10sbat Privacy Policy — Your Data, Your Rights, Our Obligations

1 Introduction & Data Controller Identity

This Privacy Policy ("Policy") is issued by 10sbat ("we," "us," "our," "10sbat"), the operator of the online gaming and sports betting platform accessible at https://10sbat.org. This Policy applies to all personal data collected, processed, stored, and used in connection with your registration and use of the 10sbat platform, including all casino games, sports betting markets, payment services, promotional communications, and customer support interactions.

10sbat acts as the data controller in respect of personal data provided by players. As data controller, 10sbat determines the purposes for which and the manner in which personal data is processed. Where 10sbat engages third-party service providers to process data on its behalf, those providers act as data processors and are contractually bound to process data only in accordance with 10sbat's documented instructions and applicable data protection law.

This Policy should be read alongside the 10sbat Terms and Conditions and Responsible Gaming Policy. By registering a 10sbat account, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2 Categories of Personal Data We Collect

10sbat collects personal data from players through multiple channels, including the account registration process, KYC verification, payment transactions, platform usage, and direct communications with our support team. The following table summarises the categories of data collected and their source:

10sbat does not intentionally collect special categories of sensitive personal data (such as health data, religious beliefs, or biometric data) unless specifically required by applicable law or submitted voluntarily by the player in the context of a responsible gaming support request.

3 How 10sbat Uses Your Personal Data

10sbat processes player personal data for the following specific purposes. Where a purpose requires a particular legal basis, this is identified in Section 4.

• Account creation and management: Processing registration information to create, maintain, and manage your 10sbat account, including identity verification, password management, and account settings.
• Age and identity verification (KYC): Verifying that players are aged 21 or above and confirming the accuracy of identity information in compliance with 10sbat's gaming licence obligations and anti-money-laundering regulations.
• Payment processing: Facilitating PKR deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and crypto channels, and processing withdrawal requests to verified payment methods.
• Game and betting service delivery: Enabling access to casino games, live dealer tables, cricket and PSL betting markets, slot games, Happy Fishing, and Plinko products.
• Fraud prevention and AML compliance: Monitoring account and transaction activity to detect and prevent money laundering, fraud, account takeovers, bonus abuse, and other prohibited conduct.
• Responsible gaming: Using gameplay and transaction data to identify patterns that may indicate problem gambling behaviour, and to administer self-exclusion and account limit tools.
• Customer support: Responding to support queries, resolving complaints, and maintaining records of player interactions.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have consented to receive marketing communications. Players may opt out at any time through account settings.
• Platform improvement and analytics: Analysing aggregate, anonymised usage data to improve platform performance, game selection, and user experience for Pakistani players.
• Legal and regulatory compliance: Meeting obligations imposed by 10sbat's gaming licence, applicable law, and regulatory authority requests or orders.

4 Legal Basis for Data Processing

10sbat processes personal data only where a valid legal basis exists under applicable data protection law. The primary legal bases on which 10sbat relies are as follows:

• Contractual necessity: Processing required to establish, perform, or manage your player account and the services you have contracted to receive, including payments, game access, and support.
• Legal obligation: Processing required to comply with 10sbat's obligations under its gaming licence, anti-money-laundering legislation, Know Your Customer regulations, and other applicable legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, internal analytics, and network protection — where 10sbat's legitimate interests in operating a safe, compliant platform are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where explicit consent has been obtained. Consent can be withdrawn at any time without affecting the lawfulness of prior processing.

5 Data Sharing & Third-Party Disclosure

10sbat does not sell, rent, or commercially exchange personal data with third parties. Data is shared only in the following circumstances and only to the extent strictly necessary for the stated purpose:

• Payment processors: JazzCash, EasyPaisa, Visa/Mastercard network processors, bank transfer intermediaries, and USDT blockchain processors receive transaction data required to execute deposits and withdrawals.
• KYC and identity verification providers: Third-party identity verification services may process identity document scans and biometric data for the purpose of verifying player age and identity in compliance with licensing requirements.
• Game software providers: Game providers such as Evolution, Pragmatic Play, and similar studios may receive session identifiers and stake data for the purpose of game outcome determination and technical operation. These providers do not receive personally identifiable information beyond what is required for technical game function.
• Regulatory and law enforcement authorities: 10sbat will disclose personal data to gaming regulators, financial intelligence units, law enforcement agencies, or courts where required by law, court order, or regulatory instruction. 10sbat will notify affected players of such disclosures where legally permissible.
• Fraud and AML screening services: Transaction and account data may be shared with third-party fraud detection and AML screening services that assist 10sbat in meeting its compliance obligations.
• Corporate transactions: In the event of a merger, acquisition, or sale of substantially all of 10sbat's assets, player data may be transferred to the acquiring entity, subject to the same data protection obligations as set out in this Policy.

6 International Data Transfers

10sbat's platform infrastructure and certain third-party service providers may be located in jurisdictions outside Pakistan. Where personal data is transferred internationally, 10sbat ensures that appropriate safeguards are in place to maintain a standard of data protection equivalent to that applied within 10sbat's primary operating jurisdiction.

Safeguards for international transfers include: standard contractual clauses incorporated into data processing agreements with service providers; transfer to jurisdictions that have received an adequacy determination by a recognised data protection authority; or transfer under binding corporate rules where applicable. Transfers are made only where genuinely necessary for the provision of platform services.

Pakistani player data is handled with full awareness of and sensitivity to local privacy expectations. 10sbat does not transfer data to jurisdictions known to have inadequate data protection frameworks without implementing compensating contractual safeguards.

7 Data Retention Periods

10sbat retains personal data only for as long as necessary to fulfil the purposes for which it was collected, and in compliance with legal retention obligations under applicable AML, KYC, and gaming licence regulations. The following retention periods apply:

At the end of applicable retention periods, personal data is either securely deleted or anonymised such that it can no longer be attributed to an identifiable individual.

8 Cookies & Tracking Technologies

10sbat uses cookies and similar tracking technologies on the platform. Cookies are small data files placed on your device when you access the 10sbat website. They serve the following functions:

• Essential cookies: Required for the platform to function — including maintaining your logged-in session, remembering your language and currency preferences, and enabling secure account access. These cannot be disabled without affecting platform functionality.
• Performance and analytics cookies: Used to collect anonymised data about how players navigate the platform, which pages are most visited, and where errors occur. This data is used to improve platform performance. No personally identifiable information is included in analytics data.
• Functional cookies: Remember preferences such as game volume settings, table layout preferences, and recently played games to improve your platform experience.
• Marketing cookies: Used only where explicit consent has been obtained. These cookies track which promotional offers you have interacted with to avoid sending duplicate or irrelevant communications.

You may manage cookie preferences through your browser settings. Most browsers allow you to reject non-essential cookies, delete existing cookies, or receive notification before a cookie is set. Note that disabling essential cookies will affect your ability to log in and use the 10sbat platform.

9 Your Data Protection Rights

As a 10sbat player, you hold the following rights in respect of your personal data. These rights may be subject to limitations where legal obligations require data retention or restrict disclosure:

To exercise any of the above rights, submit a request via 10sbat's 24/7 live chat or support email. 10sbat will respond within 30 calendar days and may request identity verification before processing your request to ensure your data is not disclosed to an unauthorised party.

10 Security Measures

10sbat implements technical and organisational security measures appropriate to the sensitivity of player personal data. These measures are reviewed regularly and updated in response to evolving security threats. Current safeguards include:

• 256-bit SSL/TLS encryption for all data in transit between player devices and 10sbat servers.
• AES-256 encryption for sensitive data stored at rest, including identity documents and financial information.
• Role-based access controls ensuring that only authorised 10sbat personnel with a documented operational need can access personally identifiable player data.
• Two-factor authentication (2FA) available to all players and mandatory for 10sbat administrative accounts.
• Regular third-party penetration testing and vulnerability assessments of platform infrastructure.
• Automated anomaly detection systems that flag unusual account activity, rapid IP changes, or atypical transaction patterns for manual review.
• Comprehensive data breach response procedures, including a commitment to notify affected players and relevant authorities of material breaches within 72 hours of confirmed detection where required by law.

While 10sbat maintains robust security measures, no online platform can guarantee absolute security. Players are advised to use strong, unique passwords, enable two-factor authentication, and avoid accessing their 10sbat account over unsecured public Wi-Fi networks.

11 Minors & Age Verification Policy

10sbat strictly prohibits the use of its platform by persons under the age of 21. 10sbat does not knowingly collect or process personal data from individuals under 21 years of age. All accounts are subject to KYC age verification before full platform access is granted.

Where 10sbat discovers that personal data has been collected from an individual who was under 21 at the time of collection, the account will be immediately closed, all data will be deleted (subject to any mandatory legal retention requirements), and any real-money balances will be handled in accordance with 10sbat's minor-account policy and applicable regulatory guidance.

12 Third-Party Services & External Links

The 10sbat platform integrates services from third-party providers including game studios, payment gateways, and identity verification services. Each of these providers operates under their own privacy policies and data processing agreements with 10sbat. 10sbat is not responsible for the privacy practices of third-party providers beyond the contractual obligations imposed through data processing agreements.

The 10sbat platform does not contain links to external third-party websites for the purpose of advertising or general information. Where links to regulatory or support bodies are provided in the responsible gaming context, those organisations operate under their own independent privacy policies.

Players who interact with payment processors (such as JazzCash or EasyPaisa apps) outside of the 10sbat platform interface are subject to those providers' own privacy policies and data practices, which are outside of 10sbat's control.

13 Changes to This Privacy Policy

10sbat reserves the right to update and amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or platform data practices. When material changes are made — meaning changes that meaningfully affect your rights or the manner in which your data is processed — 10sbat will notify registered players via the email address or mobile number associated with their account at least 14 days before the changes take effect.

Minor updates, including corrections and clarifications that do not substantively alter player rights, may be published without prior notification. The "Last Updated" date at the top of this Policy will always reflect the most recent revision. We encourage players to review this Policy periodically to stay informed of how 10sbat manages personal data.

Continued use of the 10sbat platform following the effective date of an updated Policy constitutes acceptance of the revised terms. If you do not agree with a material policy change, you may close your account prior to the effective date by contacting 10sbat support.

14 Contact & Privacy Complaints

For all privacy-related enquiries, data subject access requests, or complaints about 10sbat's data practices, please contact us through one of the following channels:

• Live Chat: Available 24/7 through the 10sbat platform — average response time 3–5 minutes. For privacy requests, please state "Data Privacy Request" at the start of your message so it is routed to the appropriate team.
• Support Email: [email protected] (plain text only — not a clickable link). Allow up to 3 business days for email responses to privacy enquiries.

When submitting a data subject access request, please include your registered email address, your 10sbat username, and a description of the data or action requested. For account security purposes, 10sbat will verify your identity before processing any request that involves disclosure, modification, or deletion of personal data.