Privacy Policy — e98win

1 Introduction

This Privacy Policy ("Policy") is issued by e98win (referred to herein as "e98win", "we", "us" or "our"), the operator of the online betting and live casino platform accessible at e98win.cam (the "Platform").

This Policy explains how e98win collects, uses, stores, discloses, transfers and protects the personal data of individuals who register an account, visit the Platform or otherwise interact with our services ("Users", "you" or "your"). It applies to all personal data we process in connection with the operation of the Platform, including data collected through the website, mobile interfaces, customer support channels and payment processing flows.

By using the Platform, you acknowledge that you have read and understood this Policy. This Policy should be read together with our Terms & Conditions and our Responsible Gambling Policy.

2 Definitions

3 Data We Collect

e98win collects Personal Data in the following categories, depending on your interaction with the Platform:

3.1 Registration and Account Data

• Full legal name and date of birth.
• Email address and (where provided) mobile phone number.
• Country of residence and, where requested, city (such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar).
• Preferred account currency (e.g., PKR).
• Username and encrypted password credentials.

3.2 Identity Verification (KYC) Data

• Copy of a government-issued identity document — for Pakistani users, typically a Computerised National Identity Card (CNIC) or valid passport.
• Proof of address documentation where required.
• Selfie or liveness-check image submitted during verification.
• Payment method verification documents (e.g., screenshot of a JazzCash, Easypaisa or bank account in your name).

3.3 Financial and Transactional Data

• Deposit and withdrawal transaction records, including amounts (in PKR or other currencies), timestamps and payment method references.
• Betting history: markets wagered on, stake amounts and settlement outcomes.
• Bonus and promotional activity records.

3.4 Technical and Device Data

• IP address and approximate geographic location derived therefrom.
• Device type, operating system, browser type and version.
• Session duration, pages visited, click-path data and referral source.
• Cookie identifiers and similar tracking technologies (see Section 9).

3.5 Communications Data

• Records of correspondence with customer support, including live chat transcripts and emails.
• Feedback, complaints and dispute records.

3.6 Responsible Gambling Data

• Self-imposed limits (deposit caps, loss limits, session timers) set through the account dashboard.
• Self-exclusion requests and their duration.
• Any information shared in the context of responsible gambling support interactions.

4 How We Use Your Personal Data

e98win processes your Personal Data for the following purposes:

e98win does not use your Personal Data for automated decision-making that produces legal effects or similarly significant outcomes without human review.

5 Legal Basis for Processing

Where internationally recognised data protection frameworks apply to our processing activities, we rely on one or more of the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations to you under the Terms & Conditions — such as account management, payment processing and providing betting services.
• Legal obligation: Processing required to comply with applicable laws — including anti-money laundering (AML) regulations, KYC obligations and any direction from a competent regulatory authority.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gambling enforcement and service improvement, where those interests are not overridden by your privacy rights.
• Consent: Where we rely on consent (for example, for optional marketing communications), you may withdraw that consent at any time by contacting us using the details in Section 15.

6 Data Sharing and Third-Party Disclosure

e98win does not sell, rent or trade your Personal Data to third parties. We may share your data with the following categories of recipient, strictly on a need-to-know basis and subject to appropriate data protection obligations:

6.1 Service Providers and Data Processors

• KYC and identity verification providers: Third-party services used to verify identity documents, conduct liveness checks and screen against sanction lists.
• Payment processing partners: Entities that facilitate deposit and withdrawal transactions. This may include mobile wallet integrators and bank gateway partners. These providers process only the financial data necessary to execute your transaction. Note that Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced as familiar payment instruments — their involvement in any transaction is governed by their own terms and they do not endorse this Platform.
• Technology and infrastructure providers: Cloud hosting, content delivery and security service providers that support the technical operation of the Platform.
• Customer support tools: Live chat and email support software providers who process communication records on our behalf.
• Analytics providers: Where we use analytics tools, data is aggregated and/or anonymised to the greatest extent practicable.

6.2 Legal and Regulatory Disclosure

We may disclose your Personal Data to competent authorities, courts, regulators or law enforcement bodies where required to do so by applicable law, a valid court order, or to protect the rights and interests of e98win, our users or the public.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of assets involving e98win, your Personal Data may be transferred to the successor entity, subject to equivalent data protection obligations.

7 International Data Transfers

e98win operates internationally and your Personal Data may be transferred to, and processed in, countries outside your country of residence. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place — such as contractual data protection obligations with service providers — to protect your data to a standard consistent with this Policy.

8 Data Retention

e98win retains your Personal Data for as long as is necessary for the purposes for which it was collected, subject to the following considerations:

• Active accounts: Personal Data is retained for the duration of your account's active status plus any mandatory retention period required by applicable law or the operator's licence obligations.
• KYC documents: Identity and verification documents are retained for a minimum period following account closure as required by applicable AML obligations. This period may extend to five (5) years or more depending on the applicable jurisdiction.
• Transaction records: Financial transaction records, betting history and payment logs are retained for the period required by applicable financial record-keeping obligations.
• Support communications: Customer support records are retained for a reasonable period to facilitate dispute resolution and quality assurance.
• Closed accounts: Upon account closure, actively accessible Personal Data is suppressed or deleted in accordance with applicable retention schedules. Certain data may be retained in audit logs or archival systems for legal compliance purposes.

9 Cookies and Tracking Technologies

e98win uses cookies and similar client-side tracking technologies on the Platform for the following purposes:

• Essential / functional cookies: Required for the Platform to operate — managing login sessions, remembering your language or currency preference, and maintaining shopping-cart-equivalent state in the cashier. These cannot be disabled without impairing core Platform functionality.
• Security cookies: Used to detect fraudulent sessions, prevent cross-site request forgery attacks and enforce rate limits on login attempts.
• Analytics cookies: Used to understand aggregate usage patterns — which pages are visited, how long sessions last, and where users arrive from. Data is used in aggregated or anonymised form for Platform improvement purposes.
• Preference cookies: Remember settings you have configured, such as responsible gambling limits displayed or notification preferences.

10 KYC Document Handling

Because KYC documents contain particularly sensitive personal data — including government-issued identity numbers, facial images and financial records — e98win applies heightened handling standards to this category of data.

• KYC documents must only be submitted through the secure HTTPS verification portal within your Account dashboard.
• Documents submitted via unencrypted email, social media or unverified third-party channels will not be accepted and will be discarded.
• Access to KYC documents within e98win is restricted on a strict need-to-know basis to authorised compliance personnel only.
• Documents are stored using encryption at rest and access is logged for audit purposes.
• e98win will never instruct you to send documents to personal email addresses or informal messaging channels. If you receive such a request, treat it as a potential phishing attempt and contact us immediately.

11 Your Data Rights

Depending on applicable law and your relationship with the Platform, you may hold some or all of the following rights with respect to your Personal Data. To exercise any of these rights, contact us using the details in Section 15.

We will respond to all legitimate rights requests within a reasonable timeframe. We may need to verify your identity before processing a request to ensure we are disclosing data to the correct individual.

12 Children's Privacy

The Platform is strictly intended for adults aged 18 or above — or the higher minimum age required by the operator's licence jurisdiction. e98win does not knowingly collect Personal Data from individuals under the applicable minimum age. If we discover or are notified that Personal Data has been collected from an underage user, we will immediately suspend the Account, delete or restrict the relevant data, and take appropriate steps as required by applicable law.

If you believe a minor has registered an Account on the Platform, please contact us immediately at the address in Section 15.

13 Security Measures

e98win implements technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• HTTPS / TLS encryption for all data transmitted between your device and the Platform.
• Encryption at rest for sensitive data categories including KYC documents and payment credentials.
• Access controls: internal access to Personal Data is restricted to authorised personnel on a need-to-know basis, with access logs maintained for audit purposes.
• Regular security assessments of Platform infrastructure and third-party service providers.
• Two-factor authentication (2FA) options for User accounts.
• Session management controls including automatic logout after periods of inactivity.

In the event of a data breach that poses a risk to your rights, we will notify affected users and relevant authorities in accordance with applicable obligations.

14 Amendments to this Policy

e98win reserves the right to amend, update or replace this Privacy Policy at any time. Where material changes are made, we will endeavour to notify you via the Platform or by email to your registered address. The date of the most recent review is displayed at the top of this page.

Your continued use of the Platform following publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with an updated Policy, you should cease using the Platform and request account closure.

15 Contact Us

For all privacy-related enquiries, data subject access requests, complaints or questions about this Policy, please contact our support team. We aim to respond to all legitimate privacy requests within a reasonable period.