betr Privacy Policy — How We Handle Your Personal Data in Pakistan

This Privacy Policy applies to betr, the online gaming platform operated at betr.ws, which provides live casino games, slot machines, Ludo tournaments, esports betting, and associated payment and account management services to players in Pakistan.

For the purposes of this Privacy Policy, betr acts as the data controller in respect of the personal data collected through its platform. As data controller, betr is responsible for determining the purposes for which your personal data is used and for ensuring that it is processed lawfully, fairly and transparently in accordance with applicable data protection obligations.

If you have any questions about how betr handles your personal data, or if you wish to exercise any of your data rights described in this policy, you can contact betr's Data Protection point of contact at privacy@betr.ws. betr aims to respond to all data-related queries within 5 business days and to formal data subject requests within 30 calendar days of receipt.

betr collects personal data through several channels — directly from you when you register or use the platform, automatically through your interactions with the platform, and in some cases from third-party verification and payment providers. The categories of data we collect include:

betr uses your personal data only for specific, legitimate purposes. We do not use your data in ways that you would not reasonably expect given the context in which it was collected. The primary purposes for which betr processes your personal data are:

• Account management: creating and maintaining your betr account, authenticating your identity at login, and managing your account preferences and settings.
• Service delivery: enabling you to access and play games, place bets, participate in tournaments, and use all features of the betr platform.
• Payment processing: processing your deposits via Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT and card; verifying payment ownership; and processing withdrawal requests to your registered accounts.
• Identity and age verification: verifying that you are who you say you are, that you are at least 18 years old, and that the payment accounts you use belong to you — all required by regulatory and anti-money laundering obligations.
• Legal compliance: complying with applicable anti-money laundering (AML) laws, counter-terrorism financing (CTF) requirements, and regulatory reporting obligations.
• Responsible gaming: monitoring gaming patterns to identify players who may be showing signs of problem gambling, and administering deposit limits, self-exclusion requests and other responsible gaming tools.
• Security and fraud prevention: detecting and preventing fraudulent activity, unauthorised account access, bonus abuse, collusion and other prohibited conduct.
• Customer support: responding to your queries, resolving complaints, and maintaining records of support interactions for quality and compliance purposes.
• Marketing communications: sending you promotional offers, tournament announcements and platform updates by email or SMS, where you have consented to receive these. See Section 13 for how to opt out.
• Platform improvement: analysing aggregated, anonymised usage data to improve betr's platform performance, game library and user experience.

betr processes your personal data on the following legal grounds, each of which applies to specific processing activities:

• Contract performance: processing that is necessary to fulfil betr's obligations under the Terms and Conditions you agreed to at registration — including account management, game access and payment processing.
• Legal obligation: processing required to comply with applicable laws — including AML/CTF obligations, age verification requirements, and regulatory reporting to relevant authorities.
• Legitimate interests: processing for betr's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, security monitoring, responsible gaming monitoring, and platform improvement through anonymised analytics.
• Consent: processing activities where you have given explicit consent — primarily the sending of marketing communications. You may withdraw consent for marketing at any time without affecting any other aspect of your account or betr's service.

Processing your deposits and withdrawals requires betr to handle financial account information. Here is precisely what betr holds and what it does not hold:

What betr stores: The type of payment method you use (e.g., Easypaisa, JazzCash), the partial identifier of your wallet or account (e.g., last four digits of a phone number associated with a wallet), transaction reference numbers, amounts, timestamps, and the currency of each transaction. This information is necessary for payment reconciliation, dispute resolution and regulatory compliance.

What betr does NOT store: Full payment card numbers, CVV codes, or full bank account numbers. Card payments are processed by PCI-DSS-certified third-party payment processors who handle card data directly and securely without passing the full card details to betr's systems.

betr requires that all payment accounts used for deposits and withdrawals are registered in your name — matching your betr account identity. This is both a platform rule and a regulatory requirement. Attempting to use payment accounts registered to another person will result in the transaction being declined and the matter flagged for review.

betr uses cookies and similar tracking technologies to operate the platform, personalise your experience, and improve platform performance. A cookie is a small text file stored on your device when you visit a website. betr uses the following categories of cookies:

• Strictly necessary cookies: required for the platform to function. These include session authentication cookies that keep you logged in during a session, and security cookies that protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Functional cookies: remember your preferences such as preferred game lobby view, language settings and notification preferences. Disabling these means your preferences will not be remembered between sessions.
• Analytics cookies: collect anonymised data about how players navigate and use the platform — which pages are visited most, where users encounter problems, and which game categories are most popular. betr uses this data to improve the platform. This data is aggregated and does not identify individual players.
• Session security cookies: track active gaming sessions to prevent session hijacking and enforce simultaneous session limits for account security.

betr does not use third-party advertising or retargeting cookies. You will not be tracked across other websites by betr-placed cookies. Your browser settings allow you to control or delete cookies — consult your browser's help documentation for instructions.

betr does not sell, rent or exchange your personal data with any third party for commercial gain. The only circumstances in which your personal data is shared with third parties are:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, bank partners and card processing networks receive the minimum data necessary to process your deposits and withdrawals — typically your account identifier, transaction amount and reference. These processors have their own privacy policies and data security certifications.
• Game providers: certified studios such as Evolution, Pragmatic Play and Ezugi receive a session token and game parameters when you launch a live casino or slot game. They do not receive your full identity details or payment information. They operate under contractual data protection obligations with betr.
• Identity verification providers: for KYC verification, betr uses third-party identity checking services that receive and verify your CNIC or other identity documents. These providers are bound by strict data protection and security obligations.
• Regulatory and law enforcement authorities: betr is legally required to disclose certain information to anti-money laundering authorities, tax bodies and law enforcement when legally compelled. betr complies with such requests but does not voluntarily share data with authorities beyond what is legally required.
• Professional advisors: lawyers, auditors and accountants who provide professional services to betr may have access to limited data under strict confidentiality obligations.

betr retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal obligations, and to resolve disputes or enforce agreements. The key retention periods that apply to betr player data are:

• Active account data: retained for the duration of your account and updated as needed. While your account is active, betr retains all identity, contact, financial and gaming data necessary to operate the service.
• Financial transaction records: retained for a minimum of 7 years after the transaction date, as required by anti-money laundering regulations applicable to betr's operating jurisdiction.
• KYC and identity verification records: retained for a minimum of 5 years from the date of verification, or 5 years after account closure — whichever is later — as required by applicable law.
• Support interaction records: retained for 3 years from the date of the interaction to allow for quality review and dispute resolution.
• Gaming history: retained for the duration of your account plus 5 years following account closure, to support regulatory compliance and dispute resolution.
• Data of closed accounts: following voluntary account closure, betr anonymises data that is not required by law or legitimate interest within 90 days. Data subject to legal retention requirements is held in secure, restricted systems for the required period.

betr takes the security of your personal data seriously and implements a combination of technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction. The primary security measures in place include:

• 256-bit SSL/TLS encryption on all connections between your device and betr's servers.
• Encrypted storage for all sensitive personal data at rest, including identity documents and financial account identifiers.
• Role-based access controls limiting internal access to personal data to authorised personnel with a legitimate need to access it.
• Two-factor authentication available for all betr accounts, and mandatory for administrative access to betr's internal systems.
• Regular security audits and penetration testing by independent third-party security specialists.
• Real-time monitoring systems that detect and alert on anomalous access patterns and potential security incidents.
• Data breach response procedures that include notification to affected players and relevant authorities within required timeframes in the event of a confirmed breach.

As a betr player whose personal data is processed by betr, you have a number of rights in respect of that data. Here is what each right means in practice and how to exercise it:

To exercise any of these rights, contact betr's privacy team at privacy@betr.ws. You will be asked to verify your identity before the request is processed to ensure betr is responding to the legitimate account holder. betr will not charge a fee for standard requests.

betr's services are strictly for adults aged 18 and over. betr does not knowingly collect personal data from individuals under the age of 18. Registration requires mobile OTP verification, and enhanced KYC checks including CNIC review are applied when account activity indicates a need for age verification.

If betr discovers that a minor has created an account, all data associated with that account will be deleted immediately and the account will be permanently closed. If you believe a minor has registered on betr, contact support immediately at support@betr.ws. betr treats the protection of minors from online gambling as a fundamental obligation, not a compliance afterthought.

betr's responsible gaming programme requires the processing of certain gaming behaviour data — including bet frequency, session lengths, deposit patterns and use of responsible gaming tools — to identify players who may be at risk of developing gambling-related problems and to administer the tools players use to manage their play.

This processing is carried out under betr's legitimate interests in protecting player welfare and under regulatory obligations applicable to licensed gaming operators. The data used for responsible gaming monitoring is not used for marketing purposes and is handled with additional care given its sensitivity.

Self-exclusion records are retained beyond account closure to prevent re-registration during an exclusion period. A player who has self-excluded cannot register a new account during the exclusion period — this retention of limited identifying data is necessary to enforce the exclusion and protect the player.

betr may send you promotional emails, SMS messages and in-platform notifications about bonuses, tournaments, new games and platform updates. Marketing communications are sent only where you have opted in to receive them during registration or through your account notification settings.

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

• Clicking the unsubscribe link in any marketing email from betr.
• Updating your notification preferences in your betr account settings.
• Contacting betr support and requesting removal from marketing lists.

Opting out of marketing communications does not affect transactional communications — you will continue to receive account security alerts, payment confirmations, identity verification requests and support responses regardless of your marketing preference. These communications are necessary for the operation of your account and cannot be opted out of while your account remains active.

Some of the third parties betr works with — including game providers, identity verification services and payment infrastructure providers — may be located outside Pakistan and may process your personal data in jurisdictions with different data protection frameworks.

Where betr transfers personal data internationally, it implements contractual safeguards to ensure an appropriate level of protection — including data processing agreements that require third parties to handle data to at least the same standard as applicable in betr's operating jurisdiction. betr does not transfer data to jurisdictions that it assesses as providing inadequate protection without first putting appropriate safeguards in place.

betr reviews this Privacy Policy regularly and may update it to reflect changes in data processing activities, applicable law, or regulatory requirements. When material changes are made — meaning changes that affect how your data is used or your rights — betr will notify registered players through their account notification centre with at least 14 days' notice before the new policy takes effect.

Minor changes — such as clarifications or the addition of new data categories in existing processing activities — may be made without prior notice but will be reflected in the version number and last-updated date shown at the top of this page. We encourage you to check this page periodically so you are always aware of betr's current privacy practices.

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how betr handles your personal data, please contact betr's privacy team:

• Email: privacy@betr.ws — for all data subject requests and privacy-specific queries. Response within 5 business days for general queries and 30 calendar days for formal data subject requests.
• General support: support@betr.ws or live chat, available 24/7. For account-level queries, support can address most issues directly or escalate to the privacy team where needed.

If you are not satisfied with betr's response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority in your jurisdiction. betr will cooperate with any regulatory investigation and will not retaliate against any player who exercises their rights or raises a legitimate complaint in good faith.