hq117 Privacy Policy

This Privacy Policy ("Policy") is issued by hq117 ("hq117", "we", "us", "our") and applies to all personal data collected and processed in connection with your use of the hq117 website at hq117.net and all associated services, games, betting markets, account features, and support channels (collectively, the "Platform").

This Policy is intended to provide you with a clear and comprehensive explanation of how hq117 collects, uses, stores, shares, and protects your personal information. It also sets out the rights you have in relation to your personal data and explains how you can exercise those rights.

This Policy applies to all registered users and visitors of the hq117 Platform, including players based in Pakistan and internationally. By registering an account with hq117 or continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood this Policy.

For the purposes of applicable data protection law, hq117 is the data controller in respect of the personal data collected and processed through the Platform. As data controller, hq117 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully and in accordance with this Policy.

If you have any questions about how hq117 processes your personal data, or if you wish to exercise any of your data subject rights, you may contact hq117's designated privacy team using the contact information set out in Section 14 of this Policy.

hq117 operates under an international gaming licence. Our data processing activities are designed to be consistent with the requirements of international data protection standards including, where applicable, the principles set out in the General Data Protection Regulation (GDPR) and Pakistan's emerging digital data governance framework.

hq117 collects personal data from you directly (when you provide it) and automatically (when you use the Platform). The categories of personal data we collect include:

hq117 does not intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, health data, or biometric data unless specifically required for regulatory compliance and with your explicit consent where required by law.

hq117 uses the personal data described in Section 3 for the following specific purposes:

• Account Registration & Management: To create and maintain your hq117 account, authenticate your identity at login, and manage your account preferences and settings.
• Identity Verification (KYC): To verify your age, identity, and eligibility to use the Platform in compliance with our gaming licence requirements and applicable anti-money laundering (AML) regulations.
• Payment Processing: To process your deposits in PKR via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard, and to process your withdrawal requests to verified payment methods.
• Gaming & Betting Services: To provide you with access to hq117's casino games, live dealer tables, cricket betting markets, sports betting, and all other Platform services.
• Responsible Gaming: To monitor your gaming activity for signs of problematic gambling behaviour, enforce self-exclusion requests, apply deposit and loss limits, and comply with our responsible gaming obligations under our licence.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, account abuse, bonus exploitation, and other prohibited conduct on the Platform.
• Anti-Money Laundering (AML): To monitor transactions for suspicious activity, conduct enhanced due diligence where required, and report to relevant authorities as mandated by applicable law.
• Customer Support: To respond to your inquiries, resolve complaints, and provide technical assistance through live chat and email.
• Marketing Communications: To send you promotional offers, bonus notifications, and Platform updates where you have provided consent or where we have a legitimate interest in doing so. You may opt out at any time.
• Legal Compliance: To comply with applicable laws, regulations, court orders, and the requirements of our international gaming licence.
• Platform Improvement: To analyse aggregated usage data to improve the hq117 Platform's performance, user experience, game offerings, and features.

hq117 processes your personal data on the following legal bases, consistent with internationally recognised data protection principles:

• Contractual Necessity: Processing is necessary to perform the contract between you and hq117 — specifically, to provide the Platform services you have registered to access, including account management, payment processing, and access to games and betting markets.
• Legal Obligation: Processing is required to comply with legal obligations applicable to hq117, including KYC/AML requirements under our gaming licence, financial crime prevention laws, and mandatory record-keeping obligations.
• Legitimate Interests: Processing is carried out for purposes that serve hq117's legitimate business interests, including fraud detection, Platform security, responsible gaming monitoring, and business analytics — provided such interests are not overridden by your own interests or fundamental rights.
• Consent: Where hq117 relies on your consent as the legal basis for processing (primarily for direct marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

hq117 uses cookies and similar tracking technologies (including web beacons and session tokens) on the Platform. Cookies are small data files stored on your device that help the Platform function correctly and allow hq117 to understand how you use the Platform.

hq117 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to operate and cannot be disabled. These include session authentication tokens, security cookies, and load-balancing cookies.
• Functional Cookies: Allow the Platform to remember your preferences such as your selected language, currency (PKR), and responsible gaming settings between sessions.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate and use the Platform, enabling hq117 to improve performance and user experience over time.
• Marketing Cookies: Used to deliver relevant promotional content and track the effectiveness of hq117's marketing communications where you have consented to receive them.

You may control cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may impair the functionality of the hq117 Platform, including the ability to log in to your account.

hq117 does not sell your personal data. We do not share your personal information with third parties for their own commercial purposes. hq117 may share your personal data with third parties only in the following limited circumstances:

• Payment Processors: Your financial data is shared with payment processing partners (including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard networks) solely for the purpose of processing your deposits and withdrawals. These partners process your data under their own privacy policies and are contractually bound to protect it.
• Identity Verification Providers: hq117 uses third-party KYC and identity verification service providers to assist in verifying the identity and age of registered players. These providers process your KYC documentation on hq117's behalf and under hq117's instruction.
• Gaming Software Providers: Game data may be shared with our licensed game software providers to facilitate the delivery of casino games and betting markets on the Platform. These providers receive only the minimum data necessary to operate their services.
• Regulatory & Law Enforcement Authorities: hq117 may disclose personal data to regulators, law enforcement agencies, tax authorities, or other governmental bodies where required to do so by applicable law, court order, or regulatory direction under our gaming licence.
• Anti-Fraud & AML Partners: hq117 may share limited transaction and identity data with anti-fraud and anti-money laundering screening services to fulfil our compliance obligations.
• Business Successors: In the event of a merger, acquisition, or sale of hq117's business assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

hq117 operates internationally and your personal data may be transferred to, stored in, or processed in countries other than Pakistan. These transfers occur in connection with hq117's use of internationally hosted infrastructure, payment processing systems, and third-party service providers described in Section 7.

Where personal data is transferred outside of Pakistan to jurisdictions that may not provide an equivalent level of data protection, hq117 takes steps to ensure that appropriate safeguards are in place, including:

• Entering into data processing agreements with receiving parties that include contractual protections aligned with internationally recognised data protection standards.
• Selecting service providers that operate in jurisdictions or under frameworks that provide adequate levels of data protection.
• Implementing technical and organisational security measures that apply uniformly regardless of where data is stored or processed.

By using the hq117 Platform and providing us with your personal data, you acknowledge that your information may be transferred internationally in accordance with this Policy and the safeguards described herein.

hq117 retains your personal data for only as long as is necessary for the purposes for which it was collected, or as required by applicable law and our gaming licence obligations. Our standard data retention periods are as follows:

• Account & Identity Data: Retained for the duration of your active hq117 account plus a minimum of five (5) years following account closure, as required by our gaming licence and AML compliance obligations.
• Financial & Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, in accordance with financial record-keeping requirements applicable under our gaming licence.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Communications Data: Live chat transcripts and support email records are retained for up to two (2) years from the date of the interaction.
• Technical & Usage Data: Retained for up to thirteen (13) months from collection for analytics purposes, after which it is anonymised or deleted.
• Marketing Consent Records: Retained for as long as you remain subscribed to marketing communications, plus a reasonable period thereafter to demonstrate consent history.

Upon expiry of the applicable retention period, hq117 will securely delete or irreversibly anonymise your personal data in accordance with our data disposal procedures. Data subject to an ongoing legal hold, regulatory inquiry, or dispute resolution process may be retained beyond the standard periods until the matter is resolved.

As a player registered with hq117, you hold specific rights in relation to your personal data. hq117 is committed to facilitating the exercise of these rights in a timely and transparent manner. Your rights include:

Please note that certain rights are subject to limitations where hq117 is required to retain data for legal compliance purposes — for example, AML and gaming licence record-keeping obligations may override an erasure request in respect of transaction and KYC data.

hq117 implements comprehensive technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes:

• Encryption in Transit: All data transmitted between your device and the hq117 Platform is encrypted using Transport Layer Security (TLS 1.2 or higher).
• Encryption at Rest: Personal data stored in hq117's databases and infrastructure is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within hq117's internal systems is restricted on a strict need-to-know basis with role-based access controls and multi-factor authentication for administrative systems.
• Intrusion Detection: hq117 operates continuous network monitoring and intrusion detection systems to identify and respond to security incidents promptly.
• Vulnerability Management: hq117's Platform undergoes regular security assessments including penetration testing and vulnerability scanning by qualified security professionals.
• Staff Training: All hq117 personnel who handle personal data receive regular data protection and security awareness training.
• Incident Response: hq117 maintains a documented data breach response procedure. In the event of a significant data breach affecting your personal data, hq117 will notify affected players and relevant authorities as required by applicable law.

The hq117 Platform is strictly intended for adults aged 21 years and above. hq117 does not knowingly collect personal data from individuals under the age of 21. This is a non-negotiable requirement under both hq117's Terms & Conditions and our international gaming licence obligations.

hq117 implements age verification checks during the registration process and through KYC verification to help ensure compliance with the 21+ requirement. If hq117 becomes aware or has reason to believe that personal data belonging to a person under the age of 21 has been collected, hq117 will:

• Immediately suspend the account associated with that data.
• Void any gaming activity and associated winnings from the account.
• Return any deposits made, less any bonuses received, where practicable.
• Securely delete the personal data of the underage individual as soon as is legally permissible.

hq117 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our gaming licence conditions, or our data processing practices. All updates will be posted on this page with a revised effective date.

When material changes are made to this Policy — particularly changes that affect your rights or hq117's data processing purposes — hq117 will provide notice to registered players by email to the address associated with your account and/or by displaying a prominent notification on the Platform.

Your continued use of the hq117 Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you should cease using the Platform and contact hq117 support to arrange account closure and data handling in accordance with your rights under Section 10.

hq117 recommends that all registered players review this Privacy Policy periodically to remain informed of how their personal data is being handled. The effective date displayed at the top of this page indicates when the most recent revision was made.

If you have any questions, concerns, or requests relating to this Privacy Policy or hq117's handling of your personal data, please contact our privacy team using the details below. hq117 is committed to resolving all privacy enquiries promptly and transparently.

• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Subject Request" so your message reaches the correct team. Responses are provided within 6 hours during standard operating hours and within 30 days for formal data subject requests.
• Live Chat: Available 24/7 directly on the hq117 Platform — suitable for general privacy questions and initial guidance on how to submit a formal data subject request.

When submitting a data subject request, please include your registered hq117 account username or email address and a description of your request. hq117 may need to verify your identity before processing certain requests to protect against unauthorised access to your personal data.