authorities: Where required by applicable law or a valid order from a competent regulatory or law enforcement authority, hn55 will disclose personal data without prior notice to you if legally required to do so.
• Technology Service Providers: Cloud hosting, customer support tooling, and analytics providers that operate as data processors on behalf of hn55 under data processing agreements containing appropriate contractual protections.
• Corporate Transactions: In the event of a merger, acquisition, or asset sale involving hn55, personal data may be transferred to a successor entity. Affected users will be notified in advance where legally and commercially permissible.

7 International Data Transfers

hn55 operates as an internationally licensed gaming platform and may process or store personal data in jurisdictions outside Pakistan. When personal data is transferred internationally, hn55 ensures that adequate safeguards are in place, which may include:

• Standard contractual clauses approved by relevant data protection authorities.
• Adequacy decisions where the destination country provides an equivalent level of data protection.
• Binding corporate rules where transfers occur within a group of companies subject to consistent data protection standards.

In all cases, hn55 applies the same security and access controls to internationally processed data as it does to data processed within its primary infrastructure.

8 Data Retention

hn55 retains personal data for no longer than is necessary for the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of the account relationship plus a minimum of five years following account closure, in compliance with AML record-keeping requirements under applicable gaming licence conditions.
• Transaction Records: Retained for a minimum of five years following the date of each transaction, or longer where required by applicable financial regulation.
• Support Communications: Retained for three years following the resolution of a support query, or longer if the communication relates to an ongoing dispute or regulatory investigation.
• Responsible Gaming Data: Retained for five years following account closure to support compliance monitoring, self-exclusion enforcement, and responsible gaming programme evaluation.
• Cookie and Usage Data: Session cookies expire at the end of each browser session. Persistent cookie data is retained for up to 12 months unless deleted earlier by the user.

Following the expiry of a retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an individual.

9 Security Measures

hn55 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between user devices and hn55 servers.
• AES-256 encryption for sensitive personal and financial data stored at rest.
• Role-based access controls ensuring that hn55 staff access personal data only to the extent required by their specific role.
• Two-factor authentication available for all registered hn55 accounts.
• Regular security vulnerability assessments and penetration testing of the Platform infrastructure.
• Intrusion detection systems and 24/7 security monitoring of the hn55 platform environment.
• Staff data protection training and strict internal data handling policies.

Notwithstanding these measures, no security system is impenetrable. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, hn55 will notify affected users and relevant regulatory authorities in accordance with applicable breach notification obligations.

10 Cookies & Tracking Technologies

hn55 uses cookies and similar tracking technologies to operate the Platform effectively, to maintain your login session, and to analyse usage patterns for the purpose of service improvement. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during a gaming session. These cannot be disabled without preventing Platform use.
• Functional Cookies: Store your preferences such as language settings, deposit limit selections, and responsible gaming configurations. Disabling these may affect the personalised functionality of your account.
• Analytics Cookies: Collect anonymised data about how users navigate the Platform — pages visited, session duration, and feature usage. This data is used to improve the hn55 user experience and is not linked to your personal identity.
• Security Cookies: Used to detect and prevent fraudulent activity, including session hijacking and CSRF attacks. These are strictly necessary and cannot be disabled.

Most web browsers allow you to manage cookie preferences through the browser settings menu. Clearing cookies will end your current session and may reset saved preferences. hn55 does not use third-party advertising cookies or cross-site tracking technologies for the purpose of serving behavioural advertising.

11 Your Privacy Rights

As a user of the hn55 Platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact hn55 support using the details in Section 14. hn55 will respond to verified requests within 30 days.

• Right of Access: You may request a copy of the personal data hn55 holds about you, together with information about how it is processed and who it has been shared with.
• Right to Rectification: If personal data hn55 holds about you is inaccurate or incomplete, you may request that it be corrected or completed without undue delay.
• Right to Erasure: In certain circumstances, you may request deletion of your personal data. Note that hn55 may be legally required to retain certain categories of data — such as transaction records and KYC documents — for minimum regulatory retention periods, which supersede a deletion request in those categories.
• Right to Restriction: You may request that hn55 restrict the processing of your personal data in certain circumstances, such as where you contest its accuracy or where processing is unlawful but you prefer restriction over deletion.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests at any time. hn55 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent — primarily for marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

12 Minors & Age Policy

The hn55 Platform is strictly for adults aged 21 years and above. hn55 does not knowingly collect personal data from individuals under the age of 21. All accounts are subject to age verification during the KYC process.

If hn55 discovers or has reasonable grounds to believe that an account belongs to a person under the age of 21, the account will be immediately suspended, all bonus balances forfeited, and real-money funds returned to the source payment method following KYC confirmation of the account holder's details. Any personal data collected from a confirmed minor will be deleted in accordance with applicable data protection obligations, except where retention is required for legal or regulatory purposes.

13 Changes to This Policy

hn55 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the services offered on the Platform. When material changes are made, hn55 will notify registered users via the mobile number on file or via the account notification system, with reasonable advance notice where the change affects how we process personal data.

The updated Policy will be published on this page with a revised effective date at the top. We recommend reviewing this Policy periodically. Continued use of the hn55 Platform after the effective date of an updated Policy constitutes your acknowledgment of the changes.

14 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to raise a complaint about how hn55 has handled your personal data, please contact our support team. hn55 is committed to resolving data privacy concerns promptly and fairly.

Where you are not satisfied with hn55's response to a privacy complaint, you may have the right to escalate your complaint to the data protection authority in the jurisdiction governing hn55's international gaming licence, or to seek judicial remedy under applicable law. hn55 will provide guidance on the applicable escalation route upon request.