Privacy Policy — 88ed Platform

This Privacy Policy ("Policy") is published by 88ed, the operator of the website accessible at https://88ed.cam (the "Platform"). It sets out the manner in which 88ed collects, processes, uses, stores, discloses and protects personal data obtained through the Platform.

88ed is an English-language online gambling information and editorial service directed at users in Pakistan. The Platform does not operate a gambling service, accept bets or process financial transactions on behalf of users. The personal data processing described in this Policy relates solely to Platform operations — website analytics, user correspondence and standard web-service infrastructure.

This Policy should be read together with our Terms & Conditions, which govern your use of the Platform and are incorporated into this Policy by reference. By continuing to use the Platform, you acknowledge that you have read and understood this Policy.

For the purposes of this Policy, the following terms carry the meanings set out below:

For the purposes of this Policy, the Data Controller responsible for Personal Data collected through the Platform is:

If you have any questions or requests relating to this Policy or the processing of your Personal Data, please use the contact details above. All correspondence should be in English.

This Policy applies to all Personal Data collected by 88ed in connection with the Platform, including data collected from:

• Visitors who browse the Platform without submitting any contact form or enquiry.
• Users who submit enquiries or correspondence to 88ed by any means.
• Users who interact with any feature of the Platform, including navigation, page views and use of informational tools.

This Policy does not apply to the data practices of third-party gambling operators, payment providers or other external services that may be referenced in Platform content. When you leave the 88ed Platform and interact with any third-party service — including operators such as those that may process PKR deposits via Easypaisa, JazzCash, Raast or other methods — your data is governed exclusively by the privacy policies of those third parties. 88ed has no control over and accepts no responsibility for third-party data practices.

88ed may collect and process the following categories of Personal Data:

88ed does not collect special categories of Personal Data (such as biometric data, health data, financial account credentials or government-issued identity document numbers) through the Platform. Any KYC documentation required by a third-party operator is submitted directly to that operator and is not processed by 88ed.

88ed collects Personal Data through the following methods:

• Automatic collection: When you access the Platform, certain technical and usage data is collected automatically by web server logs and analytics tools. This occurs regardless of whether you submit any form or make any explicit contact.
• Cookies and similar technologies: The Platform uses cookies and comparable tracking technologies to record session information, user preferences and aggregated analytical data. See Section 8 (Cookies & Tracking) for full details.
• User-submitted correspondence: If you contact 88ed by email or through any contact mechanism provided on the Platform, we collect the personal data you voluntarily include in that communication — typically your name, email address and the content of your message.

88ed processes Personal Data only for the specific, legitimate purposes described below. For each purpose, the applicable legal basis is identified:

88ed does not use Personal Data for automated decision-making that produces significant legal or similarly significant effects on Users, nor for profiling for marketing purposes directed at individual Users.

The Platform uses cookies and similar technologies. Cookies are small text files stored on your device when you visit a website. They allow us to recognise your device on return visits and to analyse how the Platform is used.

We do not use cookies to track your activity across third-party websites or to serve targeted advertising.

88ed does not sell, rent or trade Personal Data to any third party. We may share Personal Data in the limited circumstances described below:

• Service Providers (Data Processors): We may share data with carefully selected third-party service providers who process data on our behalf — for example, web hosting providers, content delivery network providers and analytics platforms. These providers operate under contractual data processing agreements that restrict their use of data to the services they provide to 88ed only.
• Legal Compliance: We may disclose Personal Data to law enforcement agencies, regulatory bodies or other authorities where required to do so by applicable law, court order or binding regulatory direction.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of 88ed's business, Personal Data may be transferred as part of that transaction. We will notify Users of any such transfer through a prominent notice on the Platform prior to data being transferred and subject to a new privacy policy.
• Protection of Rights: We may disclose Personal Data where we reasonably believe disclosure is necessary to protect the legal rights, safety or property of 88ed, our users or others.

As an online platform accessible globally, data processed in connection with Platform operations may be transferred to and stored on servers located outside Pakistan. Where such transfers occur, 88ed takes steps to ensure that appropriate safeguards are in place to protect the transferred data, including contractual obligations on receiving parties.

Users in Pakistan should be aware that data protection frameworks vary by country, and that the country receiving transferred data may not provide an equivalent level of statutory data protection to Pakistan. By using the Platform, you acknowledge and accept this.

Where transfers to third-party service providers occur, those providers are required by contract to process data only for the purposes instructed by 88ed and to maintain appropriate security standards.

88ed retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention guidelines apply:

• Technical and Usage Data: Retained in aggregated or anonymised form for ongoing analytics purposes. Individually identifiable technical data (such as IP logs) is retained for a limited period determined by our security and fraud prevention requirements, typically no longer than 12 months from collection unless a specific legal obligation requires longer retention.
• Correspondence Data: Retained for the duration necessary to resolve the relevant enquiry and for a reasonable period thereafter for record-keeping purposes, typically up to 24 months.
• Cookie Data: Session cookies expire at the end of your browser session. Persistent cookies expire in accordance with the specific cookie's configuration, typically no longer than 13 months.

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

88ed implements reasonable and appropriate technical and organisational security measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include:

• HTTPS encryption for all Platform communications using TLS protocols.
• Access controls limiting Personal Data access to authorised personnel only on a need-to-know basis.
• Regular review of data handling processes and security configurations.
• Contractual security obligations imposed on third-party Data Processors.

Notwithstanding these measures, no method of electronic transmission or storage is completely secure. 88ed cannot guarantee the absolute security of Personal Data transmitted to or stored in connection with the Platform. Users transmit data at their own risk.

Subject to applicable law, you may have the following rights in relation to your Personal Data held by 88ed. The precise rights available to you depend on the data protection laws applicable in your jurisdiction:

To exercise any of the above rights, please contact us at [email protected] (plain text — not a clickable link). We will respond within a reasonable timeframe, typically no longer than 30 days from receipt of a valid request. We may ask you to verify your identity before processing certain requests.

Please note that certain rights may be subject to limitations where legal obligations require us to retain data, or where your request would adversely affect the rights of others.

The Platform is strictly restricted to users who are at least 18 years of age, or the higher minimum age required by the operator or licence jurisdiction applicable to the User. 88ed does not knowingly collect Personal Data from individuals under the age of 18.

If we become aware that Personal Data has been submitted by or collected in relation to a minor, we will take prompt steps to delete that data. Parents or guardians who believe that a minor has submitted Personal Data to 88ed are asked to contact us at [email protected] (plain text — not a clickable link) so that we may investigate and take appropriate action.

Platform content may include references to third-party services, organisations and platforms. 88ed does not control and is not responsible for the privacy practices or content of any third-party service.

The Platform may use third-party analytics services to collect aggregated usage statistics. These services operate under their own privacy policies and may use their own tracking technologies subject to their respective terms. 88ed ensures that any analytics provider used does not use Platform data for independent commercial purposes unrelated to providing analytics services to 88ed.

Any third-party CDN libraries used to deliver Platform styling or functionality (such as Bootstrap CSS or font libraries) may log access requests. These logs are managed by the respective CDN providers under their own data policies.

88ed recognises that a substantial portion of its audience is located in Pakistan. The following specific points are provided for Pakistani users:

• Pakistan does not currently have a comprehensive national data protection statute equivalent to the EU's GDPR or similar frameworks. 88ed nonetheless applies data protection standards reflective of internationally recognised privacy principles in its handling of all user data.
• The Prevention of Electronic Crimes Act, 2016 (PECA) and related instruments may be relevant to certain aspects of electronic data processing in Pakistan. 88ed's data practices are conducted with awareness of applicable Pakistani law.
• References to payment methods including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah in Platform content are strictly informational and contextual. 88ed does not transmit user data to those providers and makes no representations about their data practices.
• Users in Pakistan who have concerns about how their data is handled are encouraged to contact 88ed directly using the contact details in Section 18 of this Policy.

88ed reserves the right to update or amend this Privacy Policy at any time. Changes will be published on this page with an updated "Last Updated" date at the top of the document. Where changes are material, we will take reasonable steps to bring them to your attention through a prominent notice on the Platform.

Your continued use of the Platform following publication of any amended Policy constitutes your acknowledgement of and agreement to the amended terms. If you do not accept any changes to this Policy, you must cease using the Platform.

We recommend that you review this page periodically to stay informed of how 88ed handles your Personal Data.

For any questions, concerns, requests or complaints relating to this Privacy Policy or the processing of your Personal Data by 88ed, please contact us using the details below. All correspondence should be submitted in English.

We will acknowledge receipt of your enquiry within a reasonable period and aim to provide a substantive response within 30 days of receiving a complete and valid request.

For matters relating to responsible gambling, age verification or self-exclusion guidance, please also visit our Responsible Gambling page. For general platform terms, see our Terms & Conditions.