Privacy Policy — 88ef1

This Privacy Policy ("Policy") is published by 88ef1 ("Operator", "Platform", "we", "us", "our") and governs the collection, processing, storage, use and disclosure of personal data relating to individuals ("User", "Player", "you") who access or use the 88ef1 online betting and gaming service at 88ef1.cam and any associated features or services (collectively, the "Service").

88ef1 is committed to handling personal data responsibly, transparently and in accordance with applicable data protection standards. We recognise that our user base spans major Pakistani cities — including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — and that protecting personal information is fundamental to the trust players place in our platform.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which contain additional provisions relevant to how we handle your information.

The following terms carry the meanings set out below throughout this Policy:

88ef1 collects personal data through multiple touchpoints. The categories of data we collect, and the circumstances in which we collect them, are set out below.

We do not collect payment card numbers directly. Any payment card data entered via the cashier is processed by certified payment service providers operating under applicable payment security standards. Our systems only receive transaction confirmation and reference data.

88ef1 processes personal data for the following purposes:

• Account Management: To create, maintain, authenticate and administer your Account, including processing login credentials and security settings.
• KYC & Identity Verification: To verify your identity and age in compliance with the Platform's KYC obligations before enabling withdrawals or higher-tier account functions.
• Transaction Processing: To process deposits, withdrawals and bonus credits denominated in PKR, and to maintain accurate Account balance records.
• Service Delivery: To provide the full range of betting, gaming, live dealer and sports wagering services available on the Platform, including PSL and cricket markets.
• Customer Support: To respond to enquiries, resolve complaints and provide technical assistance via live chat, email or help centre.
• Fraud Prevention & AML: To detect, investigate and prevent fraudulent activity, money laundering, collusion and other prohibited conduct in accordance with AML obligations.
• Responsible Gambling: To monitor gaming activity for signs of problem gambling and to implement player-requested limits, cooling-off periods or self-exclusion orders.
• Legal Compliance: To comply with applicable laws, regulatory requirements, court orders or lawful requests from competent authorities.
• Platform Improvement: To analyse usage patterns, identify technical issues and develop new features that improve the player experience.
• Marketing Communications: To send promotional offers, bonus notifications and platform updates to Users who have opted in to receive such communications.

Where applicable data protection law requires a legal basis for processing personal data, 88ef1 relies on one or more of the following grounds:

• Contractual Necessity: Processing required to perform the contract between you and the Operator (i.e., operating your Account, processing transactions, delivering the Service).
• Legal Obligation: Processing required to comply with applicable law, including KYC, AML and responsible gambling obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, service improvement and direct marketing to existing users, balanced against your privacy interests.
• Consent: Where you have given explicit consent, such as opting in to marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

88ef1 does not sell personal data to third parties. We may share personal data with carefully selected third parties in the following circumstances:

• KYC/Identity Verification Providers: Specialist third-party services that verify identity documents, perform liveness checks and screen against sanctions lists.
• Payment Service Providers: Entities that process financial transactions on our behalf. These providers are independently certified and operate under their own data security standards.
• Game Software Providers: Certified game studios and RNG audit firms whose software powers the casino, slots and live dealer sections of the Platform.
• Fraud & AML Screening Services: Third-party tools that assist in detecting suspicious activity, match-fixing patterns and money laundering indicators.
• Cloud Infrastructure & IT Service Providers: Hosting, database and security vendors that support Platform operations under data processing agreements.
• Regulatory & Law Enforcement Authorities: Where disclosure is required by law, court order or formal regulatory request from a competent authority.
• Professional Advisers: Legal, audit and financial advisers where necessary for the Operator's business operations, subject to professional confidentiality obligations.

All financial transactions on the Platform are processed in Pakistani Rupees (PKR) where PKR is the designated Account currency. The Platform may reference familiar Pakistani payment services — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — as contextual payment references within the cashier interface.

Transaction data — including deposit amounts, withdrawal requests, balance history and payment method type references — is retained as required for AML compliance, regulatory obligations and dispute resolution. Full payment card numbers are never stored on 88ef1 systems.

The 88ef1 Platform uses cookies and similar tracking technologies to operate core functionality, analyse usage and remember your preferences. The categories of cookies we deploy are:

You may manage or disable optional cookies through your browser settings. Disabling essential cookies will impair Platform functionality and may prevent you from accessing your Account. Continued use of the Platform constitutes acceptance of our essential cookie deployment.

88ef1 retains personal data for as long as is necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory and audit obligations. Specific retention periods are as follows:

• Account and Registration Data: Retained for the lifetime of the Account and for a minimum period thereafter as required by the Operator's licensing and AML obligations.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of Account closure or the date of the last transaction, whichever is later, in compliance with AML requirements.
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer Support Communications: Retained for two (2) years from the date of the final interaction, unless required for longer in connection with an unresolved dispute.
• Activity and Gaming Logs: Retained for a minimum of two (2) years for fraud monitoring and responsible gambling purposes.
• Marketing Preferences: Retained until you withdraw consent or request erasure, subject to any overriding legal retention obligation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an individual.

88ef1 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• TLS/SSL Encryption: All data in transit between your browser or device and the Platform is encrypted using HTTPS with Transport Layer Security (TLS).
• Data Encryption at Rest: Sensitive data fields, including KYC documents and financial records, are encrypted within our database infrastructure.
• Access Controls: Internal access to personal data is restricted on a need-to-know basis. Administrative access is subject to multi-factor authentication and audit logging.
• Password Security: User passwords are stored using industry-standard cryptographic hashing; plain-text passwords are never retained.
• Security Audits: The Platform undergoes periodic security assessments to identify and remediate potential vulnerabilities.
• Incident Response: In the event of a data breach that may affect your rights, we will notify affected Users and relevant authorities as required by applicable law.

Subject to applicable law and the Operator's legal retention obligations, you hold the following rights with respect to your personal data:

To exercise any of these rights, contact us at [email protected] with a clear description of your request. We will respond within thirty (30) days. We may request proof of identity before actioning a request. Note that certain rights may be limited where we are required by law to retain or continue processing your data — for example, AML retention obligations take precedence over erasure requests in respect of transaction records.

If you are a parent or guardian and believe that a minor under your care has registered an Account or provided personal data to the Platform, please contact our support team immediately at [email protected] so we can investigate and take appropriate action.

The operation of an international online betting platform may require the transfer of personal data to countries outside of your country of residence, including countries whose data protection laws differ from those in Pakistan or in the Operator's licensing jurisdiction.

Where such transfers occur, 88ef1 ensures appropriate safeguards are in place, which may include:

• Contractual clauses requiring the recipient to apply equivalent data protection standards.
• Transfers to jurisdictions that provide an adequate level of data protection under applicable standards.
• Transfers strictly necessary for the performance of our contract with you (e.g., processing a PKR transaction through an international payment processor).

By using the Service, you acknowledge and agree that your personal data may be processed in jurisdictions outside Pakistan, subject to the safeguards described above.

88ef1 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law or platform operations. Material changes will be communicated to registered Users via the email address on file or by a prominent notice on the Platform prior to the change taking effect.

Your continued use of the Service after any update to this Policy constitutes your acceptance of the revised terms. The "Effective" date at the top of this Policy identifies the version currently in force. We encourage you to review this Policy periodically.

For questions, requests or complaints regarding this Privacy Policy or the processing of your personal data, please contact the 88ef1 team through any of the following channels:

• Data / Privacy Queries (Email): [email protected]
• Live Chat: Available on the Platform during operator support hours.
• Help Centre: Visit the FAQ page for answers to common privacy-related questions.

We aim to acknowledge all privacy-related requests within seven (7) days and to resolve them within thirty (30) days. Complex requests, particularly those requiring regulatory input, may take longer. We will keep you informed of progress in such cases.