fly99 Privacy Policy

fly99 ("fly99", "we", "us", "our") operates the online gaming platform accessible at https://fly99.lol (the "Platform"). This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by fly99.

This Policy applies to all individuals who access or use the fly99 Platform, including registered account holders, visitors who browse without registering, and persons who contact us through any channel including live chat or email. By accessing the Platform or submitting any personal information to fly99, you acknowledge that you have read and understood this Policy.

This Policy should be read in conjunction with fly99's Terms & Conditions, which together constitute the full legal framework governing your relationship with fly99.

fly99 is the data controller in respect of the personal information collected and processed through the Platform. As data controller, fly99 determines the purposes and means by which personal data is processed.

For all data protection and privacy enquiries, players may contact fly99 through the support channels listed in Section 15 of this Policy. fly99 is committed to responding to all data-related requests within a reasonable timeframe, and in any event within thirty (30) calendar days of receipt.

fly99 collects the following categories of personal data from users of the Platform:

fly99 does not intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, or health information. If you voluntarily disclose such information in a support communication, it will be used only to resolve the specific matter and will not be stored or processed beyond that purpose.

fly99 collects personal data through the following means:

• Direct interactions: When you register an account on fly99, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in any promotion, you provide personal data directly to us.
• Automated technologies: When you access the fly99 Platform, we automatically collect Technical Data via cookies, server logs, and similar tracking technologies. See Section 7 for full details.
• Third-party payment processors: When you use JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, or USDT TRC20 to transact with fly99, we receive confirmation and reference data from the relevant payment processor.
• Identity verification providers: fly99 may use third-party KYC service providers to verify your identity. These providers may return data about the outcome of identity checks to fly99.
• Fraud and security tools: fly99 uses security and fraud-detection systems that analyse Technical and Usage Data to identify suspicious activity.

fly99 processes your personal data only where a valid legal basis exists. The following table summarises the primary purposes of processing and the corresponding legal basis for each:

fly99 does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 processors receive the minimum data required to authorise and complete your transactions. These entities are bound by their own data protection and financial regulation requirements.
• Identity verification providers: Third-party KYC and AML screening providers receive identity document data and biographic information solely for verification purposes. These providers act under strict data processing agreements with fly99.
• Game technology providers: Licensed game software providers may receive anonymised session and gameplay data for the purposes of game performance monitoring, RNG certification, and dispute resolution. This data does not identify you directly.
• Regulatory and law enforcement authorities: fly99 may disclose personal data to governmental, regulatory, or law enforcement bodies where legally required to do so, including in response to valid legal process or where disclosure is necessary to protect the safety of users or the public.
• Professional advisers: In limited circumstances, fly99 may share relevant data with legal counsel, auditors, or compliance consultants under obligations of confidentiality.

All third parties with whom fly99 shares personal data are required to process that data only for the stated purpose and to maintain appropriate security standards. fly99 does not permit third-party recipients to use your personal data for their own marketing or commercial purposes.

fly99 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small data files stored on your device when you visit the fly99 Platform. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function, including session management, fly99 Login authentication, and security. These cannot be disabled without affecting your ability to use the Platform.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and whether you have acknowledged specific notifications.
• Performance and analytics cookies: Collect anonymised data about how users interact with the Platform — which pages are visited most frequently, error events, and load times — to help us improve the experience.
• Security cookies: Assist fly99 in detecting and preventing fraudulent access, unusual login activity, and account takeover attempts.

You may control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Blocking strictly necessary cookies will impair your ability to use the Platform and may prevent fly99 Login from functioning. Please note that fly99 does not use third-party advertising cookies or behavioural profiling technologies for serving external advertisements.

fly99 retains personal data only for as long as is necessary to fulfil the purposes outlined in this Policy or as required by applicable regulatory or legal obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your account and for a minimum period of five (5) years following account closure, as required by AML and gaming regulatory obligations.
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of the transaction in compliance with financial record-keeping requirements.
• Communication and Support Data: Retained for two (2) years from the date of the communication, or longer if the communication relates to an ongoing dispute.
• Technical and Usage Data (logs): Typically retained for up to twelve (12) months, unless specific events such as fraud investigations require extended retention.
• KYC Documentation: Retained for the period required by the applicable licensing and AML obligations, typically five (5) years post-account closure.

Upon expiry of the applicable retention period, fly99 will securely delete or anonymise your personal data so that it can no longer be associated with your identity.

fly99 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• TLS encryption for all data transmitted between your device and the fly99 Platform, including during fly99 Login sessions.
• Encryption-at-rest for stored personal and financial data.
• Role-based access controls ensuring that personal data is accessible only to fly99 personnel who require it to perform their specific functions.
• Continuous security monitoring and intrusion detection systems.
• Regular security assessments and penetration testing of Platform infrastructure.
• Strict vendor security requirements for all third-party service providers who process personal data on fly99's behalf.

While fly99 takes all reasonable steps to protect your data, no system is completely immune to security incidents. In the event of a data breach that poses a risk to your rights and freedoms, fly99 will notify affected users as soon as reasonably practicable and will take prompt remedial action.

Subject to applicable law, you have the following rights in respect of your personal data held by fly99:

• Right of Access: You may request a copy of the personal data fly99 holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data. For most account data, you can update information directly through your fly99 account settings.
• Right to Erasure: In certain circumstances, you may request deletion of your personal data. Note that fly99 may be unable to fully comply with erasure requests where retention is required by law (for example, transaction records required for AML compliance).
• Right to Restriction of Processing: You may request that fly99 restrict processing of your data in specific circumstances, such as while a dispute about accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling for responsible gaming purposes, where you have grounds relating to your particular situation.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact fly99 using the details in Section 15. We will respond within 30 calendar days of receiving your request. We may need to verify your identity before processing a rights request.

The fly99 Platform is strictly intended for adults aged 21 years and over. fly99 does not knowingly collect, use, or retain personal data from any person under the age of 21. If you are under 21 years of age, you must not access the Platform, register an account, or provide any personal information to fly99.

If fly99 becomes aware that personal data has been collected from an individual under 21 years of age, we will take immediate steps to delete that data, close the associated account, and refund any deposited funds. Parents and guardians who believe that a minor has registered on fly99 should contact our support team immediately so that the account can be closed without delay.

fly99 may process or store personal data on servers located outside Pakistan. Where personal data is transferred internationally, fly99 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to or greater than the protections available in Pakistan.

Such safeguards may include contractual data processing agreements with receiving parties, standard contractual clauses approved by relevant data protection authorities, or reliance on the receiving country's adequacy status for data protection purposes. fly99 does not transfer personal data to jurisdictions that do not provide an adequate level of protection without appropriate safeguards in place.

The fly99 Platform does not contain links to external third-party websites for commercial or advertising purposes. Where links to internal fly99 pages are present — such as references to our Terms & Conditions, Responsible Gaming page, or FAQ — these are part of the fly99 Platform and are covered by this Policy.

If you navigate away from the fly99 Platform to any external site — for example via a payment processor's own interface during a transaction — fly99 has no control over and accepts no responsibility for the privacy practices or content of that external site. You should review the privacy policy of any third-party site you visit independently.

fly99 may update this Privacy Policy from time to time to reflect changes in our data practices, Platform features, regulatory requirements, or applicable law. The effective date shown at the top of this Policy reflects the date on which the current version came into force.

Where changes are material — meaning they affect how we use your personal data in a way that may be unexpected or that could significantly impact your rights — fly99 will notify registered users via in-Platform notification or email to your registered address prior to the changes taking effect.

You are encouraged to review this Policy periodically. Continued use of the fly99 Platform following any update constitutes your acceptance of the revised Policy. If you do not agree with any material change, you should cease using the Platform and contact fly99 support to arrange account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or to how fly99 processes your personal data, please contact us through any of the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly within the fly99 Platform.
• FAQ: Visit our FAQ page for answers to common questions about accounts and data.

fly99's support and data protection team aims to acknowledge all privacy-related requests within 48 hours and to provide a substantive response or data subject access report within 30 calendar days of the verified request being received.

Please ensure that your request clearly identifies the nature of your query — for example, whether you are requesting access to your data, requesting deletion, or objecting to a specific processing activity — so that our team can assist you as efficiently as possible.