Privacy Policy — 98tb

1. Introduction

98tb ("we", "us", "our") is committed to protecting the privacy and personal data of every individual who uses the 98tb platform at https://98tb.org. This Privacy Policy sets out, in full, how 98tb collects, processes, stores, shares, and protects your personal data in connection with your use of the Platform, including our online casino, sports betting, and associated account services.

This Policy applies to all current and former registered players, prospective players who interact with the Platform without completing registration, and any individual whose personal data is processed by 98tb in connection with the services we provide. By accessing the 98tb Platform or creating an Account, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which contain provisions relevant to how your Account data is managed.

2. Data Controller

For the purposes of applicable data protection legislation, 98tb is the data controller in respect of personal data collected through the Platform. As data controller, 98tb determines the purposes for which and the means by which your personal data is processed. Our licensing authority's jurisdiction governs the legal framework under which we operate as a data controller.

Where 98tb engages third-party service providers to process personal data on our behalf — such as KYC verification providers, payment processors, or fraud detection services — those third parties act as data processors under binding data processing agreements that require them to process your data only on 98tb's documented instructions and in accordance with appropriate security standards.

3. Data We Collect

3.1 Registration Data

When you create a 98tb Account, we collect the following information:

• Full legal name (as it appears on your CNIC)
• Date of birth (used to verify the 21+ age requirement)
• Residential address in Pakistan
• Pakistani mobile number
• Email address
• Username and encrypted password

3.2 Identity Verification (KYC) Data

To comply with our international gaming licence obligations and applicable anti-money laundering requirements, we collect and verify:

• CNIC (Computerised National Identity Card) number and scanned copy
• Proof of address documentation where required
• Payment method ownership documentation (e.g., screenshot of JazzCash or EasyPaisa account in your name)
• Selfie or photograph for biometric identity matching, where requested

3.3 Financial Transaction Data

We record full details of all financial transactions conducted through your Account, including:

• Deposit amounts, timestamps, and payment method identifiers
• Withdrawal requests, amounts, and settlement details
• Bonus credits, wagering activity, and bonus settlement outcomes
• Account balance history

3.4 Gaming and Betting Activity Data

We maintain detailed records of all gaming and sports betting activity on your Account, including game titles played, bet amounts, outcomes, session durations, and responsible gaming tool activations. This data is used for account management, dispute resolution, fraud detection, and responsible gaming monitoring.

3.5 Technical and Device Data

When you access the 98tb Platform, we automatically collect certain technical data, including:

• IP address and approximate geographic location derived from IP
• Browser type, version, and language settings
• Device type, operating system, and screen resolution
• Referring URL and pages visited within the Platform
• Session timestamps and interaction logs

3.6 Communications Data

We retain records of all communications between you and 98tb, including live chat transcripts, support ticket exchanges, and email correspondence. This data is retained for quality assurance, dispute resolution, and regulatory compliance purposes.

4. How We Use Your Data

The table below summarises the primary purposes for which 98tb processes your personal data:

5. Legal Basis for Processing

98tb processes your personal data under one or more of the following legal bases:

• Contractual Necessity: Processing is required to perform our obligations under the agreement formed when you register an Account and accept our Terms & Conditions — for example, processing your deposits and paying out your winnings.
• Legal Obligation: Processing is necessary for 98tb to comply with its obligations under applicable law and the conditions of our international gaming licence — including KYC verification, age verification, anti-money laundering checks, and responsible gaming requirements.
• Legitimate Interest: Processing is necessary for the purposes of 98tb's legitimate business interests, where those interests are not overridden by your own privacy rights — for example, fraud prevention, platform security, and service improvement analytics.
• Consent: In certain limited circumstances, such as sending you promotional email communications, 98tb will only process your data where you have given clear, informed, and freely given consent. You may withdraw this consent at any time by contacting our support team or using the unsubscribe function in any marketing email.

6. Data Sharing & Third Parties

6.1 Service Providers

98tb shares personal data with a limited number of trusted third-party service providers who assist in delivering the Platform and its services. These include KYC and identity verification providers, payment processors (including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank infrastructure partners), fraud detection and cybersecurity services, cloud infrastructure providers, and customer support tooling providers. All such providers are bound by data processing agreements and are prohibited from using your data for their own independent purposes.

6.2 Regulatory and Licensing Authorities

98tb is required by the terms of its international gaming licence to provide certain player data to the relevant licensing and regulatory authority on request. This may include transaction histories, KYC records, and responsible gaming tool activations. Such disclosures are made only to the extent required by our legal and licensing obligations.

6.3 Law Enforcement

98tb will disclose personal data to law enforcement agencies, courts, or government bodies where we are legally compelled to do so, or where disclosure is necessary to prevent fraud, money laundering, or other criminal activity. We will, where legally permitted, notify affected players of any such disclosure.

6.4 No Sale of Data

98tb does not and will never sell, rent, license, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. This commitment is absolute and is not subject to any business arrangements or corporate transactions.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or a substantial portion of 98tb's business assets, personal data held by 98tb may be transferred as part of that transaction. In such circumstances, 98tb will take reasonable steps to ensure that the acquiring entity is bound by data protection obligations equivalent to those described in this Privacy Policy, and affected players will be notified in advance of any material change to how their data is processed.

7. Cookies & Tracking Technologies

7.1 What We Use

The 98tb Platform uses cookies and similar tracking technologies to operate correctly and deliver a personalised experience. Cookies are small data files placed on your device when you visit the Platform. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled without breaking core features such as login sessions and account security.
• Performance Cookies: Collect anonymised data about how visitors interact with the Platform, used to improve usability and identify technical issues.
• Functional Cookies: Remember your preferences such as language settings, display options, and previously used payment methods to streamline your experience.
• Analytics Cookies: Used to understand aggregate usage patterns across the Platform. Data collected via analytics cookies is not linked to personally identifiable information.

7.2 Managing Cookies

You can control cookie settings through your browser preferences. Disabling certain categories of cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be refused as they are essential for secure session management.

8. Data Retention

98tb retains your personal data only for as long as is necessary for the purposes described in this Privacy Policy, or as required by applicable law and our gaming licence obligations. The following retention periods apply as a general guide:

• Account and registration data: Retained for the duration of your Account plus a minimum of 5 years following Account closure, as required by our licensing authority for regulatory audit purposes.
• KYC and identity verification documents: Retained for a minimum of 5 years from the date of verification or Account closure, whichever is later, in compliance with anti-money laundering regulations.
• Financial transaction records: Retained for a minimum of 7 years from the date of the transaction to satisfy financial record-keeping requirements.
• Customer support communications: Retained for 3 years from the date of the relevant interaction, or longer if the communication relates to an unresolved dispute.
• Technical and device data: Retained in identifiable form for up to 13 months, after which it is anonymised or deleted.
• Marketing consent records: Retained for the period of your consent plus 3 years following withdrawal of consent.

Following the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where data has been anonymised, it may be retained indefinitely for statistical and service improvement purposes.

9. Data Security

98tb implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 98tb Platform
• AES-256 encryption for sensitive data stored at rest, including KYC documents and payment information
• Multi-factor authentication options for player Accounts
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular independent penetration testing and security audits of our infrastructure
• 24/7 automated intrusion detection and anomaly monitoring systems
• Secure, geographically redundant data storage with access logging

In the event of a personal data breach that poses a risk to your rights and interests, 98tb will notify the relevant supervisory authority and, where required, affected players within the timeframes prescribed by applicable law.

While 98tb takes every reasonable precaution to secure your data, no internet-based system can guarantee absolute security. You are also responsible for keeping your Account login credentials confidential and for using a strong, unique password for your 98tb Account.

10. Your Privacy Rights

Subject to applicable data protection law and the conditions of our gaming licence, you hold the following rights in respect of your personal data held by 98tb:

• Right of Access: You may request a copy of all personal data that 98tb holds about you. We will provide this within 30 days of a valid request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Corrections to KYC data may require resubmission of identity documents.
• Right to Erasure: In certain circumstances, you may request the deletion of your personal data. This right is subject to limitations where retention is required by law or our licensing obligations — for example, financial transaction records must be retained for a minimum of 7 years regardless of a deletion request.
• Right to Restrict Processing: You may request that 98tb restricts the processing of your data in specific circumstances, for example while a correction request is being assessed.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you may request a machine-readable copy of the personal data you have provided to 98tb.
• Right to Object: You have the right to object to processing based on legitimate interest, including profiling for fraud prevention. We will assess your objection and respond with our decision and reasons.
• Right to Withdraw Consent: Where processing is based solely on your consent (such as marketing emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact us at [email protected]. We will respond to all valid requests within 30 days. In complex cases, we may extend this period by a further 60 days, but we will inform you of any extension within the initial 30-day period.

11. Children & Minors

The 98tb Platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect personal data from persons under the age of 21. Age verification is a mandatory step in our Account registration and KYC processes.

If 98tb discovers that personal data has been collected from a person under 21 years of age, the relevant Account will be immediately suspended, all data associated with that Account will be reviewed, and any funds deposited will be handled in accordance with our Responsible Gaming Policy and applicable licensing obligations.

Parents and guardians who believe that a minor may have registered on the 98tb Platform are encouraged to contact us immediately at [email protected] so that we can investigate and take appropriate action without delay.

12. Marketing Communications

98tb may send you promotional communications — including bonus offers, new game announcements, and platform updates — by email or in-platform notification, where you have given your explicit consent to receive such communications at the time of registration or subsequently through your Account settings.

You may opt out of marketing communications at any time by:

• Clicking the unsubscribe link in any marketing email sent by 98tb
• Updating your communication preferences in your Account settings
• Contacting our support team at [email protected] with a written opt-out request

Opting out of marketing communications will not affect transactional communications — such as deposit confirmations, withdrawal notifications, and security alerts — which are sent as a necessary part of operating your Account and cannot be disabled.

13. International Data Transfers

As an internationally licensed gaming platform, 98tb may transfer your personal data to servers and third-party service providers located outside Pakistan. Where such international transfers occur, 98tb ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under our licensing jurisdiction's data protection framework.

Safeguards for international transfers may include:

• Standard contractual clauses approved by the relevant data protection authority
• Binding corporate rules where transfers occur within the 98tb corporate group
• Transfer to jurisdictions recognised as providing an adequate level of data protection

You may request details of the specific safeguards applicable to any international transfer of your personal data by contacting us at [email protected].

14. Policy Amendments

98tb reserves the right to update or amend this Privacy Policy at any time. Changes may be made to reflect updates to our data practices, new features or services on the Platform, changes in applicable law, or conditions imposed by our licensing authority. The effective date at the top of this page will be updated whenever a new version of this Policy is published.

Where amendments are material — meaning they significantly affect how your personal data is processed or your rights in relation to it — 98tb will provide advance notice to registered players via email or a prominent notice on the Platform. For non-material amendments, continued use of the Platform following publication of the updated Policy constitutes acceptance of the revised terms.

We recommend that you review this Privacy Policy periodically to stay informed of how 98tb protects your personal data. The current version is always accessible at https://98tb.org/privacy-policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way in which 98tb processes your personal data, please contact our dedicated privacy support team using the details below:

• Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week
• Live Chat: Available via the 98tb Platform after login

For questions about our responsible gaming tools or self-exclusion options, please visit our Responsible Gaming page. For full details of your contractual rights as a player, please refer to our Terms & Conditions.

We are committed to resolving all privacy-related queries fairly and promptly. If you remain unsatisfied with our response to a data rights request, you have the right to escalate your complaint to the supervisory authority in the jurisdiction under which 98tb holds its international gaming licence.