Privacy Policy — 88cf

1 Introduction

This Privacy Policy (hereinafter "Policy") governs the collection, processing, storage, disclosure and protection of personal data by 88cf (hereinafter "the Platform", "we", "us", "our") in connection with the operation of its online betting and live casino services accessible at https://88cf.cam.

88cf is an entertainment platform designed to serve Pakistani players and users in jurisdictions where online gambling is lawful. In the course of providing our services — which include sports betting on cricket, PSL/T20, ICC tournaments, football and UFC, alongside live casino games and slot content — we collect and process certain personal data about registered Users. This Policy explains how we do so responsibly.

By accessing or using the 88cf Platform, registering an account or making use of any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing and use of your personal data as described herein.

2 Definitions

3 Data Controller Identity

For the purposes of this Privacy Policy, the Data Controller responsible for your Personal Data is the entity operating the 88cf Platform at https://88cf.cam. The Platform's registered support contact for data-related enquiries is:

4 Personal Data We Collect

88cf collects Personal Data through several channels. The categories of data collected, and the contexts in which they are collected, are set out below.

• Full legal name
• Date of birth (for age-verification purposes)
• Email address
• Username and encrypted password
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar)
• Mobile telephone number (where provided)

• Copies of government-issued identity documents — valid CNIC (Computerised National Identity Card, both sides) or current passport bio-data page
• Proof of address documentation (utility bill, bank statement or equivalent) where required
• Selfie photograph or liveness-check video for identity matching
• Payment method verification documentation where applicable

• Deposit and withdrawal amounts, dates and transaction reference numbers
• Payment method identifiers (e.g., masked account or wallet references)
• Account balance history and wagering activity records

Payment method names referenced on this Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are mentioned for user context only and do not imply endorsement, affiliation or support of gambling services by those institutions. We do not store full payment card numbers on our servers.

• IP address and approximate geolocation (country and city level)
• Device type, operating system and browser version
• Session timestamps, page visit logs and in-platform navigation data
• Betting and gaming activity logs (markets viewed, wagers placed, games played)
• Responsible-gambling tool settings and history (deposit limits, session timers, self-exclusion records)

• Content of support chat and email interactions for quality assurance and complaint resolution
• Records of consent to marketing communications
• Feedback and survey responses where voluntarily provided

5 Legal Basis for Processing

88cf processes your Personal Data on one or more of the following legal bases, depending on the purpose of processing:

• Contractual Necessity: Processing is necessary to perform our contractual obligations to you as a registered User — including account creation, transaction processing, KYC verification and the provision of betting and gaming services.
• Legal Obligation: Certain data is processed to comply with applicable legal obligations, including anti-money laundering (AML) requirements, age-verification obligations and fraud-prevention mandates imposed by our licensing framework.
• Legitimate Interests: We process certain technical and usage data on the basis of our legitimate interest in operating a secure, stable and fraud-resistant platform — provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where processing is based on your consent — for example, in connection with optional marketing communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing. Withdrawal of consent does not affect data processing carried out under other legal bases.

6 How We Use Your Personal Data

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

• Creating, maintaining and operating your registered account
• Processing deposits, withdrawals and associated transaction records
• Delivering betting, casino and gaming services, including live odds and in-play market data
• Managing VIP tier status, loyalty rewards and promotional eligibility

• Verifying your identity and age as part of the KYC process
• Conducting Anti-Money Laundering (AML) screening and ongoing transaction monitoring
• Detecting and preventing fraudulent account activity, bonus abuse and collusion
• Complying with legal obligations under the Platform's applicable licensing framework

• Monitoring for unauthorised account access and security incidents
• Investigating reports of misconduct, cheating or breaches of our Terms & Conditions
• Maintaining audit trails for compliance and dispute-resolution purposes

• Recording and enforcing deposit limits, loss limits, session timers and self-exclusion status
• Identifying usage patterns that may indicate problem-gambling behaviour, for the purpose of proactive outreach where appropriate
• Maintaining self-exclusion records to prevent re-registration during an active exclusion period

• Responding to support queries, complaints and account enquiries submitted in English or Urdu
• Sending transactional notifications — deposit confirmations, withdrawal status updates, KYC approval alerts
• Sending marketing communications, where you have provided consent, relating to promotions, bonuses and platform features relevant to Pakistani players

• Aggregated, anonymised analysis of Platform usage to identify performance issues and improve the user experience
• A/B testing of user interface changes in aggregated, non-identifiable form

7 Data Sharing & Disclosure

88cf does not sell your Personal Data to any third party. We share data only in the limited circumstances described below:

• Identity Verification Providers: We engage certified third-party KYC service providers to process identity documents and conduct liveness checks. These providers operate under strict data-processing agreements and may not use your data for any purpose beyond the contracted service.
• Payment Processing Partners: Transaction data is shared with payment processing infrastructure providers to the extent necessary to process deposits and withdrawals. Full payment credentials are not stored by 88cf.
• Fraud & AML Screening Services: We may share account and transaction data with fraud-detection and AML-screening service providers as part of our compliance obligations.
• IT Infrastructure & Hosting Providers: Your data is stored on servers operated by third-party hosting infrastructure providers under contractual confidentiality and data-security obligations.
• Legal & Regulatory Obligations: We may disclose Personal Data to law enforcement agencies, courts, regulators or other government authorities where we are legally required to do so, or where disclosure is necessary to protect the rights, property or safety of 88cf, its users or third parties.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of the Platform's operations, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.

8 International Data Transfers

As an online platform serving users across multiple jurisdictions, certain of our service providers and infrastructure partners may operate in countries outside Pakistan. Your Personal Data may therefore be transferred to, stored in, or processed in countries other than Pakistan.

Where such transfers occur, 88cf takes reasonable steps to ensure that your data receives a standard of protection consistent with the principles set out in this Policy, including through contractual arrangements with recipients that impose appropriate data-protection obligations.

By using the Platform, you acknowledge and consent to the transfer of your Personal Data to other jurisdictions for the purposes described in this Policy.

9 Data Retention

We retain Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, including the satisfaction of legal, regulatory, AML and audit obligations. The following general retention principles apply:

• Account Data: Retained for the duration of the active account relationship, and for a minimum of five (5) years following account closure, to satisfy AML and financial-records obligations.
• KYC Documents: Retained for a minimum of five (5) years following the conclusion of the business relationship, as required under anti-money-laundering frameworks applicable to our licensing jurisdiction.
• Transaction Records: Retained for a minimum of five (5) years following each transaction date.
• Support Communications: Retained for up to three (3) years following resolution of the relevant interaction, to support quality assurance, audit and dispute-resolution purposes.
• Marketing Consent Records: Retained for as long as you hold an active account and for a reasonable period thereafter, to demonstrate compliance with consent obligations.
• Self-Exclusion Records: Retained indefinitely where a permanent self-exclusion has been applied, to prevent re-registration.

Following the expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised. Where data is anonymised, the resulting anonymised datasets are no longer Personal Data and are not subject to this Policy.

10 Security Measures

88cf implements and maintains a range of technical and organisational security measures designed to protect your Personal Data against accidental or unlawful loss, destruction, alteration, disclosure or unauthorised access.

• Encryption in Transit: All data transmitted between your browser/device and the Platform is encrypted using TLS/SSL protocols.
• Encryption at Rest: Sensitive Personal Data — including KYC documents and payment details — is encrypted at rest using industry-standard algorithms.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. Internal access to sensitive data categories requires multi-level authorisation.
• Two-Factor Authentication: All user accounts have the option of enabling two-factor authentication (2FA) as an additional account security layer.
• Penetration Testing: The Platform undergoes periodic security assessments to identify and remediate vulnerabilities.
• Staff Training: Personnel with access to Personal Data receive training on data-protection obligations and information-security best practices.

Notwithstanding the above, no method of electronic data transmission or storage is entirely secure. While we take reasonable measures to protect your data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account login credentials and should notify us immediately at [email protected] if you suspect any unauthorised access to your account.

11 Cookies & Tracking Technologies

88cf uses cookies and similar tracking technologies to operate the Platform, maintain session continuity, remember user preferences and carry out limited analytical measurement.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent full use of the Platform. Third-party advertising or behavioural-tracking cookies are not used on the 88cf Platform without clear prior disclosure and, where required, your consent.

12 Your Data Rights

88cf recognises and respects your rights in relation to your Personal Data. The rights described below reflect international best-practice standards that 88cf applies to all users, regardless of jurisdiction.

To exercise any of the above rights, please contact our support team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days.

We may need to verify your identity before processing certain rights requests, to ensure we do not disclose or alter data belonging to another individual.

13 Minors & Age Protection

88cf is strictly an adults-only platform. We do not knowingly collect, process or retain Personal Data relating to individuals under the age of 18 — or the higher minimum age required by the operator or applicable license jurisdiction.

Age-verification controls form a core part of our KYC process. Where we become aware, at any stage, that a User under the applicable minimum age has registered an account or provided personal data, we will:

• Immediately suspend the account and freeze any associated balance pending investigation.
• Delete all Personal Data associated with the underage User to the extent consistent with our legal obligations.
• Refund any confirmed deposits made by the underage User, less any amounts required to be held under applicable law.

Registered account holders must not share their login credentials with, or permit access to the Platform by, any person under the applicable minimum age. This constitutes a breach of our Terms & Conditions.

14 Marketing Communications

88cf may send you promotional communications — including information about bonuses, seasonal promotions, PSL/T20 betting specials, ICC tournament markets and new platform features — where you have provided explicit consent to receive such communications at the time of registration or through your account settings.

Marketing messages may be delivered by email. We do not make unsolicited telephone calls for marketing purposes.

Opting Out: You may withdraw your consent to marketing communications at any time by:

• Updating your communication preferences in your account settings dashboard.
• Clicking the unsubscribe link included in any marketing email.
• Contacting our support team at [email protected] with the subject line "Unsubscribe".

Opting out of marketing communications does not affect the sending of transactional notifications — such as withdrawal confirmations and KYC status alerts — which are required for account operation.

15 Changes to This Privacy Policy

88cf reserves the right to update, amend or replace this Privacy Policy at any time to reflect changes in our data-processing practices, legal obligations, business operations or applicable guidance. The version date at the top of this document indicates the most recent revision.

Where changes are material — for example, changes that introduce new data-processing purposes or affect your rights in a significant way — we will provide reasonable advance notice by:

• Posting a prominent notice on the Platform homepage or login page; and/or
• Sending a notification to your registered email address.

Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised terms, you must cease use of the Platform and may request account closure prior to the effective date.

We recommend reviewing this Policy periodically. The most current version is always accessible at https://88cf.cam/privacy-policy.

16 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data, please contact us through the following channel. All data-related enquiries are handled by our support team and, where appropriate, escalated to designated data-handling personnel.

For general platform terms, please review our Terms & Conditions. For responsible-gambling tools and self-exclusion, visit our Responsible Gambling page.