1
Who We Are
fafa191 is an online gaming and sports betting platform operating at fafa191.wine, designed specifically for players in Pakistan. When this privacy policy refers to "fafa191", "we", "us" or "our", it refers to the operator of the fafa191 platform and all services accessible through it.
fafa191 acts as the data controller for the personal information collected through the platform. This means we determine the purposes and the means by which your personal data is processed. If you need to contact the data controller directly, please use the contact information in Section 13 of this policy.
This policy covers all services offered on fafa191 including sports betting, live casino games (baccarat, roulette), Ludo games, VIP Club, Refer a Friend programme, and all customer support interactions.
2
What Personal Data We Collect
fafa191 collects personal data across several categories. The following table summarises the main types of information collected and the context in which they are gathered:
| Category |
Examples |
When Collected |
| Identity | Full name, date of birth, CNIC or passport number | Registration & KYC verification |
| Contact | Mobile number, email address, city/province | Registration |
| Financial | Easypaisa/JazzCash wallet numbers, bank account details, transaction history | Deposits & withdrawals |
| Account Activity | Bet history, game rounds, session durations, bonus usage | Ongoing platform use |
| Technical | IP address, device type, browser, operating system | Each platform visit |
| Communications | Live chat transcripts, email correspondence, support tickets | When contacting support |
| Verification | Photos of CNIC, selfie for liveness check | KYC process on request |
fafa191 does not collect sensitive categories of personal data beyond what is required for identity verification (i.e., CNIC details). We do not collect information about ethnicity, religion, health conditions or political opinions.
3
How We Collect Your Data
fafa191 collects personal data through the following channels:
- Direct submission: Information you provide when creating your account, completing KYC verification, making a deposit or withdrawal, or contacting customer support.
- Automated technical collection: When you visit fafa191, our servers automatically log your IP address, the pages you visit, the device and browser you are using, and session duration. This happens for all visitors whether or not they are logged in.
- Cookies and tracking technologies: fafa191 uses cookies and similar technologies to maintain session state (keeping you logged in), remember preferences and measure how the platform is used. Full details are in Section 7.
- Payment processors: When you make a deposit via Easypaisa, JazzCash, NayaPay, SadaPay or bank transfer, the payment processor confirms the transaction to fafa191 along with the necessary reference information. fafa191 does not store full card numbers or wallet PINs — these remain with the payment processor.
- Third-party identity verification: fafa191 may use a third-party KYC provider to verify identity documents. That provider processes your document images and returns a verification result to fafa191. The provider is contractually bound to use your data only for this purpose.
4
Why We Use Your Data
fafa191 uses your personal data only for the following clearly defined purposes:
- Account management: Creating, maintaining and securing your fafa191 account. This includes login authentication, OTP verification, password resets and account settings management.
- Processing transactions: Handling deposits, withdrawals, bet settlements and bonus credits. Accurate payment processing requires your payment method details and transaction history.
- Identity and age verification: Confirming that you are who you say you are, that you are 18 or over, and that your account is not being used fraudulently. This is a legal obligation for gambling operators.
- Anti-fraud and security monitoring: Detecting and preventing fraudulent activity, money laundering, account takeovers and bonus abuse. fafa191 uses automated systems and manual reviews for this purpose.
- Customer support: Responding to your queries, resolving disputes and handling complaints. Support agents access your account data to provide accurate, relevant assistance.
- Platform improvement: Analysing how players use fafa191 to improve game performance, navigation, loading times and the overall experience. This analysis is conducted on aggregated or anonymised data wherever possible.
- Regulatory compliance: Meeting our obligations under applicable laws including anti-money-laundering regulations. This may require retaining certain records for defined periods.
- Marketing communications: Sending promotional offers, bonus notifications and platform updates to players who have opted in to receive them. You can opt out at any time.
- Responsible gaming: Monitoring account activity for indicators of problem gambling and making responsible gaming tools available when relevant patterns are detected.
fafa191 does not use your data to make automated decisions that have significant legal or similar effects on you without human review. Risk assessments that affect account access are reviewed by our compliance team, not left to automated systems alone.
5
Legal Basis for Processing
fafa191 processes your personal data under the following legal bases depending on the purpose:
- Contractual necessity: Processing required to provide the services you have signed up for — account management, bet settlement, payment processing. Without this processing, the platform cannot function for you.
- Legal obligation: Processing required to comply with applicable laws — particularly anti-money-laundering, age verification and financial record-keeping requirements.
- Legitimate interests: Processing for fraud prevention, security monitoring and platform improvement, where our interests do not override your privacy rights.
- Consent: Processing for marketing communications, which you can withdraw at any time without it affecting your account or any other service.
6
Who We Share Your Data With
fafa191 does not sell or share your personal data with third parties for their own commercial purposes. Data is shared in limited circumstances only, as described below:
- Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay and banking partners receive the minimum information needed to process your deposit or withdrawal. These providers are bound by their own privacy obligations and contractual terms with fafa191.
- KYC / identity verification providers: A third-party verification service processes your identity documents to confirm your identity and age. They act only on fafa191's instructions and are contractually prohibited from using your data for any other purpose.
- Regulatory and law enforcement authorities: fafa191 may be required to disclose information to relevant authorities in response to a lawful request, court order or regulatory investigation. We will not disclose more than is required by the specific legal obligation.
- Technical infrastructure providers: Cloud hosting and server providers that store platform data may have access to encrypted data as part of their service. They operate under strict confidentiality agreements and have no rights to access or use player data beyond technical hosting.
- Fraud prevention networks: fafa191 may share anonymised risk signals with fraud detection networks to protect all players on the platform. No identifiable personal data is shared in this context.
Important: fafa191 will never share your personal data — particularly your CNIC, payment details or betting history — with advertisers, marketing companies or any commercial third party without your explicit consent.
7
Cookies and Tracking Technologies
fafa191 uses cookies and similar technologies when you use the platform. These are small data files stored in your browser that help the platform function correctly and remember your preferences. The types of cookies used on fafa191 are:
- Essential cookies: Required for the platform to function. These keep you logged in during a session, maintain your bet slip state and handle security tokens. You cannot opt out of essential cookies without losing platform functionality.
- Preference cookies: Remember your settings such as odds format (decimal, fractional or American) and language preference so you do not have to set them on every visit.
- Analytics cookies: Help fafa191 understand how players navigate the platform — which pages are most visited, where players drop off, and how game interfaces perform on different devices. This data is aggregated and used to improve the platform.
- Session tracking: Track the duration and activity of your current session for responsible gaming monitoring and fraud detection purposes.
You can manage cookie preferences through your browser settings. Deleting cookies will log you out of any active session and may reset your saved preferences. fafa191 does not use third-party advertising cookies.
8
How Long We Keep Your Data
fafa191 retains personal data only for as long as it is necessary for the purposes described in this policy or as required by applicable law. The general retention periods are:
- Active accounts: All account and transaction data is retained for the duration of your account's active status plus a minimum of five years after account closure, in compliance with anti-money-laundering regulations.
- KYC documents: Identity verification documents are retained for a minimum of five years after the end of the business relationship, as required by financial regulations.
- Transaction records: All deposit, withdrawal and bet records are retained for at least five years for regulatory compliance purposes.
- Support communications: Live chat transcripts and email correspondence are retained for a minimum of two years to support dispute resolution and quality assurance.
- Technical logs: Server logs including IP addresses are retained for up to 90 days for security and fraud investigation purposes, then deleted or anonymised.
- Marketing data: If you opt out of marketing communications, your opt-out preference is retained indefinitely to ensure you are not contacted again.
When data is no longer required to be retained, it is securely deleted or anonymised so it can no longer be associated with you.
9
How We Secure Your Data
fafa191 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure or destruction. These include:
- All data transmitted between your device and fafa191 servers is encrypted using TLS (Transport Layer Security). The padlock icon in your browser confirms this encryption is active.
- Passwords are hashed using a strong one-way algorithm. fafa191 cannot retrieve your password in plain text — only reset it.
- Sensitive fields in our database, including CNIC references and payment identifiers, are encrypted at rest.
- OTP (one-time password) verification is required for login and sensitive account actions including withdrawals, giving your account a second layer of protection beyond the password.
- Internal systems that access player data require staff authentication and all access events are logged.
- Our infrastructure is regularly assessed for vulnerabilities. Identified issues are prioritised and addressed promptly.
Data breach notification: In the unlikely event of a data breach that affects your personal information, fafa191 will notify affected players and relevant authorities in accordance with applicable regulations, as soon as is reasonably practicable.
10
Your Privacy Rights
As a registered player on fafa191, you have the following rights regarding your personal data. To exercise any of these rights, contact our support team through live chat or at support@fafa191.wine.
Right of Access
Request a copy of all personal data fafa191 holds about you. We will provide this within 30 days of your request.
Right to Rectification
Request correction of any inaccurate personal data we hold. If your registered mobile or email has changed, update it through your account settings or contact support.
Right to Erasure
Request deletion of your personal data. Note that some data must be retained under legal and regulatory obligations even after account closure.
Right to Object
Object to the processing of your data for marketing purposes at any time. You can also object to processing based on legitimate interests where your situation warrants it.
Right to Portability
Request your personal data in a structured, machine-readable format where technically feasible, so it can be transferred to another service if you wish.
Right to Restrict Processing
Request that we limit how we process your data in certain circumstances — for example, while a dispute about accuracy is being resolved.
fafa191 will acknowledge all privacy rights requests within 5 business days and respond substantively within 30 days. Complex requests may take longer, in which case we will keep you informed of the timeline.
11
Children and Minors
fafa191 is strictly an adult platform for users aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that an account belongs to a minor, it will be closed immediately and any associated data will be handled in accordance with regulatory requirements.
If you believe a minor has registered on fafa191, please contact our support team immediately through live chat or at support@fafa191.wine. We take these reports seriously and will investigate promptly.
Parents and guardians are encouraged to use device-level parental controls and to speak openly with young people about responsible online behaviour and the risks of gambling.
12
Changes to This Privacy Policy
fafa191 may update this Privacy Policy from time to time to reflect changes in how we operate, changes to applicable laws, or improvements to our practices. The "Last Updated" date at the top of this page reflects the most recent revision.
When material changes are made to this policy — changes that significantly affect how your data is processed — fafa191 will notify registered players by email or in-app notification at least 7 days before the changes take effect. Minor clarifications may be made without advance notice.
Continued use of fafa191 following a policy update constitutes your acceptance of the revised policy. If you do not agree with changes to the Privacy Policy, you should close your account and withdraw any remaining balance before the changes take effect.
13
Contact Us About Privacy
If you have any questions about this Privacy Policy, want to exercise any of your data rights, or wish to raise a concern about how fafa191 handles your personal information, please get in touch through any of the following channels:
- Live Chat: Available 24/7 through the fafa191 platform — the fastest way to get a response for account-related privacy requests
- Email: support@fafa191.wine — for formal privacy requests, data access requests or complaints
Privacy requests sent by email will receive an acknowledgement within 2 business days. The substantive response to data access or deletion requests will follow within 30 days. If your request is particularly complex, we will notify you within the initial 30-day window and provide an updated timeline.
fafa191 genuinely values your trust and treats privacy requests with the same seriousness as any other player concern. We will not penalise you in any way for exercising your data rights — your account status and service quality are completely unaffected by submitting a privacy request.