Privacy Policy — Hybaji

This Privacy Policy ("Policy") describes how Hybaji ("we", "us", "our"), operating the online betting information and entertainment platform at hybaji.cam ("Platform"), collects, processes, stores, shares and protects the personal data of users ("you", "your") who access or use the Platform.

Hybaji is committed to handling personal data with transparency, integrity and in accordance with applicable data protection principles. This Policy is designed to inform you clearly about our data practices so that you can make informed decisions about how you interact with the Platform.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy. By accessing or using the Platform, you acknowledge that you have read and understood this Policy.

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, national identity number, financial data and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, Hybaji.
• "Data Processor" means any third party that processes personal data on behalf of the Data Controller under a contractual arrangement.
• "KYC" (Know Your Customer) means the identity verification process used to confirm the identity and eligibility of users.
• "Cookies" means small text files stored on your device by a web browser at the instruction of a website, used to remember information about your visit.
• "CNIC" means Computerised National Identity Card, the standard identity document issued to Pakistani citizens by NADRA.

We collect personal data through several channels: directly from you during registration and account use, automatically through your interaction with the Platform, and from third-party verification and fraud prevention services.

We process your personal data only where a lawful basis exists for doing so. The primary bases on which we rely are as follows:

• Contractual Necessity: Processing required to create and manage your Account, process deposits and withdrawals, and fulfil obligations under the Terms & Conditions.
• Legal Obligation: Processing required to comply with applicable KYC, anti-money laundering (AML) and other regulatory obligations, including responses to lawful requests from competent authorities.
• Legitimate Interests: Processing undertaken to prevent fraud, ensure platform security, improve service quality and conduct responsible gambling monitoring, where these interests are not overridden by your rights and freedoms.
• Consent: Where we rely on consent (for example, for non-essential cookies or marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

We use your personal data for the following purposes:

• Account Registration & Management: Creating, maintaining and administering your Platform account, including verifying your identity and age.
• KYC & Compliance: Fulfilling our Know Your Customer and anti-money laundering obligations, verifying identity documents, and screening against applicable watchlists.
• Payment Processing: Facilitating deposits and withdrawals in PKR and other supported currencies, and maintaining accurate transaction records.
• Responsible Gambling: Monitoring gambling behaviour to identify potential problem gambling, administering deposit limits, loss limits, session controls and self-exclusion requests.
• Fraud Prevention & Security: Detecting, investigating and preventing fraudulent activity, unauthorised account access and other security incidents.
• Customer Support: Responding to your queries, complaints and support requests through live chat and email channels.
• Platform Improvement: Analysing usage patterns and technical data to improve Platform functionality, performance and user experience.
• Marketing Communications: Where you have provided consent, sending you promotional content, offers and Platform updates. You may opt out at any time.
• Legal Compliance: Meeting our obligations under applicable law and responding to lawful requests from regulatory or law enforcement authorities.

We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC & Identity Verification Providers: Third-party identity verification services that process identity documents and perform age and address verification on our behalf.
• Payment Service Providers: Financial service providers and payment processors that facilitate deposit and withdrawal transactions. Payment method references (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) are contextual references for Pakistani users — none of these providers are affiliated with or endorse Hybaji.
• Fraud Prevention Services: Services that assist in detecting and preventing fraudulent transactions and account abuse.
• Regulatory & Law Enforcement Authorities: Government bodies, regulators or law enforcement agencies where we are legally required or permitted to disclose personal data.
• Analytics Providers: Service providers that help us understand Platform usage through anonymised or aggregated data analysis.
• Professional Advisers: Legal, financial or other professional advisers where necessary, subject to professional confidentiality obligations.

All third-party processors are required to handle personal data in accordance with this Policy and applicable data protection law. We do not permit third-party processors to use your personal data for their own independent purposes.

Given the international nature of online betting platforms and the third-party service providers we engage, your personal data may be transferred to, stored in, or processed in countries outside Pakistan. These jurisdictions may have data protection laws that differ from those applicable in Pakistan.

Where personal data is transferred internationally, we take reasonable steps to ensure that appropriate safeguards are in place, including contractual protections with recipient entities requiring them to handle your data with a standard of care consistent with this Policy.

By using the Platform and submitting personal data, you acknowledge that such international transfers may occur in the course of delivering the services described in this Policy.

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements.

Typical retention periods are as follows:

• Account and Identity Data: Retained for the duration of your Account and for a minimum period following Account closure as required by applicable AML and regulatory obligations.
• Transaction Records: Financial and transactional records are retained for a minimum of five years from the date of each transaction, in line with standard AML compliance requirements.
• KYC Documents: Identity verification documents are retained for a period consistent with regulatory requirements applicable to the Operator's licensing jurisdiction.
• Communications Data: Support correspondence is retained for a reasonable period to handle follow-up queries and complaints, typically up to two years.
• Technical & Usage Data: Retained in aggregated or anonymised form for analytical purposes after the retention period for identifiable data has expired.

Once the applicable retention period has elapsed and there is no longer a lawful basis for retaining your data, we will securely delete or anonymise it.

Hybaji uses cookies and similar tracking technologies (such as pixel tags and local storage) to operate, improve and secure the Platform. The categories of cookies we use are as follows:

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality or performance of the Platform.

The Platform may contain references to or integrations with third-party services, including payment providers and identity verification systems. These third-party services operate under their own privacy policies, which are independent of this Policy.

Hybaji is not responsible for the privacy practices, data handling or content of any third-party service. We encourage you to review the privacy policies of any third-party service you interact with in the course of using the Platform.

References to payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are contextual references for Pakistani users only. Hybaji is not affiliated with, endorsed by or partnered with any of these providers for gambling transactions.

The Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the Operator's license jurisdiction. We do not knowingly collect personal data from individuals under the applicable minimum age.

If we become aware that personal data has been submitted by a person below the applicable minimum age, we will take immediate steps to delete that data and close the associated account. Age verification controls are applied at registration and during KYC processes to support this commitment.

If you have reason to believe that a minor has accessed the Platform or submitted personal data, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

Subject to applicable law, you have the following rights in relation to your personal data held by Hybaji. To exercise any of these rights, contact us at [email protected]. We will respond within a reasonable timeframe.

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• TLS/HTTPS Encryption: All data transmitted between your device and the Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Access Controls: Personal data is accessible only to authorised personnel who require it to perform their job functions. Access is governed by role-based permissions and regularly reviewed.
• Secure Storage: Personal data and identity documents are stored in secured environments with restricted physical and logical access.
• Regular Security Assessments: We conduct periodic reviews of our security practices and work with qualified security professionals to identify and address vulnerabilities.
• Incident Response: We maintain procedures for detecting, reporting and responding to personal data breaches. In the event of a breach that poses a risk to your rights, we will notify affected users as required by applicable law.

No method of electronic transmission or storage is 100% secure. While we apply commercially reasonable security measures, we cannot guarantee the absolute security of your personal data. We will notify you promptly in the event of a material security incident affecting your data.

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations or Platform functionality. When we make changes, we will update the "Last Updated" date at the top of this page.

Where changes are material — meaning they significantly affect how we process your personal data or the rights available to you — we will endeavour to notify registered users via the email address associated with their Account prior to the changes taking effect.

Your continued use of the Platform following publication of any updated Policy constitutes your acknowledgement of the revised terms. We recommend bookmarking this page and reviewing it periodically to stay informed of how Hybaji handles your personal data.

If you disagree with any changes to this Policy, you should discontinue your use of the Platform and may request Account closure by contacting our support team.

If you have any questions, concerns or complaints about this Privacy Policy or about how Hybaji processes your personal data, please reach out to us using the contact details below. We take all privacy enquiries seriously and will respond within a reasonable timeframe.

The email address above is provided as plain text only. It is not a clickable link. Please copy it into your preferred email client to get in touch.

For queries specifically relating to responsible gambling, deposit limits or self-exclusion, please visit our Responsible Gambling page for dedicated guidance and resources.

For queries about the general Terms of use of this Platform, please refer to our Terms & Conditions page.