Privacy Policy — 88fs Platform

This Privacy Policy ("Policy") describes how 88fs ("Platform", "we", "us", "our") collects, processes, uses, stores, shares and protects personal data about individuals ("you", "your", "User") who access or use the 88fs online betting and casino information platform, accessible at https://88fs.cam and any associated applications or services.

88fs is an English-language platform oriented towards the Pakistan market, serving users across cities including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. By accessing the Platform, creating an Account or submitting personal information to 88fs, you acknowledge that you have read, understood and agree to the data practices described in this Policy.

If you do not agree with the terms of this Policy, you must not access or use the Platform. This Policy should be read alongside the 88fs Terms & Conditions, which govern your use of the Platform more generally.

The following terms have specific meanings within this Policy:

The categories of Personal Data we collect vary depending on how you interact with the Platform. The table below summarises the primary data categories and examples:

88fs does not intentionally collect Sensitive Data beyond what is strictly necessary for KYC compliance and responsible gambling obligations. You should avoid including unnecessary sensitive information in support communications.

We collect Personal Data through the following channels:

4.1 Direct Submission

Information you provide directly when registering an Account, completing KYC verification, making deposits or withdrawals, contacting support or submitting feedback. This includes form fields on the Platform where you enter your name, date of birth, email address, residential address and payment details.

4.2 Automated Collection

Technical data collected automatically when you access the Platform, including IP address, device identifiers, session data and browser information. This data is collected through server logs, cookies and similar tracking technologies as described in Section 10.

4.3 Third Parties

We may receive Personal Data from third-party service providers engaged to support Platform operations, including:

• KYC and identity verification service providers who process identity documents and return verification results.
• Payment processing partners who provide transaction confirmation data — note that 88fs references Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah only as payment infrastructure familiar to Pakistani users; these references are contextual only and do not imply data-sharing partnerships or endorsements.
• Fraud prevention and AML screening providers who cross-reference data against relevant risk databases.
• Analytics platforms that provide aggregated performance and user-behaviour data.

88fs processes Personal Data on the following legal bases, consistent with applicable data protection principles:

• Contractual Necessity: Processing required to perform the contract between you and 88fs — including account management, bet settlement, payment processing and customer support.
• Legitimate Interests: Processing where 88fs has a legitimate business interest that is not overridden by your rights — including fraud detection, platform security, responsible gambling monitoring, and internal analytics.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements — including KYC/AML obligations, self-exclusion compliance, and responses to lawful authority requests.
• Consent: Processing for which we have obtained your specific, informed and freely given consent — such as sending optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

88fs uses your Personal Data for the following purposes:

• Creating, maintaining and administering your Account on the Platform.
• Processing deposits, withdrawals and account balance adjustments.
• Verifying your identity and age as part of the KYC process.
• Monitoring betting and gaming activity to fulfil responsible gambling obligations, including identifying patterns that may indicate problem gambling behaviour.
• Detecting, investigating and preventing fraud, money laundering, cheating and other prohibited conduct.
• Responding to support requests, complaints and account queries — including support delivered in English and, on request, Urdu.
• Sending account-related transactional communications, including deposit confirmations, withdrawal notifications and security alerts.
• Sending promotional communications where you have consented to receive them — you may opt out at any time.
• Complying with applicable legal, regulatory and reporting obligations.
• Improving Platform performance, user experience and security through aggregated analytics.

88fs does not sell your Personal Data. We may share your data with the following categories of recipients where necessary and proportionate:

7.1 Service Providers and Data Processors

Third-party providers engaged to deliver services on behalf of 88fs, including KYC verification platforms, payment processing technology partners, cloud hosting infrastructure providers, fraud detection services and customer support tools. All such providers are required to handle data in a manner consistent with this Policy and applicable data protection standards.

7.2 Legal and Regulatory Authorities

Where required by applicable law, court order, regulatory obligation or governmental authority, 88fs may disclose Personal Data to the relevant authority. We will notify you of such requests where legally permitted to do so.

7.3 Responsible Gambling Schemes

Where 88fs is enrolled in a third-party self-exclusion or responsible gambling scheme, your self-exclusion status may be shared with that scheme's administrator and with other enrolled operators, strictly for the purpose of enforcing your exclusion.

7.4 Corporate Transactions

In the event of a merger, acquisition, restructuring or sale of assets involving 88fs, Personal Data held by the Platform may be transferred to the acquiring entity, subject to equivalent data protection commitments. You will be notified of any such transfer in advance where possible.

88fs retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law or regulatory obligation. The following general retention principles apply:

• Active Account Data: Retained for the duration of your Account's active status and for a defined period following Account closure, as required by AML, KYC and gambling compliance obligations.
• Transaction Records: Financial transaction data, including deposits and withdrawals, is retained for a minimum period required by applicable financial regulations. This period is typically five to seven years from the date of the transaction.
• Support Communications: Live chat transcripts and email correspondence are retained for a period sufficient to resolve any open disputes and for quality-assurance purposes, typically one to three years.
• Self-Exclusion Records: Records of self-exclusion requests are retained for the full duration of the exclusion period plus a reasonable period thereafter to prevent re-registration.
• Technical Logs: Server and session logs are retained for a short period sufficient for security monitoring and fraud investigation, typically ninety days, unless a longer period is required by an ongoing investigation.

When data is no longer required for the purposes described in this Policy, it is securely deleted or anonymised in a manner that prevents identification of the data subject.

Subject to applicable law and certain conditions, you have the following rights in relation to your Personal Data held by 88fs:

To exercise any of these rights, please contact 88fs via the support channels described in Section 15. We will respond to all verifiable requests within a reasonable timeframe, typically within 30 days. We may need to verify your identity before processing any request relating to your Personal Data.

88fs uses cookies and similar technologies (collectively "Cookies") on the Platform. Cookies are small text files stored on your device that help us deliver and improve Platform services.

10.1 Categories of Cookies Used

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, CSRF protection tokens and load-balancing cookies. These cannot be disabled without breaking Platform functionality.
• Functional Cookies: Store your preferences such as language settings, display preferences and notification preferences to improve your experience on return visits.
• Analytics Cookies: Collect aggregated information about how users interact with the Platform — page views, click paths, session durations and error occurrences — to help us improve performance. No personally identifiable information is transmitted to analytics providers in identifiable form.
• Security & Fraud Prevention Cookies: Assist in identifying unusual or potentially fraudulent activity patterns, including device fingerprinting data used to detect multi-accounting or bot activity.

10.2 Managing Cookie Preferences

You can control and delete cookies through your browser settings. Most browsers allow you to view, block or delete cookies. Please refer to your browser's help documentation for guidance. Blocking strictly necessary cookies will impair or prevent access to the Platform.

88fs implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. Our security measures include, but are not limited to:

• Encryption of data in transit using TLS (Transport Layer Security) protocols.
• Encryption of stored sensitive data including identity document data and financial information.
• Role-based access controls ensuring that only authorised personnel can access Personal Data relevant to their function.
• Regular security assessments and penetration testing of Platform infrastructure.
• Monitoring of access logs for anomalous activity indicative of unauthorised access attempts.
• Incident response procedures for identifying, containing and reporting data breaches where required.

While 88fs takes reasonable steps to protect your data, no internet-based transmission or storage system is perfectly secure. You are responsible for maintaining the confidentiality of your Account credentials. If you believe your Account has been compromised, contact support immediately.

The 88fs Platform is strictly restricted to users who are 18 years of age or older, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect, use or retain Personal Data from minors.

If during the KYC process or through other means 88fs identifies or suspects that a User is under the minimum eligible age, the Account will be suspended immediately pending investigation. Any winnings accrued during the period of suspected underage activity may be withheld. Where it is confirmed that a minor has registered, all data held will be handled in accordance with applicable child data protection requirements.

If a parent or guardian believes that their child has provided Personal Data to 88fs, they should contact us immediately via the support channels in Section 15 so that appropriate action can be taken.

88fs may transfer your Personal Data to, or process it in, countries outside of Pakistan where our service providers, hosting infrastructure or processing systems are located. Such transfers may be to countries that have different data protection standards from those in Pakistan.

Where Personal Data is transferred internationally, 88fs takes reasonable steps to ensure that the transfer is subject to appropriate safeguards, including contractual data protection obligations with the receiving party. However, you should be aware that international data transfer regulation varies across jurisdictions and absolute equivalence to local standards cannot always be guaranteed.

By using the 88fs Platform, you acknowledge that your Personal Data may be processed internationally as described in this section.

88fs reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, Platform operations, data processing practices or regulatory requirements. Where a material change is made, we will use reasonable endeavours to notify registered Users via the email address on file or through a prominent notice on the Platform prior to the change taking effect.

The "Last Reviewed" date at the top of this Policy indicates when it was most recently updated. We recommend that you review this Policy periodically. Your continued use of the Platform following notification of any amendments constitutes acceptance of the revised Policy.

If you have any questions, concerns or complaints regarding this Privacy Policy, the way in which your Personal Data is being handled, or if you wish to exercise any of your data rights as described in Section 9, please contact the 88fs support team through the following channels:

We aim to resolve all privacy-related queries promptly and transparently. If you are not satisfied with our response to a complaint, you may have the right to escalate the matter to the appropriate data protection authority in your jurisdiction. 88fs does not operate under the oversight of any Pakistani regulatory authority in respect of data protection, and this Policy does not constitute a representation that it satisfies any specific national data protection legislation.