ef98 Privacy Policy

ef98 ("we", "us", "our") is committed to protecting the privacy and personal data of every player who registers and engages with our platform at ef98.app. This Privacy Policy has been prepared in accordance with applicable data protection obligations under ef98's international gaming licence and is specifically addressed to players based in Pakistan who access the platform in English.

This policy sets out in plain, precise terms: what personal data ef98 collects from you; the purposes for which that data is used; the legal grounds on which we process it; with whom it may be shared; how long we retain it; and what rights you have in relation to your own information.

By registering an account on ef98, completing our Know Your Customer (KYC) verification, making a deposit via JazzCash, EasyPaisa, HBL, UBL, or Meezan Bank, or simply browsing the platform, you acknowledge that you have read this Privacy Policy and understand how your data will be handled. If you do not agree with any part of this policy, you should discontinue use of the ef98 platform.

ef98 collects personal data across several categories, depending on your level of engagement with the platform. The table below summarises the principal categories of data we collect and the circumstances in which they are gathered.

ef98 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or biometric data beyond what is strictly necessary for identity verification under our KYC obligations.

ef98 processes personal data only for defined, legitimate purposes. The following list details each purpose alongside the data categories involved:

• Account creation and management: Identity and contact data are used to set up and maintain your ef98 player account, including authentication and account recovery.
• Identity verification (KYC): Identity and financial data are processed to verify that you are who you claim to be, that you are aged 21 or above, and that your payment methods are registered in your own name — as required by our licensing obligations.
• Processing deposits and withdrawals: Financial data is used to execute transactions via JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and to reconcile your ef98 PKR balance accurately.
• Delivering gaming services: Gaming activity data enables ef98 to provide personalised game recommendations, resolve bet disputes, and maintain accurate records of your session history.
• Fraud prevention and anti-money-laundering compliance: Technical and financial data are analysed to detect and prevent fraudulent account activity, bonus abuse, collusion, and money laundering.
• Customer support: Communications data is used to investigate and resolve queries, complaints, and disputes submitted via live chat or email.
• Responsible gaming enforcement: Responsible gaming data is used to enforce deposit limits, self-exclusion periods, and session time alerts in accordance with your preferences and ef98's duty-of-care obligations.
• Platform improvement and analytics: Aggregated and anonymised technical and gaming data are used to analyse platform performance, identify usability issues, and improve the overall ef98 experience for Pakistani players.
• Legal and regulatory compliance: Data across all categories may be processed where required to satisfy obligations imposed by ef98's licensing authority or applicable law.

Every instance of personal data processing carried out by ef98 is grounded in one of the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you accepted at registration — including account management, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with KYC, anti-money-laundering, and responsible gaming obligations imposed by ef98's international gaming licence.
• Legitimate interests: Processing carried out for fraud prevention, platform security, internal analytics, and abuse detection, where ef98's legitimate operational interests are not overridden by your data protection rights.
• Consent: Where ef98 processes data for optional purposes — such as sending promotional communications about bonuses, PSL special markets, or new slot releases — we will obtain your explicit consent and you may withdraw it at any time via your account settings or by contacting support.

ef98 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small data files placed on your device when you access ef98.app. They enable us to recognise your browser across sessions, maintain your login state, and collect analytical data about platform usage.

5.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies that keep you logged in to your ef98 account and security tokens that protect against cross-site request forgery. These cannot be disabled without breaking platform functionality.
• Functional cookies: Remember your preferences such as language selection, responsible gaming settings, and display preferences so you do not need to reconfigure them on each visit.
• Analytical cookies: Collect anonymised data about how players navigate ef98 — which game categories are most visited, which pages generate support queries — to guide platform improvements. This data is not linked to identifiable individuals.
• Performance cookies: Monitor technical performance indicators including page load times and error rates to ensure a consistent, high-quality experience for players accessing ef98 from Karachi, Lahore, Islamabad, Faisalabad, and elsewhere in Pakistan.

5.2 Cookie Management

You may manage or withdraw consent for non-essential cookies at any time through the cookie preference panel accessible within the ef98 platform or via your browser's built-in cookie management settings. Please note that disabling strictly necessary cookies will impair or prevent your ability to access the platform.

ef98 does not sell your personal data to any third party. We may share your data with the following categories of recipient, strictly on a need-to-know basis and only to the extent necessary for the stated purpose:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank receive the transactional and identity data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are bound by applicable financial regulation in Pakistan.
• KYC and identity verification providers: Third-party verification services receive identity documents (such as CNIC copies) and biometric data strictly for the purpose of satisfying our licensing KYC obligations. These providers are contractually bound to process data only as directed by ef98 and to maintain appropriate security standards.
• Fraud prevention and AML analytics providers: Specialist service providers may receive anonymised or pseudonymised transaction and technical data to support the detection of suspicious activity, bonus abuse, and multi-accounting behaviour.
• Gaming software and content providers: Game studio partners may receive session data necessary to operate their games within the ef98 platform (e.g., round outcomes, RNG seeds). No personally identifiable information beyond an anonymised session identifier is shared for this purpose.
• Regulatory and licensing authorities: ef98 may be required to disclose player data to its licensing authority or other competent regulatory bodies in connection with audits, investigations, or compliance reviews. Such disclosures are made only to the extent legally required.
• Law enforcement and legal proceedings: Where ef98 is subject to a valid court order, warrant, or lawful request from a competent authority, we will disclose the minimum data necessary to comply with that obligation.

ef98 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable licensing and legal obligations. The following retention principles apply:

• Account and identity data: Retained for the duration of your active account relationship with ef98, plus a minimum of five (5) years following account closure — consistent with standard anti-money-laundering record-keeping requirements applicable under ef98's licensing framework.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of each transaction to satisfy financial record-keeping obligations.
• Gaming activity data: Retained for the duration of the account relationship and for up to three (3) years after account closure for dispute resolution and compliance audit purposes.
• Communications and support data: Retained for up to three (3) years from the date of the communication to support ongoing complaint resolution and quality assurance.
• Responsible gaming data: Self-exclusion records are retained indefinitely to prevent re-registration during an active self-exclusion period; other responsible gaming preference data is retained for the account lifetime.
• Technical and analytical data: Anonymised analytics data may be retained indefinitely in aggregated form. IP logs and session data are retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with ef98's internal data destruction procedures.

ef98 implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Key security controls in place include:

• TLS/SSL encryption: All data transmitted between your device and ef98.app is encrypted in transit using Transport Layer Security (TLS), preventing interception by third parties.
• Encryption at rest: Sensitive data categories — including identity documents, payment account details, and authentication credentials — are encrypted at rest within ef98's infrastructure using industry-standard encryption algorithms.
• Access controls: Access to personal data within ef98 is restricted on a strict need-to-know basis. Staff and contractors are granted only the minimum permissions required to perform their specific roles. Access is logged and reviewed regularly.
• Two-factor authentication (2FA): ef98 supports and encourages the use of 2FA for player accounts to provide an additional layer of protection against unauthorised access.
• Regular security assessments: ef98's platform infrastructure undergoes periodic security testing, including vulnerability assessments and penetration testing, to identify and remediate potential weaknesses before they can be exploited.
• Incident response: ef98 maintains a documented data breach response procedure. In the event of a confirmed data security incident affecting your personal data, ef98 will notify you and the relevant authority within the timeframe required under our licensing obligations.

While ef98 takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own account credentials and for notifying ef98 immediately if you suspect any unauthorised access to your account.

As an ef98 player, you hold a number of rights in relation to the personal data we hold about you. ef98 is committed to honouring these rights promptly and without undue formality. The rights available to you are set out below.

To exercise any of the above rights, please contact ef98's support team via live chat or by emailing [email protected]. ef98 will acknowledge your request within a reasonable period and respond fully within the timeframe required under our licensing obligations. We may need to verify your identity before processing a data rights request.

ef98 takes its age verification obligations seriously. All new registrations are subject to age checks, and the platform's KYC process requires submission of a government-issued identity document confirming date of birth. Players in Pakistan are required to confirm, at the point of registration, that they are at least 21 years of age.

Parents and guardians who believe that a minor may have registered on ef98 should contact support immediately at [email protected] so that the matter can be investigated and resolved without delay.

The ef98 platform may contain links to third-party websites, payment provider portals, or gaming content provider interfaces. This Privacy Policy applies solely to data processed by ef98 in connection with the ef98.app platform. ef98 has no control over the privacy practices of third-party sites and accepts no responsibility for the manner in which those parties collect, use, or protect your data.

Players are encouraged to review the privacy policies of any third-party service — including payment providers such as JazzCash and EasyPaisa — before submitting personal information through those services.

ef98 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or our licensing obligations. The effective date at the top of this page will be updated whenever a revision is published.

Where changes are material — meaning they significantly affect your rights or the way your data is used — ef98 will notify registered players via the contact details associated with their account prior to the changes taking effect. For minor or administrative updates, publication of the revised policy on this page constitutes sufficient notice.

Your continued use of ef98 following the effective date of any revised Privacy Policy constitutes your acknowledgement of, and agreement to, the updated terms. If you do not agree with the revised policy, you should discontinue use and may request account closure in accordance with the Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the manner in which ef98 processes your personal data, please reach out to the ef98 support team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly within the ef98 platform — the fastest route for urgent data queries.
• Email: [email protected] — monitored continuously for privacy, account, and compliance enquiries.
• Support Hours: 24 hours, 7 days a week, Pakistan Standard Time (PKT).

Please include your registered ef98 username and a clear description of your query or request when contacting us to ensure the most efficient resolution. For formal data rights requests, ef98 may require identity verification before processing your request.