s55com Privacy Policy

For the purposes of applicable data protection law, s55com acts as the data controller in respect of all personal data collected through the s55com platform. As data controller, s55com determines the purposes for which and the manner in which personal data is processed. s55com is responsible for ensuring that its data processing activities comply with applicable privacy and data protection standards.

Where s55com engages third-party service providers — such as payment processors, identity verification providers, or fraud prevention services — those providers act as data processors under s55com's instructions. s55com enters into data processing agreements with all such processors to ensure your personal data is handled in accordance with this Privacy Policy and applicable law.

All enquiries regarding this Privacy Policy or s55com's data processing activities should be directed to the s55com data protection team at [email protected].

s55com collects and processes the following categories of personal data in connection with your use of the platform:

s55com does not intentionally collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond the photograph that may be submitted as part of CNIC-based identity verification.

s55com collects personal data through the following channels and mechanisms:

• Direct Submission: Data you provide when registering an account, completing identity verification (KYC), making a deposit or withdrawal request, contacting customer support, or submitting a formal complaint.
• Automated Collection: Technical and usage data collected automatically as you navigate and interact with the s55com platform, including through cookies, session logs, and server-side analytics tools.
• Third-Party Verification Providers: Identity and age verification data obtained from NADRA-linked or internationally recognised identity verification services when you submit your CNIC for KYC compliance.
• Payment Processors: Transaction confirmation data, payment method identifiers (tokenised), and fraud risk signals received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, Visa, and Mastercard processing networks.
• Anti-Fraud and AML Systems: Behavioural and transactional signals from third-party fraud detection and anti-money-laundering screening services that s55com employs as part of its compliance programme.

s55com processes your personal data for the following specific purposes:

• Account Management: Creating, maintaining, and securing your s55com account, including processing password resets and enforcing single-account policies.
• Identity Verification (KYC): Verifying your identity and age to ensure compliance with our 21+ policy and applicable know-your-customer obligations under our gaming licence.
• Payment Processing: Facilitating deposits and withdrawals in PKR via your chosen payment channel, reconciling transactions, and investigating payment disputes.
• Service Delivery: Enabling your participation in sports betting markets, live casino games, and slot games, and ensuring the integrity of all gaming outcomes.
• Fraud Prevention and AML Compliance: Detecting, investigating, and preventing fraud, money laundering, match-fixing, and other illegal activities in connection with your account.
• Responsible Gaming: Implementing and maintaining the self-exclusion, deposit limit, cool-off, and reality check tools available on the platform, and identifying patterns of play that may indicate problem gambling behaviour.
• Customer Support: Responding to your support queries, managing complaints, and providing technical assistance.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates via email or SMS — but only where you have provided your consent or where we have a legitimate interest in doing so, and always subject to your right to opt out at any time.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the functionality, performance, and content of the s55com platform.
• Legal and Regulatory Compliance: Meeting our obligations under our gaming licence, responding to lawful requests from regulatory or law enforcement authorities, and enforcing our Terms & Conditions.

s55com processes your personal data on the following legal bases, depending on the specific processing activity involved:

• Contractual Necessity: Processing required to perform our contract with you — that is, to provide the gaming and betting services you have registered for, process your transactions, and manage your account.
• Legal Obligation: Processing required to comply with our obligations under applicable gaming regulation, anti-money-laundering law, and our international gaming licence — including KYC verification, transaction record-keeping, and reporting to authorities.
• Legitimate Interests: Processing carried out in s55com's legitimate business interests, where those interests are not overridden by your rights — including fraud detection, platform security, abuse prevention, and aggregated analytics for service improvement.
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent — principally direct marketing communications. You may withdraw your consent at any time by contacting [email protected] or using the opt-out mechanism in any marketing email.

s55com does not sell your personal data to any third party. We share personal data only in the following strictly defined circumstances:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, Visa, and Mastercard receive the minimum necessary financial data to process your deposit and withdrawal transactions.
• Identity Verification Providers: CNIC and identity document data is shared with our licensed KYC verification partners solely for the purpose of confirming your identity and age in compliance with our regulatory obligations.
• Fraud Detection and AML Screening Services: Transactional and behavioural data is shared with our fraud prevention and AML compliance technology partners to identify and prevent financial crime on the platform.
• Gaming Content Providers: Certain technical session data may be shared with the third-party game studios whose content is hosted on the s55com platform solely to facilitate gameplay and verify game integrity.
• Regulatory and Law Enforcement Authorities: s55com will disclose personal data to competent regulatory bodies, gaming authorities, financial intelligence units, or law enforcement agencies where required to do so by law, court order, or our licensing obligations.
• Professional Advisers: In limited circumstances, personal data may be disclosed to our legal counsel, auditors, or other professional advisers where necessary for the conduct of our business and subject to appropriate confidentiality obligations.

All third parties with whom s55com shares personal data are contractually required to process that data in accordance with applicable data protection standards and solely for the specific purposes for which it was shared.

s55com retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, and for no longer than required by our regulatory, legal, and licensing obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with s55com and for a minimum of five years following permanent account closure, as required by our gaming licence for audit and regulatory review purposes.
• KYC / Identity Verification Data: Retained for a minimum of five years following account closure, consistent with anti-money-laundering record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five years following the date of each transaction.
• Responsible Gaming Records: Self-exclusion records are retained indefinitely to prevent re-registration during an active exclusion period. Other responsible gaming tool usage records are retained for five years post-closure.
• Customer Support Communications: Retained for two years from the date of last contact, unless the communication relates to an unresolved dispute or formal complaint, in which case it is retained until the matter is fully resolved plus one year.
• Marketing Consent Records: Retained for the duration of your account relationship and for three years following account closure as evidence of consent or opt-out.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised data — which can no longer be attributed to any individual — may be retained indefinitely for analytical and statistical purposes.

s55com implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. Key measures include:

• Encryption: All data in transit between your device and s55com's servers is protected by TLS 1.3 encryption. Sensitive data at rest — including financial data and identity documents — is encrypted using AES-256.
• Access Controls: Access to personal data within s55com's systems is restricted on a strict need-to-know basis. All staff with data access privileges are subject to background checks and confidentiality obligations.
• Two-Factor Authentication: s55com supports and actively encourages the use of two-factor authentication (2FA) on all player accounts as an additional layer of protection against unauthorised login.
• Penetration Testing: s55com's platform infrastructure is subject to regular independent penetration testing and vulnerability assessments to identify and remediate security weaknesses before they can be exploited.
• Incident Response: s55com maintains a formal data breach incident response procedure. In the event of a breach that is likely to result in a risk to your rights and freedoms, s55com will notify affected users without undue delay and will report to the relevant supervisory authority as required.
• Secure Data Centres: All s55com data is hosted in ISO 27001-certified data centre facilities with physical security controls, redundant power, and environmental monitoring.

s55com uses cookies and similar tracking technologies on its platform to ensure core functionality, improve user experience, and — where you have consented — deliver relevant promotional content. The following types of cookies are in use:

• Strictly Necessary Cookies: Essential for the platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without rendering the platform unusable.
• Functional Cookies: Remember your preferences and settings — such as your preferred language, notification preferences, and responsible gaming tool configurations — to provide a personalised platform experience.
• Analytical Cookies: Collect anonymised or pseudonymised data about how you use the platform — such as which pages you visit and how long you spend on them — to help s55com understand usage patterns and improve the platform. s55com uses first-party analytics tools; your data is not shared with third-party analytics platforms.
• Marketing Cookies: Used only with your explicit consent to track whether you have responded to a promotion or to help ensure that the same promotional message is not shown to you repeatedly. These cookies do not track your activity across external websites.

You may manage your cookie preferences at any time through the cookie settings panel available on the s55com platform. Note that disabling strictly necessary cookies will affect platform functionality. Withdrawing consent for analytical or marketing cookies does not affect your ability to use the core gaming and betting services.

As a data subject, you hold the following rights in respect of the personal data s55com holds about you. These rights may be exercised by submitting a written request to [email protected]: