88fd Privacy Policy — Your Data, Your Rights

This Privacy Policy ("Policy") describes the practices of 88fd ("88fd", "We", "Us", "Our") — the operator of the online gaming and sports betting platform accessible at 88fd.lol — with respect to the collection, processing, storage, transfer, and protection of the personal data of registered players and website visitors ("You", "User", "Player", "Data Subject").

88fd acts as the Data Controller for personal data collected via the 88fd platform and associated communication channels. This means 88fd determines the purposes and means of processing your personal data, and bears responsibility for ensuring that processing is conducted lawfully, fairly, and in accordance with the principles set out in this Policy.

By creating an 88fd account, making a deposit, or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy, and you consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the 88fd platform.

88fd collects personal data through several channels: directly from you during registration and account use, automatically through platform interactions, and from third-party service providers (such as payment processors and KYC verification partners). The categories of data collected are as follows:

88fd does not collect sensitive personal data beyond what is strictly required for identity verification and AML compliance. We do not collect biometric data beyond what is required for the KYC liveness check process, and we do not retain biometric raw data beyond the verification event.

88fd uses the personal data it collects for the following specific and documented purposes. We do not use your data for any purpose not listed here without your explicit consent or a legitimate legal obligation requiring us to do so:

• Account Management: To create, maintain, and administer your 88fd player account, including login authentication, session management, and account security monitoring.
• Service Delivery: To provide the core 88fd gaming and betting services — processing game rounds, recording bets, delivering live dealer streams, and ensuring the platform functions correctly for your device and network connection.
• Payment Processing: To process deposits via JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and other supported Pakistani payment methods, and to process withdrawal requests to verified payment accounts.
• Identity Verification (KYC/AML): To comply with Anti-Money Laundering obligations and international gaming licence requirements by verifying your identity, age (21+), and the legitimacy of your payment methods.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, money laundering, and other prohibited activities on the platform.
• Responsible Gaming Compliance: To monitor gaming behaviour for indicators of problem gambling and to enforce player-set limits, cooling-off periods, and self-exclusion requests.
• Customer Support: To respond to your support queries, resolve disputes, and provide assistance with account, payment, or gaming issues.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to marketing communications. This is always opt-in and can be withdrawn at any time.
• Legal Compliance: To comply with legal obligations, regulatory requirements, and lawful requests from competent authorities, including international gaming licence regulatory bodies.
• Platform Improvement: To analyse aggregated and anonymised usage data for the purpose of improving platform performance, game selection, and user experience.

For each processing activity, 88fd relies on one or more of the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and 88fd — including account management, service delivery, and payment processing. Without this processing, 88fd cannot provide you with the services you have registered for.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements — including KYC/AML obligations, gaming licence conditions, tax reporting, and lawful authority requests.
• Legitimate Interests: Processing conducted on the basis of 88fd's legitimate interests — including fraud prevention, platform security, responsible gaming monitoring, and platform improvement — where these interests are not overridden by your rights and interests.
• Consent: Processing conducted with your explicit consent — including marketing communications and certain optional analytics. You may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

88fd does not sell your personal data to any third party. Data sharing is limited strictly to what is necessary to deliver services, comply with legal obligations, and protect platform security. The following categories of third parties may receive limited personal data from 88fd:

• Payment Processors: JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and USDT processing services receive the minimum data necessary to process transactions (account identifiers and transaction amounts). All payment processors operate under binding data processing agreements.
• KYC/Identity Verification Providers: Third-party verification services receive identity documents and liveness check data for the purpose of verifying player identity and age. These providers operate under strict confidentiality and data processing agreements.
• Game Content Providers: Licensed game studios (e.g., Pragmatic Play, NetEnt, Microgaming) receive anonymised session and gameplay data necessary for game function and fairness auditing. No personally identifiable information beyond a session token is shared.
• Live Dealer Studio Operators: Live dealer game streams are operated by third-party studio providers. These providers access the minimum data required for game session delivery and do not retain identifiable player data.
• IT Infrastructure & Cloud Providers: 88fd uses cloud infrastructure providers for platform hosting. These providers process data on 88fd's instructions only and under binding data processing agreements with appropriate security controls.
• Regulatory Authorities: 88fd may be required to share player data with its international gaming licence regulatory authority, financial intelligence units, or law enforcement agencies in response to lawful requests. 88fd will comply with all legally binding orders.

Given that the majority of 88fd's player base consists of Pakistani players transacting via domestic payment systems, this section addresses specific considerations for Pakistani payment data:

• JazzCash & EasyPaisa: When you transact via JazzCash or EasyPaisa, 88fd receives confirmation of your transaction reference, amount, and the masked mobile wallet number associated with the transaction. 88fd does not receive or store your full mobile wallet PIN or password at any point.
• Bank Transfers (HBL, UBL, Meezan, Raast): Bank transfer data received by 88fd includes account title, bank name, and transaction reference. Full account numbers are masked in 88fd's systems after confirmation. 88fd does not retain complete bank account numbers.
• CNIC Data: National identity card data collected for KYC purposes is stored in encrypted form and accessed only by 88fd's compliance team and approved third-party verification providers. CNIC data is never shared with marketing partners or game providers.
• Transaction History: Your complete deposit and withdrawal history on 88fd is retained as part of your account record for the duration specified in Section 8 (Data Retention). This data is used for transaction dispute resolution and AML compliance.

88fd uses cookies and similar technical tracking technologies to operate the platform and improve the user experience. The following cookie categories are used:

• Strictly Necessary Cookies: Required for basic platform function — including maintaining your login session, preserving game state, and enabling secure payment flows. These cookies cannot be disabled without breaking core platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised usage data (page load times, game loading performance, navigation patterns) that helps 88fd optimise the platform for Pakistani mobile networks and device types. Data collected by analytics cookies is aggregated and not linked to individual identities.
• Functional Cookies: Used to remember your preferences — including language, display settings, and game lobby filters — so you don't have to reconfigure them at every login.
• Security Cookies: Used to detect and prevent fraudulent activity, including session hijacking, cross-site request forgery (CSRF), and bot activity. These cookies contain no personal data and are essential for platform security.

88fd does not use third-party advertising cookies or cross-site tracking technologies. The platform does not participate in advertising networks that track your behaviour across other websites.

88fd retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and licensing obligations. The following retention periods apply:

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be linked to you as an individual. Anonymised and aggregated data may be retained indefinitely for statistical and platform improvement purposes.

88fd takes the security of your personal data seriously. The following technical and organisational measures are in place to protect player data against unauthorised access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and 88fd's servers is encrypted using 256-bit SSL/TLS — the same standard employed by major Pakistani banks including HBL and UBL for online banking. Your login credentials, payment data, and personal information are never transmitted in plaintext.
• Encryption at Rest: Sensitive personal data stored on 88fd's servers — including CNIC data and financial records — is encrypted at rest using AES-256 encryption. Database access is restricted to authorised personnel only via multi-factor authentication.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. 88fd staff members are assigned the minimum data access rights necessary to perform their roles. All data access is logged and auditable.
• Security Monitoring: 88fd operates continuous security monitoring on all platform infrastructure, including intrusion detection, anomaly detection on login patterns, and automated alerts for suspicious activity.
• Data Breach Response: In the event of a data breach that creates a risk to your rights, 88fd will notify affected players without undue delay and take immediate remedial action. 88fd maintains a documented data breach response procedure reviewed at least annually.
• Third-Party Security: All third parties processing data on 88fd's behalf are required to maintain security standards equivalent to or exceeding those described in this section, as documented in binding Data Processing Agreements.

88fd operates under an international gaming licence and uses global cloud infrastructure. As a result, your personal data may be processed or stored on servers located outside Pakistan. In such cases, 88fd ensures that appropriate safeguards are in place to protect your data in accordance with the privacy principles set out in this Policy:

• Data transfers to third-party service providers are governed by binding Data Processing Agreements that impose equivalent data protection obligations on the recipient.
• Where data is transferred to jurisdictions without an equivalent legal framework for data protection, 88fd implements standard contractual clauses or equivalent transfer mechanisms to ensure your data remains protected.
• KYC and identity documentation is processed in jurisdictions that maintain adequate data protection standards consistent with 88fd's licensing obligations.

As a data subject, you have the following rights with respect to your personal data held by 88fd. You may exercise any of these rights by contacting 88fd support via the channels listed in Section 15:

• Right of Access: You have the right to request a copy of the personal data 88fd holds about you, along with information about how it is being processed. 88fd will respond within 30 calendar days of a verified request.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. Requests to update contact information (mobile number, email) should be made through your account settings where possible.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected. Note that erasure requests cannot be honoured where 88fd is required to retain data by law (e.g., AML obligations under Section 8).
• Right to Restriction of Processing: You may request that 88fd restricts processing of your data in certain circumstances, such as where you contest the accuracy of the data or object to processing on legitimate interests grounds.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller, where technically feasible.
• Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes. Objections to direct marketing will be honoured immediately. Objections to other legitimate interests processing will be assessed against 88fd's compelling grounds.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

88fd will not charge a fee for processing data rights requests unless they are manifestly unfounded or excessive. Identity verification will be required before processing any request to ensure data security.

88fd may send promotional communications — including bonus offers, game announcements, PSL betting promotions, and platform updates — to players who have explicitly opted in to marketing communications during registration or through their account settings.

• Opt-In Requirement: Marketing communications are always opt-in. 88fd will not send unsolicited promotional messages to players who have not consented to receive them.
• Channel Options: Marketing communications may be sent via email, SMS to your registered Pakistani mobile number, or in-app push notifications. You may configure your preferences for each channel separately in your account settings.
• Opt-Out: You may withdraw marketing consent at any time by updating your preferences in your account settings, or by following the unsubscribe instructions included in any marketing communication. Opt-out requests take effect within 72 hours. Note that transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts) are not marketing communications and cannot be opted out of while your account is active, as they are necessary for the safe operation of your account.

88fd is strictly a 21+ platform. The platform does not knowingly collect personal data from persons under 21 years of age. All account registrations are subject to mandatory age verification through CNIC-based KYC processes.

If 88fd becomes aware that personal data has been collected from a person under the age of 21, 88fd will:

• Immediately suspend the account and suspend all transaction processing.
• Delete the personal data of the underage individual from 88fd's systems, subject to any legal retention obligations that may apply.
• Return any funds deposited to the originating payment method after deducting any amounts wagered.

88fd reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, licensing requirements, data processing practices, or platform features. The version number and effective date at the top of this document will be updated to reflect the most recent revision.

When material changes are made to this Policy, 88fd will notify registered players through one or more of the following channels:

• A notification displayed on the 88fd platform upon next login, prompting acknowledgement of the updated Policy.
• An email notification to your registered email address describing the key changes and the effective date.

Your continued use of the 88fd platform after the effective date of any Policy update constitutes your acceptance of the revised Policy. If you do not accept the updated Policy, you must cease using the platform and request account closure before the effective date.

88fd recommends that players periodically review this Policy at 88fd.lol/privacy-policy to stay informed of how your data is handled. Historical versions of the Policy are available on request from 88fd support.

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 88fd, please contact us through the following channels:

Complaints: If you believe that 88fd has handled your personal data in a manner that violates this Policy or applicable data protection law, you have the right to lodge a complaint with 88fd's internal privacy team in the first instance. If your complaint is not resolved to your satisfaction, you may escalate the matter to the relevant supervisory authority under 88fd's international gaming licence jurisdiction.

This Privacy Policy was last updated on 01 January 2026 and supersedes all previous versions. Document reference: 88fd-PP-v3.1. This Policy is published in English. In the event of any inconsistency between translated versions (if any) and the English version, the English version shall prevail.