Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is published by 10game ("we", "us", "our"), the operator of the online gaming platform accessible at https://10game.cam ("the Platform"). It sets out how we collect, use, store, disclose and protect personal data relating to individuals who access or use the Platform ("you", "User", "Data Subject").

10game is an English-language platform designed for Pakistani users and other English-reading markets. We are committed to processing personal data lawfully, fairly and transparently in accordance with applicable data-protection law. This Policy is written in English and the English version is authoritative.

By registering an account or continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood its content. Where processing is based on consent, your consent is requested separately through clearly worded opt-in mechanisms.

2 Definitions

In this Policy the following terms carry the meanings given below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, device identifiers, location data and financial references.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure and deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. In the context of this Policy, that entity is 10game.
• "Data Processor" — a third party that processes Personal Data on behalf of and under the instructions of the Data Controller.
• "Cookies" — small text files placed on your device by the Platform for the purposes described in Section 10.
• "KYC" — Know Your Customer verification, comprising identity, age and, where required, address verification processes.
• "Special Category Data" — personal data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data used for unique identification, health data, or data concerning sex life or sexual orientation.

3 Data Controller

10game acts as the Data Controller in respect of Personal Data collected through the Platform. For all data-related enquiries, access requests and complaints, please contact us using the details set out in Section 15 of this Policy.

Where 10game engages third-party service providers — such as payment processors, KYC verification providers, game content suppliers and customer-support platforms — those providers may act as Data Processors under contracts that require them to process data only on 10game's documented instructions and to maintain appropriate security measures.

4 Personal Data We Collect

4.1 Data You Provide Directly

When you register, verify your identity or contact support, you provide data including:

• Full legal name as it appears on your identity document;
• Date of birth;
• Email address and, where provided, mobile number;
• Residential address;
• Identity document details — CNIC number, passport number or similar — and scanned copies or photographs of those documents;
• Selfie or liveness check images submitted during KYC;
• Proof-of-address documents where required;
• Payment instrument references — e.g., mobile wallet account name associated with Easypaisa or JazzCash, bank account name for Raast or HBL/UBL/Meezan Bank/Bank Alfalah transfers — sufficient to process and verify transactions.

4.2 Data Collected Automatically

When you access the Platform, we automatically collect technical and behavioural data, including:

4.3 Special Category Data

10game does not intentionally collect Special Category Data. Responsible gambling tools may collect information about self-reported gambling habits, which in some jurisdictions may constitute health-adjacent data. Such information is used solely to operate responsible gambling features and is not disclosed to third parties except where required by regulatory obligation.

5 Purposes of Processing & Legal Bases

We process your Personal Data only for specified, explicit and legitimate purposes. The table below sets out each processing purpose and its corresponding legal basis:

Where we rely on legitimate interests as a legal basis, we have balanced those interests against your rights and freedoms and concluded that our legitimate interests are not overridden. You may contact us to request further information about this balancing assessment.

6 Sharing Your Personal Data

10game does not sell, rent or trade your Personal Data to third parties for marketing purposes. We share data only in the following circumstances:

• Service Providers (Data Processors): We engage third-party providers to perform services on our behalf, including KYC verification providers, payment processing services, customer support platforms, cloud hosting providers and fraud prevention tools. All processors are subject to contractual data-protection obligations.
• Payment Processors: When you make a deposit or withdrawal using methods such as Easypaisa, JazzCash, Raast, or bank transfers via HBL, UBL, Meezan Bank or Bank Alfalah, the minimum data necessary to process that transaction is transmitted to the relevant provider. This is not an endorsement of, or claim of gambling support by, any payment provider.
• Regulatory and Law Enforcement Authorities: We may disclose Personal Data where required by applicable law, court order or instruction from a competent regulatory or law-enforcement authority. We will notify you of such a disclosure where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets involving 10game, Personal Data may be transferred to the acquiring entity, subject to the privacy protections described in this Policy continuing to apply.
• With Your Consent: We will share data with additional third parties only where you have given explicit, informed consent to that sharing.

7 International Data Transfers

10game's servers and service providers may be located in jurisdictions outside Pakistan. When Personal Data is transferred internationally, we apply appropriate safeguards to ensure the data receives a level of protection equivalent to that described in this Policy. Safeguards may include contractual clauses that impose data-protection obligations on the recipient party.

If you would like further information about the international transfer mechanisms applicable to your data, please contact us using the details in Section 15.

8 Data Retention Periods

We retain Personal Data for no longer than is necessary to fulfil the purpose for which it was collected and to comply with our legal and regulatory obligations. General retention guidelines are as follows:

• Account and KYC Data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, or for longer periods where required by anti-money laundering or gaming regulatory obligations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction to comply with financial record-keeping obligations.
• Customer Support Communications: Retained for three (3) years from the date of the communication, or longer where the matter relates to an unresolved dispute or regulatory investigation.
• Marketing Preferences: Retained until you withdraw consent or request deletion, plus a short additional period to record the withdrawal.
• Technical and Session Logs: Retained for up to twelve (12) months, subject to security and fraud investigation requirements.

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

9 Security Measures

10game implements technical and organisational security measures proportionate to the risk presented by the processing activities we undertake. Current measures include:

• TLS/SSL encryption for all data in transit between user devices and our servers;
• Encryption or one-way hashing of sensitive data fields, including passwords, at rest;
• Role-based access controls restricting staff access to Personal Data to those with a business need;
• Regular security assessments of platform infrastructure and third-party integrations;
• Automated anomaly detection for unusual account activity, supporting both fraud prevention and responsible gambling monitoring.

Notwithstanding these measures, no online transmission or storage system is completely secure. You transmit data to the Platform at your own risk and are responsible for maintaining the security of your own account credentials. If you suspect any unauthorised access to your account, please contact support immediately.

10 Cookies & Similar Technologies

10game uses cookies and similar client-side storage technologies to operate and improve the Platform. The categories of cookies we use are described below:

Most web browsers allow you to manage cookies through browser settings. Disabling strictly necessary cookies will impair Platform functionality and may prevent you from logging in or completing transactions.

11 Minors

The Platform is strictly restricted to individuals aged 18 and over, or the higher minimum age required by the operator's license jurisdiction. 10game does not knowingly collect Personal Data from minors. If we become aware that Personal Data has been submitted by or on behalf of a person below the minimum age, we will take steps to close the associated account and delete the relevant data as promptly as practicable.

If you believe a minor has registered an account on the Platform, please contact us immediately at [email protected] so that we can investigate and act accordingly.

12 Your Data Rights

Subject to applicable data-protection law and our regulatory retention obligations, you have the following rights in relation to your Personal Data held by 10game:

To exercise any of these rights, please submit a written request to [email protected] with sufficient information to verify your identity. We will respond within thirty (30) days of receipt of a valid request. Complex or multiple requests may require an extension, of which you will be informed. We do not charge a fee for reasonable requests; however, manifestly unfounded or excessive requests may incur a reasonable administrative charge.

13 Complaints

If you are dissatisfied with how 10game has handled your Personal Data, we encourage you to contact us in the first instance using the support details in Section 15. We will investigate your concern and respond within a reasonable period.

If you remain unsatisfied following our response, you may have the right to lodge a complaint with the data-protection authority in the jurisdiction governing the operator's license. Specific supervisory authority details are available upon request through the support channel.

14 Amendments to This Policy

10game reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, our processing practices, or the services we offer. Where changes are material, we will notify registered users by email to the address on file or through a prominent notice on the Platform prior to the amended Policy taking effect.

The "Last Updated" date shown at the top of this page indicates when the most recent revision was made. Continued use of the Platform following notification of an amendment constitutes acceptance of the revised Policy. If you do not accept the revised terms, you should cease using the Platform and request account closure.

15 Contact Us

For all data-protection enquiries, access requests, correction requests, deletion requests or privacy complaints, please contact us through the following channel:

Please include your registered email address, the nature of your request, and any relevant reference numbers in your communication. For disputes relating to Platform use, please also review our Terms & Conditions. For responsible gambling concerns, please visit our Responsible Gambling page.