Privacy Policy

Introduction

This Privacy Policy ("Policy") is issued by 1eem ("1eem", "the Platform", "we", "us", "our") and applies to all personal data collected from users ("User", "Player", "you") who access or use the online betting and casino platform operated at https://1eem.cam (the "Website").

1eem is an English-language platform built for players in Pakistan. We take the privacy of our users seriously. This Policy explains in plain language what personal data we collect, why we collect it, how it is used, who it may be shared with, how long we keep it and what rights you have over it.

By registering an Account, depositing funds or otherwise using the 1eem Platform, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you should not use the Platform.

Definitions

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person — an individual who can be identified directly or indirectly, including by reference to a name, identification number, location data or one or more factors specific to that person.
• "Processing" means any operation performed on Personal Data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, combination, restriction, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For data collected through the Platform, 1eem acts as the Data Controller.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller, strictly in accordance with documented instructions.
• "KYC" means Know Your Customer — the identity-verification process applied to Players before withdrawal access is granted.
• "AML" means Anti-Money Laundering — regulatory obligations requiring the Platform to identify, assess and report suspicious financial activity.
• "Cookie" means a small text file stored on a User's device by the Platform's web server for the purposes of session management, analytics or user preference storage.
• "Sensitive Personal Data" means data that warrants heightened protection, including identity documents, financial account details and any data that could be used to facilitate identity fraud.

Data Controller

1eem acts as the Data Controller in respect of personal data collected directly through the Platform. As Data Controller, 1eem determines the purposes for which your data is processed and is responsible for ensuring that processing is conducted lawfully, fairly and transparently.

Where 1eem engages third-party service providers to process data on its behalf — such as payment processors, KYC verification providers or fraud-detection services — those parties act as Data Processors and are bound by contractual data-processing agreements that restrict their use of your data to the specific purposes for which it was shared.

Queries and requests relating to the processing of your personal data should be directed to the 1eem support team using the contact details set out in Section 17 of this Policy.

Data We Collect

1eem collects the following categories of personal data in connection with the operation of the Platform:

4.1 Registration Data

Collected when you create an Account:

• Full legal name
• Date of birth (for age-verification purposes)
• Email address
• Username and encrypted password
• Country of residence
• Contact telephone number (where provided)

4.2 Identity & KYC Verification Data

Collected when KYC is required prior to withdrawal or as part of AML obligations:

• Government-issued photo identity document (e.g., CNIC, passport, driving licence)
• Proof of address documentation (e.g., utility bill, bank statement)
• Proof of payment source documentation (e.g., bank statement, wallet transaction history)
• Selfie or live photograph for biometric identity-matching purposes where required

4.3 Financial Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method identifiers (e.g., last four digits of a card, mobile wallet number — never full card numbers)
• Transaction reference numbers
• Currency (PKR) and balance history

4.4 Betting & Gaming Activity Data

• Wagers placed, outcomes, stakes and returns
• Game and market selection history
• Bonus and promotional uptake records
• Responsible-gambling tool settings and activity logs

4.5 Technical & Device Data

• IP address
• Device type, operating system and browser version
• Session start/end times and duration
• Referral source and navigation paths within the Platform
• Cookie and tracking data (see Section 9)

4.6 Communications Data

• Support-ticket content and live-chat transcripts
• Email correspondence with the Platform
• Complaint and dispute records

How We Collect Your Data

Personal data is collected through the following means:

• Directly from you: Information you provide when registering, completing KYC, making deposits or withdrawals, contacting support, or setting responsible-gambling limits;
• Automatically: Technical and device data collected passively when you access or interact with the Platform, including IP address, session data and cookie-based analytics;
• From third-party KYC providers: Identity verification results and fraud-risk scores from licensed identity-verification service providers engaged by 1eem to fulfil its AML obligations;
• From payment processors: Transaction confirmation data and payment-method identifiers provided by third-party payment processors when you deposit or withdraw funds.

Lawful Basis for Processing

1eem processes Personal Data on one or more of the following lawful bases:

How We Use Your Personal Data

1eem uses the personal data it collects for the following purposes:

• Account creation and maintenance: To create and manage your registered Account, authenticate your identity at login and maintain your Account settings and preferences;
• KYC and AML compliance: To verify your identity, confirm your age, assess financial-crime risk and fulfil mandatory reporting obligations required by the operator's international gaming licence;
• Payment processing: To process deposit and withdrawal transactions, verify payment-method ownership and maintain a complete transaction history;
• Sports betting and gaming services: To enable wagering on sports, casino, live games and other markets available on the Platform, and to calculate and credit winnings;
• Responsible gambling: To monitor your activity for indicators of potential problem-gambling behaviour, apply and enforce self-imposed limits, and facilitate self-exclusion requests;
• Customer support: To respond to your queries, complaints and requests through live chat, email and other support channels;
• Fraud prevention and platform security: To detect, investigate and prevent fraudulent activity, multi-accounting, bonus abuse and other prohibited conduct;
• Platform analytics and improvement: To understand how the Platform is used, identify performance issues and develop improvements to the user experience;
• Marketing communications: To send promotional offers, bonuses and platform updates where you have consented to receive such communications. You may withdraw marketing consent at any time.

Data Sharing & Disclosure

1eem does not sell your personal data to unaffiliated third parties. Your data may be shared in the following limited circumstances:

• Service providers and Data Processors: Third parties engaged by 1eem to provide services integral to Platform operation — including KYC verification providers, payment processors, fraud-detection services, cloud infrastructure providers and customer-support platform providers. All Data Processors are bound by contractual data-processing agreements;
• Regulatory and legal authorities: Where disclosure is required by law, court order or mandatory reporting obligation — including Suspicious Transaction Reports filed with relevant authorities under AML legislation applicable to the operator's licence jurisdiction;
• Responsible-gambling organisations: Where required by licence conditions, Player activity data or self-exclusion records may be shared with responsible-gambling registries or organisations designated by the licence authority;
• Corporate transactions: In the event of a merger, acquisition, restructure or sale of the operating entity, Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent data-protection obligations;
• With your consent: In any other circumstances, where you have given clear, explicit consent to the specific sharing arrangement.

Cookies & Tracking Technologies

1eem uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled without impairing Platform functionality;
• Functional cookies: Enable the Platform to remember your preferences — such as language settings and responsible-gambling limit configurations — between sessions;
• Analytical/performance cookies: Used to collect anonymised data about how the Platform is used — page views, session duration, navigation paths and technical errors. This data helps 1eem improve the user experience;
• Fraud-detection cookies: Used to identify device characteristics for the purpose of detecting fraudulent activity, multi-accounting and unauthorised access attempts.

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality. Strictly necessary cookies cannot be declined as they are required for the Platform to operate.

International Data Transfers

As 1eem operates under an international gaming licence, your personal data may be processed and stored on servers located outside Pakistan. Where Personal Data is transferred to a jurisdiction that does not provide an equivalent level of data protection, 1eem will implement appropriate safeguards — such as contractual data-transfer mechanisms or equivalent protective arrangements — to ensure your data remains protected to a standard consistent with this Policy.

By using the Platform, you acknowledge that your Personal Data may be transferred to, processed in and stored in countries other than Pakistan, including the jurisdiction in which the operator's licence is held.

Data Retention

1eem retains Personal Data for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law and the operator's licence obligations.

At the end of the applicable retention period, Personal Data is securely deleted or anonymised. Where data must be retained beyond these periods due to an ongoing investigation, legal proceeding or regulatory inquiry, retention will continue until that matter is resolved.

Security Measures

1eem implements technical and organisational security measures proportionate to the sensitivity of the data processed. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the Platform is encrypted using industry-standard TLS/SSL encryption;
• Encryption at rest: Sensitive Personal Data — including identity documents and payment-method identifiers — is encrypted when stored on Platform infrastructure;
• Access controls: Personal Data is accessible only to authorised personnel on a need-to-know basis. Access is logged and reviewed regularly;
• Password security: Passwords are stored using one-way cryptographic hashing. 1eem does not store plaintext passwords and cannot retrieve your password — only reset it;
• Two-factor authentication (2FA): Players are encouraged to enable 2FA to add a second layer of protection to their Accounts;
• Fraud detection systems: Automated and manual monitoring for unusual account activity, suspicious transactions and potential security incidents;
• Incident response: Documented procedures for identifying, containing and responding to data-security incidents, including notification obligations where applicable.

Your Rights Regarding Personal Data

Subject to applicable law and the Platform's regulatory obligations, you have the following rights in relation to your Personal Data held by 1eem. Requests should be submitted to the support team using the contact details in Section 17.

Children & Minors

The 1eem Platform is strictly intended for adults. You must be at least 18 years of age, or the higher minimum age required by the operator's licence jurisdiction, to register an Account and use the Platform.

1eem does not knowingly collect Personal Data from individuals under the applicable minimum age. If we become aware that Personal Data has been collected from a minor, we will close the relevant Account, void all associated wagers and delete the data promptly, subject to any mandatory regulatory-retention obligations.

If you believe that a minor may have registered an Account on the Platform, please contact support immediately. This age requirement does not constitute a representation that gambling is lawful in Pakistan at any age.

Pakistan-Specific Privacy Context

1eem operates under an international gaming licence. It is not licensed, regulated or supervised by any Pakistani governmental authority — including the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan (SBP), the Federal Board of Revenue (FBR) or any provincial body. Accordingly, Pakistani data-protection legislation does not govern the primary data-processing activities of this Platform.

Pakistani users interact with the Platform on the basis that they have assessed and accepted the applicable legal and privacy context in their jurisdiction. The Platform makes no representation as to the legal status of online gambling or international data transfers under Pakistani law. If you have concerns about the applicability of Pakistani privacy laws to your use of this Platform, you should seek independent legal advice.

Payment references to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are for contextual familiarity only. These providers are independent entities with their own privacy practices. 1eem does not have access to your data held by those providers beyond what is necessary to confirm payment transactions.

Changes to This Privacy Policy

1eem may update this Privacy Policy from time to time to reflect changes in our data-processing practices, legal obligations or Platform features. When material changes are made, the revised Policy will be published on this page with an updated "Last Updated" date.

Where changes are material — such as the introduction of a new category of data processing or a new third-party sharing arrangement — registered Users will be notified via email or a prominent notice on the Platform where reasonably practicable.

Continued use of the Platform following the publication of a revised Policy constitutes acceptance of the updated terms. If you do not agree with a revised Policy, you should cease using the Platform and contact support to request Account closure.

We recommend reviewing this page periodically. The version number and "Last Updated" date at the top of this document indicate when the most recent revision was made.

Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the processing of your Personal Data, please contact the 1eem data team through the following channel:

• Support Email: [email protected] (plain text — not a clickable link)
• Support Hours: 24 hours a day, 7 days a week
• Languages: English and Urdu
• Subject line for data requests: Please use "Data Subject Request — [your Account username]" to ensure your query reaches the correct team promptly

We aim to acknowledge all data-related requests within five business days and to respond substantively within a reasonable period, consistent with the complexity of the request and any applicable legal timelines.