88fa Privacy Policy

1. Identity of the Data Controller

For the purposes of applicable data protection law, the data controller responsible for the personal data you provide to 88fa is the entity operating the 88fa.cam platform under an international online gaming licence. As data controller, 88fa determines the purposes and means of processing your personal data.

All data-related enquiries, access requests, correction requests, and deletion requests should be directed to our Data Protection contact at [email protected], clearly marked "Data Protection Request" in your subject line. 88fa will acknowledge such requests within five (5) business days.

2. Categories of Personal Data We Collect

88fa collects and processes the following categories of personal data in connection with your account and use of the Platform:

88fa does not collect special categories of sensitive personal data (such as biometric data, health data, or religious beliefs) unless specifically required by a regulatory obligation and disclosed to you at the time of collection.

3. How We Collect Your Data

Personal data is collected through the following channels on the 88fa Platform:

• Direct Registration: Data you provide when creating your account, completing KYC verification, or updating your profile.
• Transaction Processing: Data exchanged when making deposits or requesting withdrawals through JazzCash, EasyPaisa, Raast, 1LINK, bank transfers, or other supported methods.
• Platform Interaction: Data automatically generated as you navigate the Platform, place bets, and interact with games.
• Customer Support: Data provided during live chat, email correspondence, or any other support interaction.
• Cookies and Tracking Technologies: Data collected through cookies, pixel tags, and similar technologies as described in Section 8 of this Policy.
• Third-Party Verification Services: Data received from identity verification providers used to conduct KYC checks as required by our licensing obligations.

4. Purposes of Processing & Legal Basis

88fa processes your personal data only where we have a lawful basis to do so. The following table sets out our processing purposes alongside the legal basis we rely upon for each:

5. Sharing of Personal Data

88fa does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. We share personal data only in the following limited circumstances and only to the extent necessary:

• Payment Processors: JazzCash, EasyPaisa, Raast, 1LINK, HBL, UBL, Meezan Bank, and other payment partners receive the minimum financial data necessary to process your transactions.
• Identity Verification Providers: Third-party KYC service providers receive identity document data to conduct regulatory-required verification checks on our behalf.
• Game Software Providers: Game providers (such as Pragmatic Play or PG Soft) may receive anonymised session data necessary to deliver game services. No directly identifiable personal data is shared for game delivery purposes.
• Regulatory Authorities: Licensing authorities, financial intelligence units, and other competent regulatory bodies may receive personal data where we are legally required to disclose it.
• Legal Advisers and Auditors: Professional advisers bound by confidentiality obligations may access personal data as necessary for legal, compliance, or audit purposes.
• Law Enforcement: Personal data may be disclosed to law enforcement or government agencies where required by applicable law or a valid legal process.

All third parties processing personal data on behalf of 88fa are bound by data processing agreements that require them to process data only on our documented instructions and to maintain appropriate security standards.

6. International Data Transfers

88fa operates internationally and your personal data may be transferred to, and processed in, countries outside Pakistan. Where such transfers occur, 88fa takes appropriate steps to ensure that your data receives a level of protection comparable to that afforded under applicable data protection standards, including by relying on contractual safeguards with the relevant recipients.

Specifically, transfers to game software providers and technology infrastructure partners may involve processing in jurisdictions where 88fa holds contractual protections with the data importer. If you have questions about the safeguards applicable to a specific transfer, please contact us at [email protected].

7. Data Retention

88fa retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law or regulatory obligation. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, as required by anti-money laundering regulations applicable to our licensing jurisdiction.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Support and communications records: Retained for three (3) years from the date of the interaction, unless a longer period is required for an unresolved dispute.
• Marketing preference records: Retained until you withdraw consent or request deletion, after which an opt-out record is maintained to prevent accidental re-enrolment.
• Technical and usage data: Retained for up to twenty-four (24) months from collection, unless specific security or regulatory requirements necessitate longer retention.

On expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

8. Cookies & Tracking Technologies

88fa uses cookies and similar tracking technologies on the Platform to deliver and improve our services. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies and security tokens. They cannot be disabled without preventing you from using the Platform.
• Functional Cookies: Remember your preferences, language settings, and login status to provide a smoother experience across sessions.
• Analytics Cookies: Collect anonymised or aggregated data about how players use the Platform, enabling us to identify and fix usability issues and improve content.
• Marketing Cookies: Used only with your consent to deliver relevant promotional messages and track the effectiveness of our campaigns. No marketing cookies are set without explicit opt-in.

You may control non-essential cookies through your browser settings. Note that disabling certain functional cookies may affect the quality of your experience on 88fa. Our cookie preferences can also be managed through the cookie consent banner displayed on your first visit to the Platform.

9. Security Measures

88fa implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmissions between your device and the 88fa Platform.
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and financial information.
• Two-factor authentication (2FA) available to all account holders as an additional access control layer.
• Automated session timeouts following periods of inactivity.
• Access controls restricting internal data access to employees with a documented operational need.
• Regular security audits and penetration testing of Platform infrastructure.
• Incident response procedures to manage and contain any data security incidents promptly.

10. Your Data Rights

Subject to applicable law, you hold the following rights with respect to your personal data held by 88fa:

• Right of Access: You may request a copy of the personal data we hold about you. We will provide this within thirty (30) days of a verified request.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Some data (such as your legal name on a KYC-verified account) requires documentary evidence to amend.
• Right to Erasure: You may request deletion of your personal data. This right is subject to overriding retention obligations under AML law and our licence requirements. We will inform you of any such constraints at the time of your request.
• Right to Restriction: You may request that we limit processing of your data in certain circumstances, such as while a correction request is being assessed.
• Right to Data Portability: You may request that we provide your data in a structured, commonly used, machine-readable format where technically feasible.
• Right to Object: You may object to processing of your data based on legitimate interests, including profiling, in certain circumstances.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time with immediate effect going forward.

To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request" and describe the right you wish to exercise. We may need to verify your identity before processing the request. We will respond within the applicable statutory timeframe.

11. Children's Privacy — 21+ Strictly Enforced

The 88fa Platform is intended exclusively for adults aged 21 years and older. We do not knowingly collect personal data from individuals below this age threshold. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the data to the extent not required by regulatory retention obligations, and return any deposited funds to the originating payment source.

If you believe a person under 21 has created an account on 88fa, please contact us immediately at [email protected] so that we can take appropriate action.

12. Third-Party Services & Links

The 88fa Platform may reference third-party service providers (such as game studios or payment processors) in the course of delivering services to you. These third parties operate under their own privacy policies, and 88fa is not responsible for the data practices of third-party entities that are not acting as processors on our behalf.

This Privacy Policy applies solely to the 88fa.cam Platform and does not extend to any external websites, applications, or services that may be referenced or integrated into the Platform. We encourage you to review the privacy practices of any third-party service you interact with independently of 88fa.

13. Amendments to This Privacy Policy

88fa reserves the right to update this Privacy Policy at any time. Material changes — particularly those affecting how we use your data or the rights available to you — will be communicated via email to your registered address and/or by a prominent notice on the Platform at least seven (7) days before taking effect.

Minor clarifications, corrections of typographical errors, and changes required by new regulatory guidance may take effect immediately upon publication. The "Last Reviewed" date at the top of this Policy reflects the date of the most recent update. We recommend reviewing this Policy periodically.

14. Contact, Complaints & Enquiries

For any privacy-related question, data rights request, or complaint about how 88fa has handled your personal data, please contact our Data Protection team:

• Email: [email protected] (subject: "Data Protection Request")
• Live Chat: Available 24/7 on the 88fa Platform in English and Urdu
• Response Time: Acknowledgement within five (5) business days; full response within thirty (30) days for access requests

If you are not satisfied with our response to a data protection complaint, you have the right to escalate your complaint to the competent supervisory authority in the jurisdiction under which our licence operates. We will provide the relevant authority's contact information upon request.

This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy, both of which form part of the complete framework governing your use of 88fa.