Privacy Policy — 88wine

01 Introduction

This Privacy Policy (hereinafter "Policy") is issued by 88wine (hereinafter "we", "us", "our", "the Platform") in relation to the collection, use, storage, disclosure and protection of personal data obtained from users ("you", "User", "Player") who access or use the 88wine platform at https://88wine.cam.

88wine is an online betting and live casino platform designed primarily for English-speaking Pakistani users, covering sports betting including Pakistan cricket, PSL, ICC tournaments, football and UFC, as well as live dealer casino and slot products. We recognise that Pakistani users entrust us with personal information, and this Policy explains precisely how that information is handled.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall use of the Platform. By accessing 88wine or creating an Account, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

02 Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, date of birth, residential address, payment details and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, organisation, retrieval, use, disclosure, transfer, restriction or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data; in this context, 88wine.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller pursuant to a written data processing agreement.
• "KYC Data" — identity verification documents and information submitted by Players as part of the Know Your Customer process, including government-issued photo identification, proof of address and proof of payment method.
• "Cookies" — small text files placed on your device by the Platform for the purposes of functionality, analytics, session management and security.
• "Consent" — a freely given, specific, informed and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.

03 Data Controller

88wine acts as the Data Controller in respect of Personal Data collected from users of the Platform. The Data Controller is responsible for determining the purposes for which, and the manner in which, Personal Data is processed.

Where Personal Data is shared with third-party service providers — such as payment processors, identity verification services or analytics platforms — those parties may act as Data Processors under contractual data processing agreements. 88wine ensures, to the extent practicable, that Data Processors provide sufficient guarantees in respect of technical and organisational security measures.

For all data-related enquiries, complaints or rights requests, you may contact us via the details set out in Section 17 (Contact Us) of this Policy.

04 Data We Collect

88wine collects Personal Data in the following categories, depending on your level of interaction with the Platform:

4.1 Registration Data

When you create an Account, we collect: full name, date of birth, email address, country of residence, username, and chosen password (stored in hashed form only — we do not store plaintext passwords).

4.2 KYC & Verification Data

To comply with our age verification and identity verification obligations, we may request: government-issued photo identification (e.g., CNIC, passport), proof of residential address, and, for Pakistani users referencing familiar local payment methods (Easypaisa, JazzCash, bank transfer via HBL, UBL, Meezan Bank, Bank Alfalah, or Raast), proof of payment method ownership. These documents are collected for verification purposes only and are handled with strict access controls.

4.3 Transaction & Financial Data

Records of deposits, withdrawals, wagers, account balances, bonus usage, and transaction timestamps. We do not store full payment card numbers — truncated identifiers only are retained where relevant.

4.4 Usage & Behavioural Data

Information about how you use the Platform, including pages visited, features accessed, betting patterns (at aggregate level for platform improvement), session duration and click-path data. This data is used to improve the Platform experience and for responsible gambling monitoring purposes.

4.5 Technical & Device Data

IP address, browser type and version, operating system, device type (e.g., Android mobile as predominantly used by Pakistani users), time zone and referring URL. This data is used for security, fraud prevention and platform optimisation.

4.6 Communications Data

Content of support conversations, email correspondence, and feedback submissions. These records are retained for quality assurance and dispute resolution purposes.

05 How We Use Your Data

Personal Data collected by 88wine is used strictly for the following purposes:

06 Legal Basis for Processing

Where applicable data protection law requires a legal basis for processing Personal Data, 88wine relies on the following bases:

• Contract Performance: Processing necessary to fulfil the contractual obligations arising from your registration and use of the Platform, including account management, bet processing and withdrawal handling.
• Legal Obligation: Processing required to comply with applicable legal requirements, including anti-money laundering obligations, age verification requirements, and record-keeping duties imposed by the operator's license jurisdiction.
• Legitimate Interests: Processing where 88wine has a legitimate business interest that is not overridden by your rights, including fraud prevention, platform security, and aggregate analytics for service improvement. We conduct balancing assessments to ensure these interests do not disproportionately affect your rights.
• Consent: Where processing is based on your freely given, specific and informed consent — in particular for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Data Sharing & Disclosure

88wine does not sell your Personal Data to third parties. We may share Personal Data with the following categories of recipients only where necessary for the stated purpose and subject to appropriate contractual safeguards:

• Payment Processors & Financial Service Providers: To process deposits and withdrawals. Where Pakistani users utilise local payment references such as Easypaisa, JazzCash, Raast or bank transfers via HBL, UBL, Meezan Bank or Bank Alfalah, relevant transaction data is shared only to the extent required for payment processing. None of these providers endorse gambling or this operator.
• Identity Verification Services: Third-party KYC providers who assist in verifying the identity and age of Account holders. These providers operate under strict data processing agreements.
• Technology & Infrastructure Providers: Cloud hosting providers, platform infrastructure and cybersecurity services. These entities act as Data Processors and are bound by contractual confidentiality and security obligations.
• Analytics Providers: Aggregated or pseudonymised usage data may be shared with analytics platforms for platform performance monitoring. Individual Player profiles are not shared with analytics providers.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order or valid legal process, Personal Data may be disclosed to competent authorities. 88wine will challenge overly broad disclosure requests to the extent permitted by law.
• Professional Advisers: Legal, accounting and audit professionals where disclosure is necessary for the exercise or defence of legal claims, subject to professional confidentiality obligations.

08 International Data Transfers

As an online platform operating across jurisdictions, Personal Data collected from Pakistani users may be transferred to and processed in countries outside Pakistan. Where such transfers occur, 88wine takes appropriate steps to ensure that an adequate level of protection is maintained for your Personal Data, including through the use of contractual safeguards with recipient parties.

Transfers are made only to countries or processors that provide adequate data protection standards or where additional safeguards are in place. If you require further information about the safeguards applied to international transfers of your Personal Data, you may submit a written request via the contact details in Section 17.

09 Data Retention

Personal Data is retained only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable legal obligations. General retention principles applied by 88wine are as follows:

• Account Data: Retained for the duration of the Account relationship and for a period thereafter as required by the operator's applicable license jurisdiction obligations and anti-money laundering record-keeping requirements.
• KYC Documents: Retained for the period specified by applicable regulatory requirements, typically a minimum of five years following the end of the Account relationship, unless a longer period is mandated.
• Transaction Records: Retained for the minimum period required by applicable law and for dispute resolution purposes.
• Support Communications: Retained for up to three years following the resolution of the relevant enquiry, unless required for longer periods for ongoing dispute or legal processes.
• Marketing Consent Records: Retained for as long as you have an active Account or until you withdraw consent, whichever is earlier, plus a reasonable period to demonstrate compliance.

Upon the expiry of applicable retention periods, Personal Data is securely deleted or anonymised so that it can no longer be used to identify an individual.

10 Cookies & Tracking Technologies

88wine uses cookies and similar tracking technologies when you access the Platform. Cookies are small text files stored on your device. We use the following categories of cookies:

• Essential / Strictly Necessary Cookies: Required for the Platform to function correctly, including session management, login state and security tokens. These cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, pseudonymised data about how users interact with the Platform, including page visit frequency and navigation paths. This data is used exclusively for internal platform improvement.
• Functional Cookies: Used to remember user preferences such as language settings and last-visited pages to improve the experience on return visits.
• Security Cookies: Used to detect and prevent fraudulent activity, unusual access patterns and potential security threats to your Account.

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect your ability to use some features of the Platform. 88wine does not use cross-site tracking cookies for third-party advertising purposes.

11 Data Security

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

• SSL/TLS encryption for all data in transit between your device and the Platform.
• Password hashing using industry-standard algorithms — plaintext passwords are never stored.
• Access controls limiting Personal Data access to authorised personnel on a need-to-know basis.
• Regular security assessments of Platform infrastructure.
• Intrusion detection systems monitoring for unusual access patterns.

While we take security seriously, no system is entirely immune to breach. In the event of a Personal Data breach that poses a risk to your rights and freedoms, 88wine will notify you in accordance with applicable data protection obligations. You should promptly report any suspected unauthorised access to your Account via the contact details in Section 17.

12 Minors & Age Verification

88wine is strictly an adults-only platform. We do not knowingly collect Personal Data from individuals under the age of 18, or under the higher minimum age required by the applicable operator or license jurisdiction. Age verification is conducted as part of the KYC process for all Account holders.

If we become aware that Personal Data has been collected from a minor, we will take immediate steps to delete that data and close the associated Account. If you believe a minor has registered on the Platform, please contact us immediately via the details in Section 17.

13 Your Data Rights

Subject to applicable data protection law and certain legal exceptions, you have the following rights in respect of your Personal Data held by 88wine:

To exercise any of these rights, please submit a written request to the contact details in Section 17. We will respond within a reasonable timeframe and in any event within the period required by applicable law. Certain rights may be subject to limitations or exceptions under applicable data protection law or regulatory obligations applicable to gambling operators.

14 Marketing Communications

88wine will send you marketing communications — including promotional offers, bonus notifications and platform updates — only where you have provided explicit consent to receive such communications. Marketing is opt-in, not opt-out.

You may withdraw consent for marketing communications at any time by: (a) updating your communication preferences in account settings; or (b) contacting our support team via the details in Section 17. Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to withdrawal, and does not affect your ability to receive transactional communications necessary for Account management (such as deposit confirmations and security alerts).

15 Pakistan-Specific Context

88wine serves Pakistani users and acknowledges the specific legal and regulatory context that applies. In relation to data protection specifically:

• Pakistan's data protection landscape is evolving. The Personal Data Protection Bill and associated regulatory framework, where applicable, may affect how data collected from Pakistani residents is handled. 88wine monitors applicable legal developments.
• 88wine does not claim to be regulated by, endorsed by, or affiliated with the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any provincial data protection authority.
• Payment method references used on the 88wine Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are contextual references for Pakistani users and do not imply any data-sharing partnership with, or endorsement by, those organisations.
• Where Personal Data relating to Pakistani users is transferred internationally, 88wine applies appropriate contractual safeguards as described in Section 8.

Pakistani users who have concerns about how their Personal Data is handled are encouraged to contact us directly via the details in Section 17.

16 Changes to This Privacy Policy

88wine reserves the right to update or amend this Privacy Policy at any time. Where material changes are made, we will provide reasonable notice via the Platform or by email to registered Account holders. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision.

Your continued use of the Platform following notification of any changes constitutes your acknowledgement of the revised Policy. We encourage you to review this Policy periodically to stay informed about how your Personal Data is handled. If you object to any changes, you may close your Account by contacting our support team.

17 Contact Us

For all privacy-related enquiries, data rights requests, complaints or concerns relating to the processing of your Personal Data by 88wine, please contact us using the following details: