Privacy Policy — 88ef9

88ef9 ("we", "us", "our", "the Platform") operates the online betting and live casino service accessible at https://88ef9.cam. We are committed to protecting and respecting the privacy of every individual who visits or uses the Platform ("you", "your", "User").

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by 88ef9. It covers our practices relating to data collection, storage, use, disclosure, retention and security, as well as the rights you hold in relation to your personal information.

This policy should be read alongside our Terms & Conditions and our Responsible Gambling page, both of which form part of the overall framework governing your use of 88ef9.

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

88ef9 collects Personal Data through several channels depending on how you interact with the Platform. The categories of data we may collect include:

Data you provide directly:

• Registration data: Full legal name, date of birth, residential address (including city — for example, Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar), email address, mobile phone number and chosen username.
• KYC documents: Government-issued identity documents (such as CNIC/NICOP, passport or driving licence), proof of address, and any additional documentation we may request as part of our verification obligations.
• Payment information: Transaction records, payment method references and amounts. We do not store full card numbers or mobile wallet PINs. Payment references to services familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — are used as contextual identifiers only and do not imply any endorsement or affiliation.
• Support communications: The content of live chat conversations, emails and any supporting documentation you submit when contacting [email protected].
• Responsible gambling self-assessments: Data you enter when using deposit limit, loss limit, cooling-off or self-exclusion tools within your Account dashboard.

Data collected automatically:

• Technical data: IP address, browser type and version, operating system, device type and screen resolution.
• Usage data: Pages visited, features accessed, bet history, game session durations, login timestamps and navigation paths within the Platform.
• Cookie and tracking data: Session tokens, preference settings and analytics identifiers. See Section 7 for full cookie details.
• Geolocation data: Country and approximate region-level location derived from your IP address, used to assess jurisdictional access restrictions.

88ef9 uses the Personal Data we collect for the following purposes:

We will not use your Personal Data for any purpose that is incompatible with those stated above without first providing notice and, where required, obtaining your consent.

Where applicable data protection law requires a lawful basis for Processing, 88ef9 relies on one or more of the following:

• Contract performance: Processing is necessary to perform the contract between you and 88ef9 — primarily the operation of your Account, execution of bets and processing of payments.
• Legal obligation: Processing is necessary to comply with applicable legal and regulatory requirements, including KYC, AML and licensing obligations imposed on the Platform's operating jurisdiction.
• Legitimate interests: Processing is necessary for 88ef9's legitimate business interests — including fraud prevention, platform security, responsible gambling monitoring and service analytics — provided those interests are not overridden by your rights and freedoms.
• Consent: Where Processing is based on your consent (for example, marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Where we rely on legitimate interests as our lawful basis, we carry out a balancing assessment to ensure that our interests do not disproportionately override your privacy rights. You may request details of such assessments by contacting us at [email protected].

88ef9 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. We may share your data only in the following limited circumstances:

• Service providers and Data Processors: We engage carefully selected third-party vendors to assist with operating the Platform — including cloud hosting providers, payment processing infrastructure, KYC verification services, fraud detection systems and customer support tools. These parties process data solely under our documented instructions and are bound by contractual confidentiality obligations.
• Regulatory and licensing authorities: We may be required to disclose data to the regulatory body or licensing authority under whose jurisdiction 88ef9 operates, as a condition of maintaining our operating licence.
• Law enforcement and legal processes: Where we receive a lawful request from a government authority, court order or law enforcement agency, we may be required to disclose relevant Personal Data. We will seek to notify you of such requests where legally permissible.
• Fraud and AML investigations: We may share data with financial intelligence units, partner platforms or other operators where we are legally required or where it is necessary to prevent serious financial crime.
• Business transfers: In the event that 88ef9 is acquired, merged with or its assets are transferred to another entity, your Personal Data may form part of the transferred assets. We will notify affected Users of any such change in ownership and the applicable privacy arrangements.
• Responsible gambling partners: With your consent, or where required under our licensing obligations, we may share limited data with responsible gambling support organisations to facilitate access to help resources.

88ef9 uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are as follows:

You can manage your cookie preferences at any time through your browser settings or via the cookie preference centre available within the Platform. Disabling strictly necessary cookies will affect your ability to use core Platform features including login and bet placement.

We do not use third-party advertising networks or cross-site tracking technologies to serve behavioural advertising to users outside the 88ef9 Platform.

88ef9 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, accounting and reporting requirements. The following general retention periods apply:

• Active Account data: Retained for the duration of your Account's active status plus a minimum of five (5) years following Account closure, to meet AML and licensing audit obligations.
• KYC documentation: Retained for a minimum of five (5) years from the date of submission, or longer where required by applicable regulatory requirements in the operator's licensing jurisdiction.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction for financial audit and AML compliance purposes.
• Support communications: Retained for three (3) years from the date of the last interaction, or longer if the communication relates to an unresolved dispute or regulatory inquiry.
• Marketing consent records: Retained for the duration of the marketing relationship plus two (2) years, as evidence of valid consent.
• Analytics data: Aggregated and anonymised after twenty-six (26) months, after which it is no longer linked to individual User profiles.

When Personal Data is no longer required under any applicable retention obligation, 88ef9 will securely delete or irreversibly anonymise it. Deletion is carried out using industry-standard methods appropriate to the data's sensitivity and storage medium.

88ef9 implements a range of technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• Encryption in transit: All data transmitted between your device and the Platform is encrypted using TLS (Transport Layer Security) protocols.
• Encryption at rest: Sensitive Personal Data stored on our servers — including KYC documents and financial records — is encrypted at rest using industry-standard algorithms.
• Access controls: Access to Personal Data is restricted on a strict need-to-know basis. Staff with access to sensitive data undergo background screening and regular privacy training.
• Secure payment processing: Payment transaction data is handled through PCI-DSS compliant infrastructure. 88ef9 does not store full card numbers, CVV codes or mobile wallet PINs on its own systems.
• Penetration testing and security audits: The Platform undergoes periodic security assessments by qualified third-party testers to identify and remediate vulnerabilities.
• Incident response: 88ef9 maintains a documented data breach response procedure. In the event of a breach that poses a material risk to affected individuals, we will notify relevant parties in accordance with applicable regulatory requirements.

While we employ robust security practices, no method of electronic transmission or storage is completely immune to risk. You are responsible for keeping your Account credentials confidential and for notifying us immediately at [email protected] if you suspect any unauthorised access to your Account.

Depending on applicable data protection legislation, you may hold some or all of the following rights in relation to your Personal Data. 88ef9 will respond to verified requests within a reasonable timeframe and in accordance with applicable law:

To exercise any of these rights, please contact us in writing via live chat or at [email protected]. We may need to verify your identity before actioning a request. We will not charge a fee for handling rights requests in normal circumstances. Where requests are manifestly unfounded or excessive, we reserve the right to apply a reasonable administrative charge or to decline the request, with explanation.

88ef9 is strictly an adults-only platform. The Platform is not directed at, and we do not knowingly collect Personal Data from, any individual under the age of 18 — or the higher minimum age required by the operator and/or its licensing jurisdiction, whichever is greater.

Age verification is a mandatory step in our KYC process. Where we have reason to believe that a registered User is under the minimum age, we will:

• Immediately suspend the Account pending investigation.
• Decline to process any pending withdrawal requests until age is confirmed.
• Permanently close the Account and return any real-money balance (net of any promotional credits) if underage access is confirmed.
• Delete any Personal Data associated with the underage Account, except where retention is required for compliance or regulatory reporting purposes.

If you are a parent or guardian and believe a minor under your care has created an Account or accessed the Platform, please contact us immediately at [email protected] or via live chat. We will investigate and action all such reports promptly. We also encourage parents and guardians to use parental control software to restrict access to online gambling platforms on shared or children's devices.

88ef9 operates globally and may engage service providers located in jurisdictions outside Pakistan. As a result, your Personal Data may be transferred to, stored in, or processed in countries other than Pakistan. These countries may have data protection laws that differ from those in your home jurisdiction.

Where such transfers occur, 88ef9 takes steps to ensure that appropriate safeguards are in place to protect your Personal Data, which may include:

• Standard contractual clauses or data processing agreements with recipient entities that impose equivalent data protection obligations.
• Transfers only to jurisdictions that have been assessed as providing an adequate level of protection for Personal Data.
• Internal policies and technical controls that restrict how transferred data may be accessed or used by recipient entities.

By using the 88ef9 Platform, you acknowledge that your Personal Data may be transferred internationally in the manner described above. You may request further information about our cross-border transfer safeguards by contacting [email protected].

88ef9 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the scope of the Platform's services. When material changes are made, we will take reasonable steps to notify you — which may include a notice on the Platform homepage, an in-platform notification, or an email to the address registered on your Account.

The "Last updated" date at the top of this page reflects when the current version of this Privacy Policy came into effect. We encourage you to review this page periodically to stay informed about how we handle your Personal Data.

Your continued use of the Platform following publication of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with the updated policy, you must stop using the Platform and may request Account closure in accordance with our Terms & Conditions.

If you have any questions, concerns or requests relating to this Privacy Policy or the way 88ef9 handles your Personal Data, please reach out through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week directly on the Platform. Live chat is the fastest route for urgent matters including suspected data breaches or unauthorised account access.
• Email: [email protected] — for formal data subject requests, privacy complaints and non-urgent queries. Support agents can assist in English and Urdu. Please include your registered username and a clear description of your request.

We aim to acknowledge all privacy-related correspondence within 48 hours and to resolve the majority of requests within 30 days, or within any shorter period required by applicable law. For complex requests — particularly those involving large volumes of data or third-party coordination — we will inform you if additional time is required.

Formal complaints about our data handling practices should be submitted in writing via email. If you remain unsatisfied with our response, you may be entitled to escalate your complaint to the relevant supervisory authority in the jurisdiction where you are located or where 88ef9 is licensed to operate.