SC999 Privacy Policy

This Privacy Policy ("Policy") is published by SC999 ("we", "us", "our"), the operator of the online gaming platform accessible at https://sc999.cam ("Platform"). It applies to all users of the Platform ("you", "your", "User") regardless of the country or city from which you access our services, including users based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and all other locations.

This Policy describes: (a) what personal data we collect from you; (b) the lawful basis on which we process it; (c) how and why we use it; (d) with whom we share it; (e) how long we retain it; (f) what rights you have in relation to your data; and (g) how to contact us about privacy matters.

This Policy should be read alongside our Terms & Conditions, which govern the overall contractual relationship between you and SC999. In the event of any conflict between this Policy and the Terms & Conditions on a privacy matter, this Policy shall prevail.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"), including but not limited to name, email address, date of birth, financial information and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, SC999.
• "Processor" means an entity that processes Personal Data on behalf of the Controller, such as a third-party payment service provider or analytics partner.
• "Consent" means freely given, specific, informed and unambiguous indication of the data subject's agreement to the processing of their Personal Data.
• "KYC" means Know Your Customer — the identity, age and address verification procedures undertaken pursuant to anti-money laundering and responsible gambling obligations.
• "Cookies" means small data files placed on your device by the Platform to support functionality, analytics and personalisation.
• "Third Party" means any person or entity other than you or SC999, including service providers, payment processors and analytics vendors.

SC999 collects personal data through several means, including information you provide directly, data generated through your use of the Platform, and information received from third parties in the course of compliance procedures.

3.1 Data You Provide Directly

3.2 Data Collected Automatically

When you access the Platform, we may automatically collect the following technical and behavioural data:

• IP address and approximate geolocation derived from it;
• Device type, operating system, browser type and version;
• Pages visited, time on page, click-path data and session duration;
• Referring URL and exit page;
• Unique device identifiers and cookie IDs.

3.3 Data from Third Parties

We may receive personal data about you from third parties in limited circumstances, including:

• Identity verification and fraud screening providers who assist with KYC checks;
• Payment service providers confirming transaction outcomes;
• Anti-money laundering screening services checking against sanctions and PEP (Politically Exposed Person) lists.

SC999 processes personal data only where a valid legal basis exists. The principal legal bases on which we rely are as follows:

• Contractual Necessity — processing required to perform the contract with you, including account registration, game access, payment processing and withdrawal fulfilment.
• Legal Obligation — processing required to comply with applicable legal and regulatory requirements, including KYC, AML obligations, record-keeping requirements and response to lawful requests from competent authorities.
• Legitimate Interests — processing for purposes of fraud prevention, platform security, responsible gambling enforcement, and service improvement, where those interests are not overridden by your rights and interests.
• Consent — where you have given specific, informed and freely given consent to certain processing activities, such as receiving marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

SC999 processes personal data for the following purposes:

• To create, manage and maintain your Account and provide access to Platform services;
• To verify your identity and age in accordance with KYC requirements;
• To process deposits, withdrawals and transaction records;
• To detect, investigate and prevent fraud, money laundering, collusion and other prohibited conduct;
• To enforce our Terms & Conditions and respond to disputes;
• To operate responsible gambling tools, including self-exclusion administration and limit enforcement;
• To respond to your customer support enquiries;
• To send you service-related communications including account notifications and security alerts;
• To send you marketing communications where you have given consent or where permitted under applicable law — you may opt out at any time;
• To analyse Platform usage and improve user experience;
• To comply with applicable laws, regulatory requirements and lawful requests from competent authorities.

SC999 does not sell, rent or trade your personal data to third parties. We may share your data only in the following limited circumstances:

6.1 Service Providers (Data Processors)

We engage carefully selected third-party service providers who process data on our behalf, bound by contractual data processing obligations. These may include:

• Payment processors and cashier technology providers;
• KYC and identity verification technology providers;
• AML screening and fraud detection services;
• Cloud hosting and infrastructure providers;
• Customer support platform operators;
• Analytics and platform performance monitoring services.

6.2 Legal and Regulatory Disclosure

We may disclose personal data to competent governmental authorities, law enforcement agencies, licensing regulators or courts where we are required to do so by applicable law, court order or valid legal process. We will, where legally permissible, endeavour to notify you of such disclosure.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of our business, your personal data may be transferred to a successor entity. We will take reasonable steps to ensure that your data continues to be processed in accordance with this Policy following any such transfer.

SC999 uses cookies and similar tracking technologies (such as pixel tags and local storage) on the Platform. Cookies allow us to recognise your device, maintain your session, personalise your experience and analyse Platform performance.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies — essential for the Platform to function. These cannot be disabled as they are required for login sessions, security tokens and responsible gambling limit enforcement.
• Performance & Analytics Cookies — used to collect aggregated, anonymised data about how users interact with the Platform, enabling us to improve functionality and performance.
• Functional Cookies — used to remember your preferences, such as language and display settings, to provide a more personalised experience.
• Marketing Cookies — used where consent has been given to serve relevant content. These may track browsing activity across sessions.

7.2 Managing Cookies

You may manage and disable cookies through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to access certain Platform features, including secure login. For performance and marketing cookies, browser-level controls or any consent management tool provided on the Platform allow you to adjust your preferences at any time.

SC999 operates as an international platform and your personal data may be processed in countries outside your country of residence, including countries that may not have data protection laws equivalent to those in your jurisdiction. Where we transfer personal data internationally, we take reasonable steps to ensure that appropriate safeguards are in place to protect your data, including contractual protections with our service providers.

By using the SC999 Platform and providing your personal data, you acknowledge and consent to the transfer and processing of your data in international jurisdictions as described in this Policy.

SC999 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including:

• For the duration of your active Account plus any mandatory post-closure retention period required by applicable law or regulatory obligation (typically five years for AML compliance records, though this may vary by jurisdiction);
• For the period necessary to resolve any outstanding disputes, complaints or legal claims;
• For the duration required to enforce self-exclusion or responsible gambling restrictions imposed on an account;
• For the period required by our operating licence conditions.

On expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data destruction procedures. Transaction records and KYC documentation are retained as required by AML legislation applicable to the operator's licensing jurisdiction.

SC999 implements technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure and unauthorised access. These measures include, but are not limited to:

• 256-bit TLS (Transport Layer Security) encryption for all data transmitted between your browser and our servers;
• Encryption at rest for sensitive stored data including identity documents;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Multi-factor authentication for internal administrative systems;
• Incident response procedures for detecting, investigating and mitigating data security events.

Subject to applicable data protection law and certain exceptions, you may have the following rights in relation to your personal data held by SC999:

These rights are described individually in the section below. To make a request, please contact us at [email protected] with a clear description of your request and sufficient information for us to verify your identity.