§ 1 Who We Are
s55com ("we", "us", "our") operates the online casino and sports betting platform accessible at s55com.app and through the s55com Android application ("Platform"). This Privacy Policy applies to all users who access, register on, or interact with the Platform, including Pakistani players who use the Platform for cricket betting, live casino games, slot titles, and related services.
For the purposes of applicable data protection law, s55com is the data controller responsible for your personal information. Questions, requests, or concerns relating to this policy should be directed to our support team using the contact details in Section 12.
§ 2 Information We Collect
s55com collects personal information in the following categories:
- Registration data: Full name, date of birth, gender, Pakistani mobile number (03XX format), chosen username, email address, and password (stored in hashed form — never in plain text).
- Identity verification documents: Copies of CNIC, passport, or driving licence; proof of address documents such as utility bills or bank statements; and payment method ownership evidence, where requested during the verification process.
- Financial data: Deposit and withdrawal transaction records including amounts in PKR, payment method identifiers (JazzCash account number, Easypaisa wallet reference, bank account details, card BIN data), and transaction timestamps. Full card numbers and full bank account details are not stored by s55com — these are handled exclusively by our licensed payment processor partners.
- Gameplay data: Game session logs, wager amounts and outcomes, bonus utilisation records, bet history on cricket and other sportsbook markets, and jackpot participation records.
- Device and technical data: IP address, device type and model, operating system version, browser or app version, screen resolution, and unique device identifiers. This data is collected automatically when you access the Platform.
- Behavioural data: Pages visited, features used, session duration, click patterns, and in-app navigation. This data is used to improve the Platform and personalise your experience.
- Communications data: Records of any correspondence with s55com customer support, including chat transcripts and email exchanges.
§ 3 How We Use Your Data
s55com uses the personal information we collect for the following purposes:
- Account management: To create, maintain, and secure your s55com account; to process s55com logins; and to communicate with you about account activity, security alerts, and platform updates.
- Service delivery: To process deposits and withdrawals in PKR via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and other supported payment methods; to enable gameplay on casino and sportsbook products; and to credit and track bonuses and promotions.
- Identity and age verification: To confirm that you meet the minimum age requirement of 18 years and to verify your identity as required by our compliance obligations.
- Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, bonus abuse, multi-accounting, money laundering, and other prohibited conduct under our Terms and Conditions.
- Regulatory compliance: To fulfil our obligations under applicable law, including record-keeping requirements and cooperation with lawful requests from regulatory and law enforcement authorities.
- Responsible gaming: To monitor gameplay patterns for indicators of problem gambling and to administer voluntary responsible gaming tools including deposit limits, session controls, and self-exclusion.
- Marketing communications: To send you promotional offers, bonus notifications, and product updates where you have provided consent or where we have a legitimate interest to do so. You may opt out of marketing communications at any time via your account notification settings.
- Platform improvement: To analyse usage patterns, test new features, resolve technical issues, and improve the overall s55com user experience for Pakistani players.
§ 4 Legal Basis for Processing
s55com processes your personal data on one or more of the following legal grounds:
- Contractual necessity: Processing required to fulfil our obligations under the s55com Terms and Conditions — including account creation, payment processing, and gameplay delivery — is carried out on the basis of contract performance.
- Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement is carried out on the basis of s55com's legitimate interests, provided those interests are not overridden by your fundamental rights.
- Legal obligation: Processing required to comply with applicable law, regulatory requirements, or lawful authority requests is carried out on the basis of legal obligation.
- Consent: Processing for marketing communications and non-essential cookies is carried out on the basis of your consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
§ 5 Sharing Your Information
s55com does not sell your personal data to third parties. We may share your information in the following limited circumstances:
- Payment processors: Your financial data is shared with our licensed payment processing partners — including JazzCash, Easypaisa, and banking partners — solely for the purpose of processing your deposit and withdrawal transactions. These partners are bound by their own data protection obligations.
- Game providers: Certain gameplay session data is shared with our licensed game studio partners (such as PG Soft, Pragmatic Play, and Evolution Gaming) to deliver their games and resolve technical disputes about game outcomes.
- Identity verification providers: Identity and age verification data may be processed by third-party verification service providers engaged by s55com. These providers act as data processors under our instruction.
- Regulatory authorities: s55com will disclose personal data to law enforcement, regulatory, or judicial authorities when required to do so by applicable law or valid legal process.
- Corporate transactions: In the event of a merger, acquisition, or sale of all or part of s55com's business, user data may be transferred to the acquiring entity subject to equivalent data protection commitments.
In all cases where data is shared with third parties, s55com takes reasonable contractual and technical steps to ensure your data is handled appropriately and in accordance with applicable law.
§ 6 Data Retention
s55com retains your personal data for as long as your account remains active and for a further period as required by our legal, regulatory, and compliance obligations. Specifically:
- Account and identity data is retained for a minimum of five (5) years following account closure to satisfy anti-money laundering record-keeping requirements.
- Transaction and financial records are retained for a minimum of five (5) years from the date of each transaction.
- Gameplay logs are retained for a minimum of three (3) years to support dispute resolution processes.
- Marketing consent records are retained until consent is withdrawn and for a reasonable period thereafter to evidence compliance.
When data is no longer required for any lawful purpose, s55com will securely delete or anonymise it in accordance with our data management procedures.
§ 7 Cookies & Tracking
s55com uses cookies and similar tracking technologies on its web platform and Android application to deliver core functionality and improve user experience. The categories of cookies we use include:
- Essential cookies: Required for the Platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled without impairing core Platform functionality.
- Functional cookies: Used to remember your preferences such as language settings, game lobby filters, and notification preferences between sessions.
- Analytics cookies: Used to collect aggregated data about Platform usage patterns — pages visited, session duration, feature interactions — to inform product development decisions. This data is anonymised where possible.
- Marketing cookies: Used to personalise promotional content and measure the effectiveness of marketing campaigns. These are only deployed with your consent and can be disabled via your browser or app settings.
You may manage your cookie preferences through your browser settings or device privacy controls. Blocking essential cookies will impair your ability to log in and use core Platform features.
§ 8 Your Rights
Subject to applicable law, you have the following rights in relation to your personal data held by s55com:
Right of AccessYou may request a copy of the personal data s55com holds about you, including account details, transaction history, and gameplay records.
Right to RectificationIf any personal data we hold is inaccurate or incomplete, you have the right to request that it be corrected. For registration data, you can update many fields directly in your account settings.
Right to ErasureYou may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations — particularly anti-money laundering record-keeping requirements which override erasure requests for financial transaction data.
Right to RestrictionYou may request that s55com restrict processing of your data in certain circumstances — for example, while the accuracy of data you have contested is being verified.
Right to PortabilityWhere processing is based on consent or contractual necessity and carried out by automated means, you may request your data in a structured, machine-readable format.
Right to ObjectYou may object to processing based on legitimate interests — including profiling for marketing purposes. s55com will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request". s55com will respond within 30 days of receiving a valid, complete request. We may need to verify your identity before processing any rights request.
§ 9 Data Security
s55com implements a range of technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:
- TLS/SSL encryption for all data in transit between your device and s55com servers;
- Bcrypt or equivalent hashing for all stored passwords — plain-text passwords are never stored;
- OTP-based two-factor authentication for account login from unrecognised devices;
- Automatic session timeout after periods of inactivity;
- Role-based access controls limiting internal staff access to personal data on a need-to-know basis;
- Regular security assessments and penetration testing of the Platform infrastructure.
While s55com takes all reasonable steps to secure your data, no system is completely immune to risk. In the event of a data breach that poses a risk to your rights, s55com will notify affected users and relevant authorities in accordance with applicable law.
§ 10 Children's Privacy
s55com is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 18. Age is verified at the point of registration, and accounts where underage use is suspected are suspended immediately pending investigation.
If you believe a minor has registered on s55com, please contact us immediately at [email protected]. We will investigate and take appropriate action, including account closure and deletion of any data associated with the underage user.
§ 11 Changes to This Policy
s55com reserves the right to update or revise this Privacy Policy at any time. When material changes are made, we will notify registered users via on-platform notification or email to the address associated with your s55com account. The "Last Updated" date at the top of this policy reflects when the most recent revisions were made.
Continued use of the Platform after notification of changes constitutes acceptance of the revised Privacy Policy. If you do not agree to material changes, you should cease using the Platform and request account closure.
§ 12 Contact Us
For all privacy-related enquiries, data rights requests, or concerns about how s55com handles your personal information, please contact our support team:
Email: [email protected]
Subject line for data requests: "Data Rights Request — [your username]"
Response time: We aim to respond to all privacy enquiries within 5 business days and to data rights requests within 30 calendar days.