mostpaly Privacy Policy

Introduction

This Privacy Policy ("Policy") sets out how mostpaly ("we", "us", "our", "the Platform", "the Company") collects, processes, stores, and protects the personal data of users ("you", "your", "the Player") who access or register on the mostpaly website and associated gaming services. mostpaly is committed to handling all personal information in a transparent, lawful, and responsible manner, consistent with internationally recognised data protection standards.

This Policy applies to all products and services offered under the mostpaly brand, including the sportsbook, live casino, slot games, Limbo, Keno, and all other gaming products available to registered players. It also applies to any communications you have with us through our customer support channels, email correspondence, and any other interaction with the Platform.

This Policy should be read alongside our Terms & Conditions, which govern the overall contractual relationship between you and mostpaly. Both documents form part of the binding agreement between the parties.

Data We Collect

mostpaly collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with the platform, and in some cases from third-party service providers involved in identity verification or fraud prevention. The categories of data we collect are described below.

Identity & Registration Data

When you create a mostpaly account, we collect information necessary to establish and verify your identity. This includes your full legal name, date of birth, residential address, nationality, and a valid government-issued identity document such as your CNIC (Computerised National Identity Card), passport, or driving licence. Pakistani players from Karachi, Lahore, Islamabad, Faisalabad, and other cities are required to submit a valid CNIC as their primary identity document during the KYC verification process.

Contact Data

We collect your email address and, where provided, a contact phone number. These are used for account communication, support correspondence, transaction notifications, and regulatory reporting purposes. Phone numbers are stored as plain data and are never used for unsolicited marketing without your explicit consent.

Financial Data

To process deposits and withdrawals, mostpaly collects payment-related information including your JazzCash or EasyPaisa mobile wallet number, bank account details (for HBL, UBL, or Meezan Bank transfers), or card details (for Visa and Mastercard transactions). mostpaly does not store full card numbers — card data is processed and tokenised by our certified payment gateway partners in accordance with applicable payment security standards.

Usage & Technical Data

Cookies & Analytical Data

mostpaly uses cookies, web beacons, and similar tracking technologies to understand how the platform is used and to improve the experience for all players. Please refer to Section 8 of this Policy for a full breakdown of cookie categories and how to manage your preferences.

How We Use Your Data

mostpaly processes personal data for specific, documented purposes only. We do not use your data for any purpose that is incompatible with the reasons for which it was originally collected. The primary purposes for which mostpaly processes personal data are as follows:

• Account Registration & Management: To create and maintain your mostpaly account, verify your identity, and manage your player profile throughout your relationship with the Platform.
• KYC & Age Verification: To fulfil our legal and regulatory obligations to verify that all players are 21 years of age or older, and that their identity and source of funds meet our compliance standards.
• Payment Processing: To process your deposits and withdrawals in PKR via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard in a secure and timely manner.
• Platform Delivery: To provide access to our full range of gaming products including cricket betting, live casino, slots, Limbo, and Keno, and to personalise your experience on the platform.
• Anti-Money Laundering (AML) & Fraud Prevention: To monitor transaction patterns and player behaviour for signs of fraudulent activity, money laundering, or other financial crime, as required under our international licensing obligations.
• Customer Support: To respond to your queries, resolve complaints, and maintain records of interactions for quality assurance and dispute resolution purposes.
• Responsible Gaming: To monitor gameplay patterns and proactively identify players who may be showing indicators associated with problem gambling, in line with our duty of care obligations.
• Legal & Regulatory Compliance: To comply with applicable laws, respond to regulatory requests, and fulfil reporting obligations imposed by our licensing authority.
• Service Improvement: To analyse aggregated, anonymised usage data to improve platform performance, identify bugs, and enhance the overall player experience.
• Marketing Communications: Where you have provided explicit consent, to send you information about mostpaly promotions, bonuses, and new product features. You may withdraw consent at any time.

Legal Basis for Processing

mostpaly processes personal data only where a valid legal basis exists. In most cases, one or more of the following bases applies to each processing activity carried out by the Platform:

• Contractual Necessity: Processing that is required to perform the contract between you and mostpaly — including account management, payment processing, and delivery of gaming services — is carried out on the basis of contractual necessity.
• Legal Obligation: Where mostpaly is required by law or regulatory mandate to process your data — such as for KYC verification, AML monitoring, or regulatory reporting — processing is carried out on the basis of legal obligation.
• Legitimate Interests: In certain cases, mostpaly processes personal data on the basis of legitimate interests, such as fraud detection, platform security, and responsible gaming monitoring. We balance these interests against your privacy rights and do not apply this basis where your interests override ours.
• Consent: For non-essential activities such as marketing communications or the use of analytical cookies, mostpaly processes data only where you have provided freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Data Sharing & Disclosure

mostpaly does not sell, rent, or trade your personal data to third parties for commercial purposes. Data is shared with external parties only in the limited circumstances described below, and always subject to appropriate contractual protections.

Service Providers

We engage trusted third-party service providers to assist in delivering the mostpaly platform. These include payment gateway operators (who process your JazzCash, EasyPaisa, and card transactions), identity verification providers (who assist with KYC and document validation), cloud infrastructure providers, and customer support software vendors. All such providers are contractually bound to process your data solely on our instructions and to maintain appropriate security measures.

Regulatory & Law Enforcement Authorities

mostpaly may be required to disclose personal data to regulators, licensing authorities, financial intelligence units, or law enforcement agencies where required to do so by law, court order, or regulatory direction. Such disclosures are made only to the extent required and in compliance with applicable legal procedures.

Anti-Fraud & AML Platforms

To fulfil our anti-money laundering and fraud prevention obligations, mostpaly may share data with industry-standard AML screening tools and fraud detection platforms. Such sharing is limited to the data necessary to perform the relevant screening functions and is governed by binding data processing agreements.

Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the mostpaly business, your personal data may be transferred to the acquiring entity as part of the transaction. In such circumstances, mostpaly will provide reasonable advance notice to affected players and ensure that the receiving entity is bound by terms no less protective than those in this Policy.

International Data Transfers

mostpaly operates as an internationally licensed platform, and your personal data may be processed or stored on servers located outside Pakistan. Where data is transferred to countries that may not offer an equivalent level of data protection to your home jurisdiction, mostpaly ensures that appropriate safeguards are in place before any such transfer occurs.

These safeguards may include the use of standard contractual clauses approved by recognised data protection authorities, binding corporate rules where applicable, or other legally recognised transfer mechanisms that provide meaningful protection for your personal data.

By registering on mostpaly and accepting this Privacy Policy, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan as described above. mostpaly takes all reasonable steps to ensure that your data is handled securely and in accordance with this Policy regardless of where it is processed.

Data Retention

mostpaly does not retain personal data beyond the period necessary for the purposes for which it was collected, or beyond the period required by applicable law or regulatory obligation. The following general retention principles apply across the Platform:

• Active Account Data: Personal data associated with an active mostpaly account is retained for the duration of the account relationship and for a minimum of five years following account closure, in line with standard AML and gaming regulatory requirements.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of seven years from the date of the transaction to satisfy financial record-keeping obligations.
• KYC Documents: Identity verification documents submitted during the KYC process are retained for the duration of the account relationship and for a minimum of five years following account closure.
• Support Communications: Customer support correspondence is retained for a period of three years from the date of the last interaction, to facilitate dispute resolution and quality assurance.
• Marketing Data: Where you have consented to marketing communications, your contact preferences are retained until you withdraw consent or request deletion. Following withdrawal of consent, your data is removed from marketing lists within 30 days.
• Analytical & Cookie Data: Anonymised analytical data derived from platform usage is retained indefinitely in aggregated form. Individual-level session and cookie data is deleted within 13 months.

When data is no longer required and no legal obligation to retain it exists, mostpaly securely deletes or anonymises it in a manner that prevents reconstruction of identifiable information.

Cookies & Tracking Technologies

mostpaly uses cookies and similar technologies — including web beacons, pixel tags, and local storage objects — to operate the platform effectively, maintain your session, and understand how players interact with the site. The following categories of cookies are used on mostpaly:

You can manage your cookie preferences at any time through the cookie settings panel available on the mostpaly platform. Please note that disabling non-essential cookies may affect the functionality and personalisation of your player experience. Strictly necessary and security cookies cannot be disabled as they are integral to the safe operation of the platform.

Your Privacy Rights

As a registered player on mostpaly, you hold a set of rights in relation to your personal data. These rights are outlined below. To exercise any of these rights, you may contact our support team at [email protected]. We aim to acknowledge all data rights requests within five business days and to resolve them within 30 days, though complex requests may require additional time.

• Right of Access: You have the right to request a copy of all personal data held by mostpaly in relation to your account. We will provide this in a structured, commonly used, and machine-readable format upon verified request.
• Right to Rectification: If any personal data held on your account is inaccurate or incomplete, you have the right to request that it be corrected. For most account details, you may update information directly through the account settings panel.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent and no other legal basis applies. Please note that certain data must be retained by mostpaly for regulatory reasons even following a deletion request — we will inform you of any such limitations at the time of your request.
• Right to Restriction of Processing: In certain circumstances, you may request that mostpaly restrict the processing of your personal data — for example, while the accuracy of data is being contested or while a complaint is under investigation.
• Right to Data Portability: You may request that personal data you have provided to mostpaly be transferred to you or to another controller in a structured, machine-readable format, where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on legitimate interests. mostpaly will cease such processing unless compelling legitimate grounds exist that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent — such as for marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Children & Minors

mostpaly operates a strict 21+ age policy across all of its products and services. The Platform is not directed at, and does not knowingly collect personal data from, any individual under the age of 21. Registration on mostpaly is only available to adults who meet the minimum age requirement and have passed our age verification process.

If mostpaly becomes aware that personal data has been collected from an individual under the age of 21 — whether through a misrepresentation of age during registration or by any other means — the relevant account will be immediately suspended, all associated data will be reviewed, and the account will be permanently closed in line with our underage gambling prevention policy.

Parents and guardians who believe that a minor in their care has accessed or registered on mostpaly are encouraged to contact our support team immediately at [email protected]. We take such reports extremely seriously and will act promptly to investigate and resolve the matter.

Security Measures

mostpaly takes the security of your personal data seriously and implements a comprehensive set of technical and organisational measures designed to protect it against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• TLS/SSL Encryption: All data transmitted between your browser or device and mostpaly's servers is encrypted using Transport Layer Security (TLS) protocols. This applies to all platform interactions including login, payments, and account management.
• Data Encryption at Rest: Sensitive personal data stored on mostpaly's servers — including identity documents, financial records, and authentication credentials — is encrypted at rest using industry-standard algorithms.
• Access Controls: Access to personal data within the mostpaly organisation is restricted on a strict need-to-know basis. Only authorised personnel with documented business reasons are permitted to access identifiable player data. All internal access is logged and monitored.
• Regular Security Audits: mostpaly engages independent security professionals to conduct regular penetration testing and vulnerability assessments of the platform. Identified issues are prioritised and remediated in accordance with industry best practice.
• Incident Response: In the event of a personal data breach that poses a risk to affected players, mostpaly maintains a documented incident response procedure that includes timely notification to affected individuals and, where required, to relevant regulatory authorities.
• Employee Training: All mostpaly personnel who handle personal data receive regular training on data protection obligations, security best practices, and the procedures to follow in the event of a suspected breach.

Despite these measures, no online platform can guarantee absolute security. Players are encouraged to use strong, unique passwords for their mostpaly accounts and to enable any two-factor authentication features available on the platform. If you suspect your account has been compromised, contact our support team immediately.

Changes to This Privacy Policy

mostpaly reserves the right to update or amend this Privacy Policy at any time. Changes may be made to reflect updates in our data processing practices, new regulatory requirements, changes in the services we offer, or to improve the clarity and completeness of the Policy.

When material changes are made to this Policy, mostpaly will notify registered players via email to the address held on their account, and a prominent notice will be displayed on the Platform for a minimum of 14 days following the update. The "Effective Date" at the top of this document will be updated to reflect the date on which the revised Policy takes effect.

Your continued use of the mostpaly platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you must cease using the Platform and contact our support team to request account closure.

We encourage you to review this Policy periodically to stay informed about how mostpaly is protecting your personal data.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which mostpaly handles your personal data, please reach out to our dedicated support team. We are available 24 hours a day, 7 days a week, including Pakistani public holidays such as Pakistan Day, Independence Day, and Eid.

You can contact our Data Privacy team at: [email protected]

When submitting a privacy-related query, please include your registered account username and a clear description of your request. This helps our team locate your account records promptly and provide an accurate, complete response. We aim to acknowledge all privacy correspondence within 24 hours and to resolve substantive matters within 30 calendar days.

For data rights requests — such as access, rectification, erasure, or portability — please include the words "Data Rights Request" in the subject line of your email to ensure your message is routed to the appropriate team member without delay.