down55 Privacy Policy —
Your Data, Our Responsibility

This Privacy Policy applies to down55 ("we", "us", "the Company", "down55"), the operator of the online gaming and sports betting platform accessible at down55.net. down55 is the data controller responsible for the collection and processing of personal data submitted by players who register and use the Platform.

The down55 Platform is operated for the benefit of adult players (18+) in Pakistan. All data processing activities described in this Privacy Policy are conducted in connection with the delivery of online gaming services — including casino games, sports betting, live dealer tables, fishing games, Cockfighting, and related services — to registered Pakistan players.

For all privacy-related enquiries, the designated data protection contact is the down55 English support team, reachable at [email protected] or via Telegram at @down55official.

down55 collects the following categories of personal data from Pakistan players in connection with the use of the Platform:

down55 collects personal data through the following channels:

• Direct registration: When you create a down55 account, you provide identity and contact data directly through the registration form.
• Account activity: As you use the Platform — depositing PKR, placing bets, claiming bonuses, contacting support — usage and financial data is recorded automatically by the Platform's systems.
• Identity verification: When down55 requires KYC verification, you submit identity documents (such as your Pakistani CNIC) directly to the verification process.
• Payment transactions: When you deposit or withdraw via Easypaisa, JazzCash, Raast, HBL, or UBL, transaction reference data is received from the payment provider to confirm and reconcile payments.
• Technical collection: Device information, IP addresses, and session data are collected automatically when you connect to the down55 Platform, through standard web server logging and cookie mechanisms described in Section 7 of this Policy.
• Support interactions: When you contact the down55 English support team via live chat, email, WhatsApp, or Telegram, the content of those communications is recorded and retained.

down55 uses the personal data of Pakistan players for the following purposes:

• Account management: To create, maintain, and administer your down55 account, including processing your login credentials and managing your PKR balance.
• Service delivery: To provide access to casino games, sports betting, live dealer tables, jackpot slots, fishing games, Cockfighting, and all other Platform features.
• Payment processing: To process PKR deposits and withdrawals via Easypaisa, JazzCash, Raast, and bank transfer channels, and to maintain accurate transaction records.
• Identity and age verification: To confirm that all registered players are aged 18 or above and that accounts are operated by the verified account holder, as required by our responsible gaming commitment.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering, and unauthorised account access.
• Regulatory compliance: To fulfil any anti-money laundering (AML), counter-terrorism financing (CTF), and Know Your Customer (KYC) obligations applicable to down55's operations.
• Responsible gaming monitoring: To monitor player behaviour for indicators of problem gambling and to enforce deposit limits, loss limits, cooling-off periods, and self-exclusions set by players.
• Customer support: To respond to player queries, resolve complaints, and maintain service quality for all Pakistan players contacting the down55 English support team.
• Platform improvement: To analyse usage patterns and performance data (in anonymised or aggregated form where possible) to improve the down55 Platform's features, speed, and user experience.
• Marketing communications: To send promotional offers, bonus notifications, and relevant Platform updates to players who have not opted out of marketing communications.

down55 processes personal data from Pakistan players on the following legal bases:

• Contract performance: Processing necessary to register your account, process deposits and withdrawals in PKR, and deliver gaming services — the core contractual obligations of the down55 Terms & Conditions that you accept at registration.
• Legitimate interests: Processing necessary for fraud prevention, platform security, multi-accounting detection, and service quality improvement, where these interests are not overridden by your privacy rights.
• Compliance with legal obligations: Processing required by applicable KYC, AML, and CTF regulations, including identity verification and transaction monitoring.
• Consent: Processing for direct marketing communications and non-essential cookies, where your consent has been obtained and can be withdrawn at any time without affecting other processing activities.

down55 does not sell your personal data. We share data only in the following limited circumstances and only to the extent necessary for the specified purpose:

• Payment processors: Personal and financial data is shared with Easypaisa, JazzCash, Raast, HBL, UBL, and other payment providers solely to process PKR deposit and withdrawal transactions. Each provider operates under their own privacy framework and applicable data security standards.
• Game software studios: Technical session identifiers (not personally identifiable information) are transmitted to game providers — such as JILI, Pragmatic Play, PG Soft, and Evolution — to deliver game sessions. These studios do not receive your name, mobile number, or payment details.
• Identity verification providers: Verification data (including CNIC copies and selfies) may be processed by specialist KYC service providers operating under strict confidentiality agreements with down55.
• Regulatory and law enforcement bodies: Where legally required, down55 may disclose personal data to relevant regulatory authorities, financial intelligence units, or law enforcement bodies in response to lawful requests.
• Group entities and service providers: down55 may share data with entities within its corporate group or with technical service providers (hosting, analytics, security) under binding confidentiality and data processing agreements.

down55 uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that help the Platform function correctly and improve your experience.

down55 uses the following categories of cookies:

• Essential cookies: Required for the Platform to operate. These include session authentication cookies that keep you logged in to your down55 account during your session. Essential cookies cannot be disabled without breaking Platform functionality.
• Functional cookies: Remember your preferences — such as display language, preferred game category, and device settings — to personalise your down55 experience across sessions.
• Performance cookies: Collect anonymised data about how players navigate the Platform, which games are most used, and where errors occur, to improve down55's technical performance and user experience.
• Security cookies: Support fraud detection and account security functions, including identifying anomalous login patterns that may indicate unauthorised access attempts.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent access to down55, but may affect certain personalisation features. On first access from a new device, down55 displays a cookie consent notice which allows you to accept or decline non-essential cookie categories.

down55 retains personal data for as long as is necessary for the purposes described in this Privacy Policy and for compliance with applicable legal obligations. The following general retention periods apply:

• Active account data: Retained for the duration of your active down55 account relationship.
• Financial transaction records: Retained for a minimum of five (5) years following the date of the transaction, to comply with applicable AML and financial record-keeping requirements.
• Identity verification documents: Retained for a minimum of five (5) years following account closure, or longer where required by applicable regulation.
• Support communications: Retained for a minimum of three (3) years following the date of the last interaction, for dispute resolution and service quality purposes.
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period thereafter to evidence prior consent in the event of a complaint.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any individual Pakistan player.

down55 implements a comprehensive range of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption on all data transmissions between your device and down55 servers, protecting data in transit from interception.
• Encrypted data storage for sensitive personal data — including identity documents and financial information — held in down55's systems.
• Access controls: Only authorised down55 staff with a documented legitimate need to process specific data categories are granted access, operating on a strict least-privilege basis.
• Two-factor authentication (2FA) available to all down55 players via your account security settings, providing an additional layer of protection for your account credentials.
• Regular security audits conducted by independent security professionals to identify and remediate vulnerabilities in the Platform's infrastructure and code.
• Incident response procedures: In the event of a data security incident affecting Pakistan player data, down55 has established procedures to contain, assess, and notify affected players within a reasonable timeframe.

While down55 implements robust security measures, no digital platform can guarantee absolute security. Players should also take personal responsibility for the security of their down55 account by using a strong password, enabling 2FA, and never sharing login credentials with other persons.

As a down55 player in Pakistan, you hold the following rights in relation to your personal data. To exercise any of these rights, contact the down55 English support team at [email protected]:

• Right of access: Request a copy of the personal data down55 holds about you, including the categories of data, the purposes for which it is processed, and any third parties with whom it has been shared.
• Right to rectification: Request correction of any inaccurate or incomplete personal data held about you. down55 will rectify confirmed inaccuracies promptly.
• Right to erasure ("right to be forgotten"): Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding retention obligations (such as AML record-keeping requirements described in Section 8).
• Right to restrict processing: Request that down55 temporarily restrict processing of your data while a complaint is pending or during an accuracy dispute.
• Right to data portability: Receive a copy of data you provided to down55 in a structured, commonly used, machine-readable format, where technically feasible.
• Right to object: Object to processing based on legitimate interests, including profiling for marketing purposes. Where objection is upheld, down55 will cease the relevant processing activity.
• Right to withdraw consent: Withdraw any consent previously given for processing activities — such as marketing communications — at any time, without affecting the lawfulness of prior processing.

down55 will acknowledge rights requests within 5 business days and aim to fulfil them within 30 calendar days. Complex requests may require additional time, in which case down55 will notify you of the extended timeframe.

down55 may send promotional communications — including bonus offers, new game announcements, and platform updates — to registered Pakistan players via SMS to registered mobile numbers, email, and in-platform notifications.

Marketing communications are sent only where:

• You have not opted out of marketing at registration or subsequently, OR
• You have explicitly opted in to receive promotional communications from down55.

You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link included in every down55 marketing email.
• Updating your communication preferences in your down55 account settings.
• Contacting the English support team at [email protected] with a written opt-out request.

Opting out of marketing will not affect transactional communications — such as deposit confirmation messages, withdrawal notifications, security alerts, and support responses — which are sent as part of the down55 service regardless of marketing preference.

down55 does not knowingly collect personal data from individuals under the age of 18. Age verification is conducted at registration and may be reinforced through identity document review at any point during the account relationship.

If down55 discovers or has reasonable grounds to believe that personal data has been collected from a minor, the following actions will be taken immediately:

• The account will be permanently suspended.
• All personal data associated with the underage account will be deleted in accordance with applicable data protection requirements.
• Any deposits made by the underage account holder will be returned to the verified source payment method after investigation.

Parents and guardians in Pakistan who believe a minor may have registered on down55 are encouraged to contact the English support team immediately at [email protected] for prompt investigation and account closure.

down55 reserves the right to update or amend this Privacy Policy at any time to reflect changes in:

• The nature of personal data collected or the purposes for which it is processed.
• Applicable data protection legislation or regulatory guidance.
• The Platform's technical infrastructure, payment methods, or operational structure.
• Third-party relationships affecting data processing activities.

Material changes — those that meaningfully affect player rights or data practices — will be communicated to registered Pakistan players via their registered mobile number or email address before the changes take effect. The "Last Updated" date at the top of this Policy will reflect the date of the most recent revision.

Your continued use of the down55 Platform following notification of a policy update constitutes acceptance of the revised Privacy Policy. If you do not accept the revised terms, you should contact the English support team to close your account before the changes take effect.

For all privacy-related queries, data subject rights requests, or complaints about how down55 handles your personal data, please contact the designated data protection team through any of the following channels:

• Email: [email protected] (please include "Privacy" in the subject line for faster routing)
• Telegram: @down55official
• WhatsApp: down55support
• Response time: Privacy requests are acknowledged within 5 business days and resolved within 30 calendar days where possible.

down55 is committed to resolving privacy complaints fairly and transparently. If you raise a complaint and are not satisfied with the outcome of down55's internal review, you may escalate the matter through any applicable independent dispute resolution process available under applicable regulations.