1. Introduction
89ef is committed to protecting the privacy and personal data of every player who uses our platform — whether you are placing a cricket bet during the PSL season from Lahore, spinning the slots from Karachi, or enjoying live casino games from Islamabad. This Policy sets out, in clear terms, how we handle data belonging to players across Pakistan and internationally.
This Policy applies to all services offered under the 89ef brand, including our website, mobile-optimised platform, customer support channels, and any related communications we send to you. It should be read alongside our Terms & Conditions and Responsible Gaming Policy, each of which forms part of the overall agreement between you and 89ef.
We operate under an internationally recognised gaming licence and align our data practices with globally accepted privacy standards, including principles derived from the General Data Protection Regulation (GDPR). While Pakistan's data protection landscape continues to develop, 89ef voluntarily applies high-standard data governance practices for the benefit of all our users.
2. Data We Collect
2.1 Information You Provide Directly
When you register for an 89ef account or interact with our platform, we may collect the following categories of personal data:
- Identity Data: Full legal name, date of birth, CNIC number (for KYC verification), nationality, and gender.
- Contact Data: Email address, mobile phone number, and residential address (city, province, country).
- Financial Data: Payment method details (e.g., JazzCash mobile number, EasyPaisa account reference, bank account details for HBL, UBL, or Meezan Bank), transaction history, deposits, withdrawals, and balance records.
- Account Data: Username, hashed password, account preferences, self-imposed limits, and communication preferences.
- Verification Documents: Copies of government-issued identity documents, proof of address, and payment method verification documents submitted during KYC review.
2.2 Information Collected Automatically
When you visit or use the 89ef platform, certain technical data is collected automatically through your device and browser:
- Device & Technical Data: IP address, browser type and version, operating system, device identifiers, and screen resolution.
- Usage Data: Pages visited, games played, bet history, session duration, click patterns, and feature usage within the 89ef platform.
- Location Data: Approximate geographic location derived from your IP address, used for regulatory compliance and fraud prevention. We do not collect precise GPS location data.
- Cookie Data: Session cookies, preference cookies, and analytics cookies as described in Section 6 of this Policy.
2.3 Information from Third Parties
In certain circumstances, 89ef may receive personal data about you from third-party sources, including identity verification service providers (for KYC checks), payment processors, fraud detection agencies, and our licensing authority where required for compliance purposes.
3. How We Use Your Data
89ef processes your personal data only for specific, legitimate purposes. The table below summarises the primary uses of your data and the corresponding lawful basis for each:
| Purpose | Data Used | Lawful Basis |
|---|---|---|
| Account registration and management | Identity, Contact, Account Data | Contract performance |
| Processing deposits and withdrawals | Financial, Identity Data | Contract performance |
| Identity verification (KYC/AML) | Identity, Verification Documents | Legal obligation |
| Fraud prevention and security monitoring | Usage, Device, Financial Data | Legitimate interests |
| Customer support and dispute resolution | Identity, Contact, Account Data | Contract performance |
| Responsible gaming monitoring | Usage, Account, Financial Data | Legal obligation / Legitimate interests |
| Sending service communications | Contact, Account Data | Contract performance |
| Sending promotional communications | Contact, Usage Data | Consent (opt-in) |
| Platform analytics and improvement | Usage, Cookie, Device Data | Legitimate interests |
| Regulatory reporting and compliance | Identity, Financial Data | Legal obligation |
89ef will never use your personal data for purposes that are incompatible with those listed above without first obtaining your explicit consent or establishing a separate lawful basis for the new processing activity.
4. Legal Basis for Processing
Depending on the specific processing activity, 89ef relies on one or more of the following lawful grounds:
- Contract Performance: Processing necessary to deliver the services you have signed up for, including account management, bet settlement, and payment processing.
- Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) laws, KYC obligations imposed by our licensing authority, and responsible gaming mandates.
- Legitimate Interests: Processing necessary for the legitimate interests of 89ef or third parties, such as fraud prevention, platform security, and service analytics — provided that such interests are not overridden by your fundamental privacy rights.
- Consent: Where we rely on your consent (for example, for marketing emails or PSL promotional messages), you may withdraw that consent at any time by contacting our support team or using the unsubscribe link in any marketing communication.
5. Data Sharing & Disclosure
5.1 Service Providers
89ef shares personal data with carefully selected third-party service providers who assist in delivering our platform. These include payment gateway operators (for processing JazzCash, EasyPaisa, and bank transactions), identity verification providers, cloud hosting and infrastructure providers, customer support software vendors, and analytics platforms. All such providers are bound by data processing agreements and are prohibited from using your data for any purpose other than providing the contracted service to 89ef.
5.2 Legal and Regulatory Disclosures
We may disclose your personal data to regulatory authorities, law enforcement agencies, or courts when required to do so by law, court order, or a valid legal process. This includes disclosures required under AML regulations or instructions from our licensing jurisdiction. 89ef will only provide the minimum amount of data necessary to satisfy each such requirement.
5.3 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of all or part of 89ef's business, your personal data may be transferred to the successor entity as part of the transaction. You will be notified of any such transfer and the privacy implications via our standard communication channels.
5.4 No Sale of Data
89ef does not, and will never, sell, rent, or commercially exploit your personal data to third-party marketers, data brokers, or advertisers. Your data is not a commodity — it is a trust that we take seriously.
6. Cookies & Tracking Technologies
89ef uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the platform. We categorise our cookies as follows:
- Essential Cookies: Required for core platform functionality, including keeping you logged into your 89ef session and maintaining your preferences. These cannot be disabled without affecting platform usability.
- Analytics Cookies: Used to understand how players navigate and use the 89ef platform, which pages are most popular, and where technical issues occur. This data is aggregated and anonymised.
- Functional Cookies: Used to remember your language preference, display settings, and other personalisation choices between visits.
89ef does not use third-party advertising or cross-site tracking cookies. You can control or delete cookies through your browser settings at any time, though disabling essential cookies may limit your ability to use certain features of the 89ef platform.
7. Data Retention
89ef retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by law. Our standard retention periods are as follows:
- Active account data: Retained for the lifetime of your 89ef account plus 5 years following account closure, in line with AML record-keeping requirements.
- KYC and verification documents: Retained for a minimum of 5 years after the end of the customer relationship, as required by international AML standards.
- Transaction records: Retained for 7 years for financial audit and regulatory compliance purposes.
- Marketing consent records: Retained until consent is withdrawn, plus an additional 2 years as evidence of the consent obtained.
- Technical and usage logs: Typically retained for 12 months for security monitoring and platform improvement purposes.
When data is no longer required, 89ef securely deletes or anonymises it in accordance with our internal data destruction procedures.
8. Your Rights
As a user of the 89ef platform, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team at [email protected]. We will respond within 30 days of receiving your request.
9. Data Security
89ef implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:
- AES-256 encryption for data at rest and TLS 1.2+ for all data in transit between your device and our servers.
- Multi-factor authentication requirements for all internal staff accessing player data systems.
- Regular third-party penetration testing and vulnerability assessments of our platform infrastructure.
- Role-based access controls ensuring that only authorised personnel with a legitimate need can access personal data.
- Continuous monitoring systems that detect and alert on unusual access patterns or potential security incidents in real time.
- Formal incident response procedures that are activated immediately in the event of a suspected or confirmed data breach.
While 89ef takes every reasonable precaution to protect your data, no digital platform can guarantee absolute security. You play an important role too — always use a strong, unique password for your 89ef account and never share your login credentials with anyone.
10. Minors & Age Verification
89ef strictly prohibits the use of our platform by individuals under the age of 21 years. We do not knowingly collect or process personal data belonging to minors. During registration, all players are required to confirm their age and submit to identity verification procedures that include date-of-birth validation.
If 89ef becomes aware that personal data has been collected from a minor without parental consent, we will take immediate steps to delete that data and close the relevant account. Parents or guardians who believe their child has registered on the 89ef platform are urged to contact us immediately at [email protected].
11. International Data Transfers
As an internationally licensed gaming platform, 89ef may transfer personal data to countries outside Pakistan as part of our normal operations — for example, when using cloud infrastructure hosted abroad or when working with international service providers. Where such transfers occur, 89ef ensures that appropriate safeguards are in place, including:
- Data processing agreements that include standard contractual clauses providing equivalent protections to those available within Pakistan.
- Transfers only to jurisdictions that maintain adequate data protection standards as recognised by our licensing authority.
- Regular reviews of our third-party suppliers to ensure ongoing compliance with data transfer obligations.
12. Changes to This Privacy Policy
89ef may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or the services we offer. When we make material changes, we will notify active players via email or a prominent on-platform notification prior to the changes taking effect.
The "Effective Date" displayed at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Policy periodically. Your continued use of the 89ef platform following the posting of any updated Policy constitutes your acknowledgment of the changes.
13. Contact & Complaints
If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a complaint about how 89ef has handled your personal information, please contact our dedicated Data Privacy team:
Email: [email protected]
Live Chat: Available 24/7 directly on the 89ef platform (average response: 3–5 minutes)
Email Response Time: Within 2–4 hours for general queries; up to 30 days for formal data subject requests
We take all privacy complaints seriously and will investigate every concern raised. If you remain dissatisfied with our response, you have the right to escalate your complaint to the relevant regulatory authority in your jurisdiction.
Last reviewed and updated: 1 January 2026. This Privacy Policy supersedes all previous versions published on this domain.