malbat Privacy Policy

1.Who We Are

1.1 This Privacy Policy applies to malbat ("we", "us", "our"), the online gaming platform accessible at malbat.co and through any associated mobile applications made available to players in Pakistan and other jurisdictions where the platform operates.

1.2 malbat acts as the data controller in respect of personal information collected through the platform. This means malbat determines the purposes and means of processing your personal data as described in this Policy.

1.3 All enquiries, data access requests and privacy complaints should be directed to our dedicated data team at [email protected]. We aim to respond to all privacy-related correspondence within 30 days.

2.Personal Data We Collect

malbat collects the following categories of personal data from registered players:

Category	Examples	Purpose
Identity Data	Full name, date of birth, CNIC number, CNIC scan/photograph	KYC verification, age verification, fraud prevention
Contact Data	Email address, Pakistani mobile number, city of residence	Account communication, OTP delivery, support
Financial Data	JazzCash/Easypaisa account number, bank name, transaction history	Deposit and withdrawal processing, AML compliance
Gaming Data	Bet history, game sessions, win/loss records, bonus usage	Account management, responsible gaming, dispute resolution
Technical Data	IP address, device ID, browser type, operating system, session logs	Security, fraud detection, platform optimisation
Usage Data	Pages visited, features used, time spent, click patterns	Platform improvement, personalisation
Communications Data	Live chat transcripts, email correspondence, support tickets	Support quality, compliance record-keeping

3.How We Collect Your Data

3.1 Directly from you – when you register a malbat account, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a malbat promotion.

3.2 Automatically – when you access the malbat platform, our systems automatically log technical and usage data including your IP address, device identifiers and session activity. This data is collected through cookies, web beacons and server logs.

3.3 From third parties – malbat may receive identity verification data from KYC service providers, fraud detection signals from payment processors including JazzCash and Easypaisa, and marketing attribution data from approved advertising partners.

4.How and Why We Use Your Data

malbat processes your personal data for the following purposes:

• Account management: Creating, maintaining and securing your malbat player account, including login authentication and two-factor verification.
• Payment processing: Executing deposits and withdrawals in PKR through JazzCash, Easypaisa and banking partners. Financial data is shared with payment providers only to the extent necessary to process your transaction.
• KYC & compliance: Verifying your identity and age (18+) in accordance with anti-money laundering obligations and responsible gaming requirements. CNIC data is used solely for this purpose.
• Customer support: Responding to queries, resolving disputes and maintaining records of malbat player interactions for quality assurance purposes.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and deploying responsible gaming interventions where appropriate, including deposit limit enforcement and self-exclusion management.
• Marketing: Sending promotional emails, SMS notifications and in-platform messages about malbat bonuses, PSL season offers and new game launches, subject to your marketing preferences. You may opt out at any time.
• Security & fraud prevention: Detecting and preventing unauthorised account access, bonus abuse, multi-accounting and money laundering on the malbat platform.
• Platform improvement: Analysing aggregated usage data to improve malbat's user experience, game lobby design and payment flow efficiency.

5.Legal Basis for Processing

malbat relies on the following legal bases to process your personal data:

• Contract performance: Processing necessary to operate your malbat account and deliver the gaming services you have registered for.
• Legal obligation: Processing required to comply with applicable KYC, AML and responsible gaming regulations.
• Legitimate interests: Processing for fraud prevention, platform security and aggregated analytics where these interests are not overridden by your privacy rights.
• Consent: Marketing communications and optional personalisation features where your explicit consent has been obtained at registration or subsequently. Consent may be withdrawn at any time by contacting [email protected].

6.Sharing Your Personal Data

6.1 malbat does not sell, rent or trade your personal data to third parties for their own marketing purposes under any circumstances.

6.2 malbat shares personal data with the following categories of third parties only to the extent necessary for the stated purpose:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank and Bank Alfalah receive financial and identity data to process your transactions and comply with their own AML obligations.
• KYC providers: Identity verification service providers receive your CNIC and identity documents to carry out automated and manual verification checks.
• Game suppliers: Licensed third-party game providers receive anonymised session data necessary to deliver game content and calculate outcomes. Game suppliers do not receive your full identity data.
• Technology providers: Hosting, cloud infrastructure, customer support software and fraud detection platforms that process data on behalf of malbat under strict data processing agreements.
• Regulatory bodies: malbat will disclose personal data to regulatory authorities, law enforcement agencies or licensing bodies when legally required to do so.

7.International Data Transfers

7.1 malbat's primary operations and data storage are arranged to serve Pakistani players. Where data is processed or stored outside Pakistan, malbat ensures that appropriate safeguards are in place, including data processing agreements that impose obligations equivalent to applicable data protection standards.

7.2 Payment data processed through JazzCash and Easypaisa is handled within Pakistan in accordance with the State Bank of Pakistan's data localisation requirements for payment service providers.

8.Data Retention

8.1 malbat retains your personal data for as long as your account remains active and for a period of five (5) years following account closure. This retention period is necessary to comply with AML record-keeping obligations and to defend against potential legal claims.

8.2 Gaming session data and bet history are retained for seven (7) years in line with standard gaming compliance requirements.

8.3 Marketing preferences and communication opt-out records are retained indefinitely to ensure we honour your preferences even if you later re-register a malbat account.

8.4 Following expiry of the applicable retention period, malbat will securely delete or anonymise your personal data so that it can no longer be associated with you.

9.Cookies & Tracking Technologies

9.1 The malbat platform uses cookies and similar tracking technologies to maintain your login session, remember your preferences, detect fraudulent activity and analyse platform usage. The following cookie categories are used:

• Essential cookies: Required for the malbat platform to function. These cannot be disabled without disrupting core functionality including login, session management and payment security.
• Analytics cookies: Used to understand how players navigate the malbat platform in aggregate. Data is anonymised before analysis.
• Preference cookies: Store your language, display and notification preferences across malbat sessions.
• Security cookies: Used for fraud detection, bot prevention and multi-account identification on the malbat platform.

9.2 You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to place bets or process payments on malbat.

10.Your Data Rights

As a malbat player, you have the following rights in respect of your personal data:

• Right of access: Request a copy of the personal data malbat holds about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data in your malbat account.
• Right to erasure: Request deletion of your personal data, subject to overriding retention obligations under AML and gaming regulations.
• Right to restrict processing: Request that malbat limits how your data is processed in certain circumstances.
• Right to data portability: Receive your personal data in a structured, machine-readable format for transfer to another service.
• Right to object: Object to processing based on legitimate interests, including direct marketing. Marketing opt-out is effective immediately upon request.
• Right to withdraw consent: Withdraw any previously given consent for optional data processing at any time without affecting lawfulness of prior processing.

To exercise any of the above rights, contact malbat at [email protected]. malbat will respond within 30 days. Identity verification will be required before processing data access or deletion requests.

11.Children's Privacy

11.1 malbat is strictly an 18+ platform. malbat does not knowingly collect personal data from individuals under the age of 18. If malbat discovers that personal data has been collected from a minor, the account will be immediately suspended, all data will be deleted, and any deposits will be returned where permitted by applicable regulations.

11.2 If you believe a minor has registered a malbat account, please report this immediately to [email protected].

12.Security Measures

malbat implements the following technical and organisational security measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the malbat platform
• Password hashing using industry-standard salted algorithms – malbat staff cannot read your password
• Two-factor authentication available for all player accounts
• Access controls ensuring malbat staff can only access player data necessary for their specific role
• Regular security audits and penetration testing of the malbat platform infrastructure
• Incident response procedures including player notification in the event of a data breach affecting their personal data

13.Third-Party Services

13.1 The malbat platform integrates third-party services including payment gateways, live casino streaming providers, game RNG engines and customer support tools. These services operate under their own privacy policies and data processing agreements with malbat.

13.2 malbat is not responsible for the privacy practices of third-party services accessed via links that may appear in marketing communications or on the malbat platform from time to time.

14.Changes to This Privacy Policy

14.1 malbat may update this Privacy Policy from time to time to reflect changes in data processing practices, applicable regulations or platform features. The "Last updated" date at the top of this page will be revised accordingly.

14.2 Material changes to this Policy will be communicated to registered malbat players via email at least 14 days before the changes take effect. Continued use of the malbat platform following the effective date constitutes acceptance of the revised Policy.

15.Contact & Complaints

For any privacy-related enquiry, data access request or complaint regarding malbat's handling of your personal data, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 on the malbat platform (English and Urdu)
• Response time: Within 30 days for formal data subject requests

If you are not satisfied with malbat's response to a privacy complaint, you may escalate the matter to the applicable data protection supervisory authority in the jurisdiction where malbat holds its operating licence.