Introduction
This Privacy Policy ("Policy") describes how hh89 ("we", "us", "our", "Platform") collects, uses, stores, shares and protects personal data relating to users ("you", "your") who access or use the hh89 platform at https://hh89.cam.
hh89 is an English-language online betting and gaming information platform designed for Pakistani audiences. Given that our users are located primarily in Pakistan — including major cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — this Policy is written with the data privacy expectations of Pakistani users in mind, while also reflecting applicable international data protection standards.
By accessing or using hh89 — including by browsing the site, creating an account, making a deposit or placing a wager — you acknowledge that you have read and understood this Policy and that you consent to the processing of your personal data as described herein. If you do not agree to this Policy, please do not use the Platform.
This Policy should be read alongside the hh89 Terms & Conditions and Responsible Gambling Policy, both of which are available on this site and are incorporated herein by reference.
Definitions
"Personal Data"
Any information relating to an identified or identifiable natural person — directly (such as name, email address or CNIC number) or indirectly (such as device identifiers, IP addresses or location data).
"Processing"
Any operation performed on personal data, including collection, recording, storage, use, disclosure, transfer, erasure or destruction — whether automated or manual.
"Data Controller"
The entity that determines the purposes and means of processing personal data. For the purposes of this Policy, hh89 is the Data Controller with respect to personal data collected through the Platform.
"Data Processor"
A third party that processes personal data on behalf of hh89 under contractual instruction — for example, a payment processing provider or cloud hosting provider.
"Cookies"
Small text files placed on your device by websites you visit. hh89 uses cookies and similar technologies to operate the Platform and improve user experience as further described in Section 9.
"KYC"
Know Your Customer — identity and address verification documents required to comply with applicable anti-money laundering and platform security obligations.
Personal Data We Collect
hh89 collects personal data through several channels, including account registration, Platform use and KYC submissions. The categories of data we may collect include:
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, CNIC / passport / driving licence number | Registration & KYC |
| Contact Data | Email address, phone number, city of residence | Registration |
| Financial Data | Payment method details, transaction history, deposit/withdrawal records (PKR amounts) | Payment processing |
| Technical Data | IP address, browser type, device identifiers, operating system, session logs | Automatic — during Platform use |
| Usage Data | Pages visited, games played, bets placed, time on Platform, click-through patterns | Automatic — during Platform use |
| Communications Data | Support query content, live chat transcripts, email correspondence | When you contact support |
| Responsible Gambling Data | Self-exclusion requests, deposit limit settings, loss limit history | When limits or exclusions are set |
We do not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, genetic or biometric data, or medical information, except where strictly required by applicable regulatory obligations (for example, problem gambling support referrals).
How We Use Your Personal Data
hh89 processes personal data only for specified, explicit and legitimate purposes. The primary purposes for which we use your data are:
- Account management: Creating and maintaining your user account, authenticating logins and managing account settings.
- Payment processing: Handling deposits and withdrawals via payment methods — which may include bank transfers referencing familiar Pakistani payment infrastructure such as HBL, UBL, Meezan Bank, Bank Alfalah, Easypaisa, JazzCash or Raast where operationally supported. None of these providers endorse gambling or are affiliated with hh89.
- KYC compliance: Verifying identity and address to meet anti-money laundering obligations and to prevent underage access.
- Platform operation: Delivering sports betting markets, casino games, live dealer content, instant games and other Platform functionality.
- Customer support: Responding to queries, resolving disputes and actioning responsible gambling requests including self-exclusion.
- Fraud prevention and security: Detecting and preventing fraudulent activity, multi-accounting, bonus abuse and security threats.
- Legal compliance: Meeting obligations under applicable law including AML regulations, licensing requirements and data protection law.
- Platform improvement: Analysing anonymised usage patterns to improve Platform performance, content quality and user experience.
- Responsible gambling: Monitoring account activity to identify signs of problem gambling behaviour and applying self-imposed or operator-imposed limits.
Legal Bases for Processing
Where applicable data protection law requires a legal basis for processing personal data, hh89 relies on the following:
Contractual Necessity
Processing necessary to perform the contract between hh89 and you — including account management, payment processing, KYC verification and delivery of betting and gaming services.
Legal Obligation
Processing required to comply with applicable laws and regulations — including AML requirements, age verification obligations and responses to lawful requests from regulatory or law enforcement bodies.
Legitimate Interests
Processing for hh89's legitimate business interests where these are not overridden by your rights — including fraud detection, Platform security, analytics and business development. We conduct a balancing assessment before relying on this basis.
Consent
Where we rely on your consent — for example, for certain marketing communications or non-essential cookies — you have the right to withdraw consent at any time without affecting the lawfulness of prior processing.
Data Sharing & Disclosure
hh89 does not sell your personal data to third parties. We may share personal data in the following circumstances:
- Payment processors and financial service providers: To facilitate deposits and withdrawals. These entities act as Data Processors under contractual obligations that restrict how they may use your data.
- KYC and identity verification providers: Third-party services used to verify identity documents as part of our AML compliance programme.
- Platform technology providers: Cloud hosting, game content studios and analytics providers who process data on our behalf and are bound by appropriate data processing agreements.
- Regulatory and law enforcement bodies: Where required by applicable law, court order or regulatory request, we may disclose personal data to competent authorities.
- Fraud prevention and AML bodies: Where we are required or permitted to share data to prevent financial crime or protect the integrity of the Platform.
- Professional advisers: Lawyers, accountants and auditors bound by professional confidentiality obligations, where necessary for legitimate business purposes.
When hh89 shares data with Data Processors (third parties who process data on our behalf), we require contractual commitments that data is processed solely in accordance with our instructions, for the specified purpose only, and with appropriate security measures in place.
International Data Transfers
As an online platform with infrastructure and service providers potentially located in multiple countries, personal data collected by hh89 may be transferred to, stored in, or processed in countries other than your country of residence — including countries that may not have the same level of data protection legislation as your home jurisdiction.
Where such transfers occur, hh89 takes steps to ensure that appropriate safeguards are in place — which may include contractual clauses, data processing agreements or other recognised transfer mechanisms under applicable data protection law. Pakistani users should be aware that data protection law in Pakistan is evolving; hh89 nonetheless commits to applying reasonable international standards of data protection to all user data regardless of where it is processed.
Data Retention
hh89 retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. General retention guidelines include:
- Active account data: Retained for the duration of your account and for a period thereafter as required by applicable AML, gaming regulatory and tax retention obligations.
- Transaction records: Financial transaction data — including PKR deposit and withdrawal records — is typically retained for a minimum of five years to satisfy AML and accounting requirements.
- KYC documents: Retained for the period required by applicable regulatory obligations, which may be five years or more from account closure.
- Support communications: Retained for a reasonable period to allow for dispute resolution and quality monitoring, typically up to three years.
- Responsible gambling records: Self-exclusion history and limit records may be retained for extended periods to prevent inadvertent re-registration and to protect vulnerable users.
When personal data is no longer required and no legal obligation prevents deletion, we take reasonable steps to securely delete or anonymise it.
Cookies & Tracking Technologies
hh89 uses cookies and similar tracking technologies to operate the Platform, improve user experience and carry out analytics. A cookie is a small text file stored on your device when you visit a website. The categories of cookies we use include:
Strictly Necessary Cookies
Essential for the Platform to function. These include session management, login authentication and security tokens. They cannot be disabled without breaking core Platform functionality.
Functional Cookies
Remember your preferences such as language settings, accepted terms and responsible gambling limit preferences. Disabling these may affect personalisation features.
Analytics Cookies
Used to understand how users interact with the Platform — including which pages are visited, time on page and navigation paths. Data is aggregated and anonymised wherever possible.
Marketing Cookies
Used, where consent has been obtained, to deliver relevant promotions and measure campaign effectiveness. You can withdraw consent for marketing cookies at any time.
Most browsers allow you to control cookies through browser settings. Blocking all cookies may impair your ability to use the Platform. For full cookie management instructions, refer to your browser's help documentation.
Children's Privacy & Age Verification
Adults 18+ only — or the higher minimum required by the operator or applicable license jurisdiction. hh89 is strictly prohibited from being used by minors. We do not knowingly collect personal data from individuals under the minimum age.
hh89 employs age verification controls at the point of registration, including mandatory declaration of date of birth and, for withdrawals and where operationally required, submission of a valid government-issued photo ID (such as a Pakistani CNIC or passport). Where we discover that personal data has been collected from a minor without parental consent, we will take immediate steps to delete that data and close the associated account.
If you have reason to believe a minor has accessed hh89 using your account credentials, contact support immediately at [email protected] (plain text — not a clickable link).
Security Measures
hh89 implements technical and organisational security measures appropriate to the nature of the personal data processed and the risks involved. These measures include:
- HTTPS/SSL encryption across all Platform pages and data transmissions;
- Access controls limiting internal access to personal data to staff with a documented operational need;
- Password hashing — account passwords are stored in hashed, salted form and are not accessible in plain text by hh89 staff;
- Two-factor authentication options for user accounts;
- Regular security assessments and monitoring of Platform infrastructure;
- Data processor agreements requiring equivalent security standards from third-party processors.
Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in a high risk to your rights, hh89 will notify affected users without undue delay as required by applicable law.
If you discover or suspect any security vulnerability affecting your hh89 account, contact [email protected] immediately. Do not attempt to exploit or publicise any vulnerability — report it responsibly and we will investigate promptly.
Exercising Your Data Rights
To exercise any of your data rights described in this Policy — including access, rectification, erasure, restriction, portability or objection — please submit a written request to [email protected]. Your request should include:
- Your full registered name and username on hh89;
- A clear description of the right you wish to exercise and the specific data involved;
- Sufficient identification to allow us to verify your identity before processing the request (this protects against unauthorised data access).
hh89 will respond to verified requests within a reasonable period consistent with applicable data protection law. We reserve the right to decline requests that are manifestly unfounded, excessive or that conflict with overriding legal obligations — for example, we cannot erase transaction records that must be retained under AML law.
Where your request is declined, we will provide a written explanation and, where applicable, information on how to lodge a complaint with the relevant supervisory authority in your jurisdiction.
Third-Party Links & Services
The hh89 Platform may reference or integrate third-party services — including payment processors and game content providers. Where third-party services operate under their own privacy policies (for example, a payment provider handling a PKR transaction via a Pakistani banking channel), hh89 is not responsible for the privacy practices of those third parties.
We encourage users to review the privacy policies of any third-party service they interact with independently of hh89. The reference to payment brands such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah on this site is for contextual information only and does not imply any data-sharing arrangement, affiliation or endorsement of gambling by those institutions.
Amendments to This Policy
hh89 reserves the right to update or amend this Privacy Policy at any time. When material changes are made:
- The "Last updated" date at the top of this document will be revised;
- A notice will be posted on the Platform where reasonably practicable;
- Where required by applicable law, we will notify you of material changes in advance of them taking effect.
Your continued use of the Platform following any amendment constitutes your acceptance of the revised Policy. If you do not agree to the updated terms, you should cease using the Platform and may request account closure.
We recommend reviewing this Privacy Policy periodically — particularly following any change to the "Last updated" date — to ensure you are aware of how your data is being handled.
Contact Us
If you have any questions about this Privacy Policy, wish to exercise a data right, report a privacy concern or raise a complaint, please contact the hh89 Data Protection team:
Email Contact
Write to: [email protected] — this is a plain text address and is not a clickable mailto: link. Copy the address manually into your email client. Include "Privacy Query" in your subject line for faster routing.
Language of Correspondence
All formal privacy requests must be submitted in English. Support staff may be able to assist with general queries in Urdu on a best-efforts basis.
Response Timeframe
We aim to acknowledge privacy requests promptly and will provide a substantive response within a reasonable period consistent with applicable data protection law. Complex or contested requests may take longer; we will keep you informed of progress.